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Filing # 22691554 E-Filed 01/19/2015 12:03:46 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY,
FLORIDA
BARBARA WILLIAMSON
Case No.: CACE 14-016683 (03)
Plaintiff,
VS,
WYNMOOR COMMUNITY COUNCIL, INC.,
a Florida Non Profit Corporation,
Defendant.
/
PLAINTIFF’S NOTICE OF OBJECTION TO NOTICE OF PRODUCTION FROM NON
PARTY DATED JANUARY 8, 2015 AND INSTRUCTIONS TO THE CLERK
The Plaintiff, BARBARA WILLIAMSON, by and through his undersigned counsel,
herewith files this Objection to Notice of Production from Non Party dated January 8, 2015,
pursuant to Florida Rule of Civil procedure 1.351(b), to:
1, GEORGE ROFFMAN, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S
MENTAL CONDITION
2. VIVIAN ROSE, M.D, AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S
MENTAL CONDITION
3. PHOENIX EMERGENCY MEDICINE OF BROWARD AS TO PRODUCTION
OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR
RECORDS OF PLAINTIFF’S MENTAL CONDITION
4. STEVEN FOSTER, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S
MENTAL CONDITION
3. ALLERGY ASSOCIATES OF FLORIDA AS TO PRODUCTION OF
PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS
OF PLAINTIFF’S MENTAL CONDITION
** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/19/2015 12:03:46 PM.****ll.
12.
13,
15.
CHARLES RUSSO, ESQ. (SIC) AS TO PRODUCTION OF ANY AND ALL
RECORDS.
NORMAN KLEIN, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S
MENTAL CONDITION
DR. PHILIP ROSENFELD/DR. ELENA ROTH AS TO PRODUCTION OF
PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR
RECORDS OF PLAINTIFF’S MENTAL CONDITION
SALOMON ESQUENAZI, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFFS
MENTAL CONDITION
JONATHAN HARRIS, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S
MENTAL CONDITION
MICHAEL LOEFFLER AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFFS
MENTAL CONDITION
KELLY BALDWIN, M.D. AS TO PRODUCTION OF ANY AND ALL
RECORDS AS THE RECORDS ARE IRRELEVANT, AND THE REQUEST IS
VAGUE, OVERBROAD AND NOT REASONABLY CALCULATED TO LEAD
TO THE DISCOVERY OF ADMISSIBLE EVIDENCE (UROLOGIST)
DR. RONALD COHEN/DR. MARSHAL KAPLAN AS TO PRODUCTION OF
ANY AND ALL RECORDS AS THE RECORDS ARE IRRELEVANT, AND
THE REQUEST IS VAGUE, OVERBROAD AND NOT REASONABLY
CALCULATED TO LEAD TO THE DISCOVERY OF ADMISSIBLE
EVIDENCE (UROLOGIST)
CHRISTOPHER GOMEZ, M.D. AS TO PRODUCTION OF ANY AND ALL
RECORDS AS THE RECORDS ARE IRRELEVANT, AND THE REQUEST IS
VAGUE, OVERBROAD AND NOT REASONABLY CALCULATED TO LEAD
TO THE DISCOVERY OF ADMISSIBLE EVIDENCE (UROLOGIST)
IRVING DAVID, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S
MENTAL CONDITION16.
19,
20.
21.
22.
23,
24,
25.
26.
