On August 15, 2014 a
Party Discovery
was filed
involving a dispute between
Johnson, Willie,
and
Lifestyle Lift Florida East Pa,
Mucci, M.D., Wayne,
Scientific Image Center Management, Inc.,
for Professional Malpractice - Medical
in the District Court of Broward County.
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Case Number: CACE-14-015935 Division: 14
Filing # 17171330 Electronically Filed 08/15/2014 04:58:25 PM
IN THE 17" JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.
FLA. BAR NO. 305553
WILLIE JOHNSON,
Plaintiff,
VS.
WAYNE MUCCI, D.O.;
SCIENTIFIC IMAGE CENTER
MANAGEMENT, INC.;
LIFESTYLE LIFT FLORIDA EAST, P.A.
d/b/a LIFESTYLE LIFT; and LIFESTYLE
LIFT FLORIDA EAST, P.A. a/k/a
LIFESTYLE LIFT SKINCARE, LLC,
Defendants.
PEE,
PLAINTIFF'S REQUEST FOR PRODUCTION TO DEFENDANT,
WAYNE MUCCI, D.O.
COMES NOW, the Plaintiff, WILLIE JOHNSON, by and through the
undersigned attorneys, pursuant to F.R.Civ.P. 1.350, requests the Defendant,
WAYNE MUCCI, D.O., to produce the following at the offices of MALOVE
HENRATTY, P.A.
1. Please produce any contracts and/or agreements between
WAYNE MUCCI, M.D. and/or LIFESTYLE LIFT FLORIDA EAST, P.A. d/b/a
LIFESTYLE LIFT and all groups that provided care and treatment to WILLIE
JOHNSON.
2. Please produce any and ail bills/invoices for services rendered to
WILLIE JOHNSON by all Defendants herein.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/15/2014 4:58:23 PM.****3. Please produce all medical records, written notes, X-rays, bills,
photographs, diagnostic testing, and any other pertinent documents or reports
concerning your treatment of WILLIE JOHNSON. Please understand the request
asks you to provide copies of every written note or communication you have
regarding WILLIE JOHNSON whether it be notes on your file jacket,
correspondence, telephone notes, or anything of the like.
4. Please provide a typed verbatim transcription of any hand-written
records prepared by WAYNE MUCCI, M.D. and/or LIFESTYLE LIFT FLORIDA
EAST, P.A. d/b/a LIFESTYLE LIFT regarding any treatment provided to WILLIE
JOHNSON. f
DATED this be day of August, 2014.
MALOVE HENRATTY, P.A.
Attorneys for Plaintiff
14 Rose Drive
Fort Lauderdale, FL 33316
Telephone: (954) 767-1000
Facsimile: (954) 767-1001
By: SC
STEPHEN L. MALOVE
Fla. Bar No. 305553
Document Filed Date
August 15, 2014
Case Filing Date
August 15, 2014
Category
Professional Malpractice - Medical
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Case Number: CACE-14-015935 Division: 14 Filing # 17171330 Electronically Filed 08/15/2014 04:58:25 PM IN THE 17" JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. FLA. BAR NO. 305553 WILLIE JOHNSON, Plaintiff, VS. WAYNE MUCCI, D.O.; SCIENTIFIC IMAGE CENTER MANAGEMENT, INC.; LIFESTYLE LIFT FLORIDA EAST, P.A. d/b/a LIFESTYLE LIFT; and LIFESTYLE LIFT FLORIDA EAST, P.A. a/k/a LIFESTYLE LIFT SKINCARE, LLC, Defendants. PEE, PLAINTIFF'S REQUEST FOR PRODUCTION TO DEFENDANT, WAYNE MUCCI, D.O. COMES NOW, the Plaintiff, WILLIE JOHNSON, by and through the undersigned attorneys, pursuant to F.R.Civ.P. 1.350, requests the Defendant, WAYNE MUCCI, D.O., to produce the following at the offices of MALOVE HENRATTY, P.A. 1. Please produce any contracts and/or agreements between WAYNE MUCCI, M.D. and/or LIFESTYLE LIFT FLORIDA EAST, P.A. d/b/a LIFESTYLE LIFT and all groups that provided care and treatment to WILLIE JOHNSON. 2. Please produce any and ail bills/invoices for services rendered to WILLIE JOHNSON by all Defendants herein. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/15/2014 4:58:23 PM.****3. Please produce all medical records, written notes, X-rays, bills, photographs, diagnostic testing, and any other pertinent documents or reports concerning your treatment of WILLIE JOHNSON. Please understand the request asks you to provide copies of every written note or communication you have regarding WILLIE JOHNSON whether it be notes on your file jacket, correspondence, telephone notes, or anything of the like. 4. Please provide a typed verbatim transcription of any hand-written records prepared by WAYNE MUCCI, M.D. and/or LIFESTYLE LIFT FLORIDA EAST, P.A. d/b/a LIFESTYLE LIFT regarding any treatment provided to WILLIE JOHNSON. f DATED this be day of August, 2014. MALOVE HENRATTY, P.A. Attorneys for Plaintiff 14 Rose Drive Fort Lauderdale, FL 33316 Telephone: (954) 767-1000 Facsimile: (954) 767-1001 By: SC STEPHEN L. MALOVE Fla. Bar No. 305553