DR. NICHOLAS KATZ/DR. JEFFREY SCHNEIDER/DR. EDWARD DEUTSCH
AS TO PRODUCTION OF ANY AND ALL RECORDS AS THE RECORDS
ARE IRRELEVANT, AND THE REQUEST IS VAGUE, OVERBROAD AND
NOT REASONABLY CALCULATED TO LEAD TO THE DISCOVERY OF
ADMISSIBLE EVIDENCE (GASTROENTEROLOGIST)
DR. ANDREW KRINSKY AS TO PRODUCTION OF ANY AND ALL
RECORDS AS. THE RECORDS ARE IRRELEVANT, AND THE REQUEST IS
VAGUE, OVERBROAD AND NOT REASONABLY CALCULATED TO LEAD
TO THE DISCOVERY OF ADMISSIBLE EVIDENCE (GYNEGOLOGIST)
DR. FRANCES SANDLER-SILVER AS TO PRODUCTION OF
PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS
OF PLAINTIFF'S MENTAL CONDITION
DR. DANIEL BRANWEIN AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFFS
MENTAL CONDITION
HOLY CROSS HOSPITAL AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S
MENTAL CONDITION
HOLY CROSS HOSPITAL ~ RADIOLOGY DEPARTMENT AS TO
PRODUCTION OF RECORDS OF PLAINTIFF’S MENTAL CONDITION
HOLY CROSS HOSPITAL ~ BILLING DEPARTMENT AS TO PRODUCTION
OF RECORDS OF PLAINTIFF’S MENTAL CONDITION
ROHAN FARIA AS TO PRODUCTION OF ANY AND ALL RECORDS AS
THE RECORDS ARE IRRELEVANT, AND THE REQUEST IS VAGUE,
OVERBROAD AND NOT REASONABLY CALCULATED TO LEAD TO THE
DISCOVERY OF ADMISSIBLE EVIDENCE
(ONCOLOGIST/HEMATOLOGIST)
RUBEN UNGARO, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S
MENTAL CONDITION
CESAR ALEGRE, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S
, MENTAL CONDITION
LYMPHATX, INC, AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S
MENTAL CONDITION27.
28.
29.
30.
VEIN CLINIC OF AMERICA AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S
MENTAL CONDITION
FLORIDA PHLEBOLOGY, P.A. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S
MENTAL CONDITION
BARNEY HORVATH, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL
AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S
MENTAL CONDITION
OVATIONS, INC. UNITED HEALTHCARE GROUP AS TO PRODUCTION OF
LOST WAGE BENEFITS. THE DOCUMENTS SOUGHT ARE IRRELEVANT
AS PLAINTIFF IS NOT MAKING A CLAIM FOR LOST WAGES.
COUNSEL FOR DEFENDANT IS HEREBY INSTRUCTED NOT TO ISSUE THE
REQUESTED SUBPOENAS
CERTIFICATE OF SERVICE
IT HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Electronic
Mail to: John D. Golden, Esq., jgolden@goldengrimes.com and
phoskin@goldengrimes.com; counsel for the Defendant, Golden & Grimes, LLP, 9350 South Dixie
Highway, Penthouse II, Miami, Florida 33156 on this / 9 day of January, 2015.
LAW OFFICES OF ANIDJAR & LEVINE, PA
Attorneys for Plaintiff
12 SE 7" Street Suite 604
Ft. Lauderdale, FL 33301
Phone: (954) 525-0050/Fax (954) 525-0020
Email for pleadings — pleadings@an]-law.com
See >
By: eee
GLEN B. LEVINE, ESQ.
FBN: 0144355
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Filing # 22691554 E-Filed 01/19/2015 12:03:46 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA BARBARA WILLIAMSON Case No.: CACE 14-016683 (03) Plaintiff, VS, WYNMOOR COMMUNITY COUNCIL, INC., a Florida Non Profit Corporation, Defendant. / PLAINTIFF’S NOTICE OF OBJECTION TO NOTICE OF PRODUCTION FROM NON PARTY DATED JANUARY 8, 2015 AND INSTRUCTIONS TO THE CLERK The Plaintiff, BARBARA WILLIAMSON, by and through his undersigned counsel, herewith files this Objection to Notice of Production from Non Party dated January 8, 2015, pursuant to Florida Rule of Civil procedure 1.351(b), to: 1, GEORGE ROFFMAN, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S MENTAL CONDITION 2. VIVIAN ROSE, M.D, AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S MENTAL CONDITION 3. PHOENIX EMERGENCY MEDICINE OF BROWARD AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S MENTAL CONDITION 4. STEVEN FOSTER, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S MENTAL CONDITION 3. ALLERGY ASSOCIATES OF FLORIDA AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S MENTAL CONDITION ** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/19/2015 12:03:46 PM.****ll. 12. 13, 15. CHARLES RUSSO, ESQ. (SIC) AS TO PRODUCTION OF ANY AND ALL RECORDS. NORMAN KLEIN, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S MENTAL CONDITION DR. PHILIP ROSENFELD/DR. ELENA ROTH AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S MENTAL CONDITION SALOMON ESQUENAZI, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFFS MENTAL CONDITION JONATHAN HARRIS, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S MENTAL CONDITION MICHAEL LOEFFLER AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFFS MENTAL CONDITION KELLY BALDWIN, M.D. AS TO PRODUCTION OF ANY AND ALL RECORDS AS THE RECORDS ARE IRRELEVANT, AND THE REQUEST IS VAGUE, OVERBROAD AND NOT REASONABLY CALCULATED TO LEAD TO THE DISCOVERY OF ADMISSIBLE EVIDENCE (UROLOGIST) DR. RONALD COHEN/DR. MARSHAL KAPLAN AS TO PRODUCTION OF ANY AND ALL RECORDS AS THE RECORDS ARE IRRELEVANT, AND THE REQUEST IS VAGUE, OVERBROAD AND NOT REASONABLY CALCULATED TO LEAD TO THE DISCOVERY OF ADMISSIBLE EVIDENCE (UROLOGIST) CHRISTOPHER GOMEZ, M.D. AS TO PRODUCTION OF ANY AND ALL RECORDS AS THE RECORDS ARE IRRELEVANT, AND THE REQUEST IS VAGUE, OVERBROAD AND NOT REASONABLY CALCULATED TO LEAD TO THE DISCOVERY OF ADMISSIBLE EVIDENCE (UROLOGIST) IRVING DAVID, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’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~ RADIOLOGY DEPARTMENT AS TO PRODUCTION OF RECORDS OF PLAINTIFF’S MENTAL CONDITION HOLY CROSS HOSPITAL ~ BILLING DEPARTMENT AS TO PRODUCTION OF RECORDS OF PLAINTIFF’S MENTAL CONDITION ROHAN FARIA AS TO PRODUCTION OF ANY AND ALL RECORDS AS THE RECORDS ARE IRRELEVANT, AND THE REQUEST IS VAGUE, OVERBROAD AND NOT REASONABLY CALCULATED TO LEAD TO THE DISCOVERY OF ADMISSIBLE EVIDENCE (ONCOLOGIST/HEMATOLOGIST) RUBEN UNGARO, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S MENTAL CONDITION CESAR ALEGRE, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S , MENTAL CONDITION LYMPHATX, INC, AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF’S MENTAL CONDITION27. 28. 29. 30. VEIN CLINIC OF AMERICA AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S MENTAL CONDITION FLORIDA PHLEBOLOGY, P.A. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S MENTAL CONDITION BARNEY HORVATH, M.D. AS TO PRODUCTION OF PSYCHOLOGICAL AND/OR PSYCHIATRIC RECORDS AND/OR RECORDS OF PLAINTIFF'S MENTAL CONDITION OVATIONS, INC. UNITED HEALTHCARE GROUP AS TO PRODUCTION OF LOST WAGE BENEFITS. THE DOCUMENTS SOUGHT ARE IRRELEVANT AS PLAINTIFF IS NOT MAKING A CLAIM FOR LOST WAGES. COUNSEL FOR DEFENDANT IS HEREBY INSTRUCTED NOT TO ISSUE THE REQUESTED SUBPOENAS CERTIFICATE OF SERVICE IT HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic Mail to: John D. Golden, Esq., jgolden@goldengrimes.com and phoskin@goldengrimes.com; counsel for the Defendant, Golden & Grimes, LLP, 9350 South Dixie Highway, Penthouse II, Miami, Florida 33156 on this / 9 day of January, 2015. LAW OFFICES OF ANIDJAR & LEVINE, PA Attorneys for Plaintiff 12 SE 7" Street Suite 604 Ft. Lauderdale, FL 33301 Phone: (954) 525-0050/Fax (954) 525-0020 Email for pleadings — pleadings@an]-law.com See > By: eee GLEN B. LEVINE, ESQ. FBN: 0144355