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Filing # 80460895 E-Filed 11/07/2018 01:03:13 PM
CASE NO: CACE14014218 (04)
MLS/md (173532)
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA.
CASE NO: CACE14014218 (04)
KHAI NGUYEN, individually, and as
Personal Representative of the Estate
of MAI TUYET NGUYEN, deceased and
on behalf of KRISTEN HUYNH, KYLIE
NGUYEN, KADEN NGUYEN and as the
Natural parent of KADEN NGUYEN, a
Minor,
Plaintiffs,
vs.
PLANTATION GENERAL HOSPITAL, L.P., d/b/a
PLANTATION GENERAL HOSPITAL; ALEX
BIRMAN, M.D.; SUNLIFE OB/GYN SERVICES
OF FORT LAUDERDALE, P.A.; GEORGES
EDOUARD, M.D.; GEORGES EDOUARD, M.LD.,
P.A., d/b/a PLANTATION PAVILION OB/GYN;
MELISSA MACHAN, ARNP; ROBERTA
SANTINI, M.D.; DORI RATHBUN; FLORIDA
UNITED RADIOLOGY, L.C.,
Defendants.
/
DEFENDANTS’ MOTION TO COMPEL PLAINTIFF TO PROVIDE PAYMENT TO.
EXPERT WITNESS MONA BROWN KETNER, RN, MSN, C-EFM
Defendants, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION
GENERAL HOSPITAL and DORI RATHBUN, by and through their undersigned counsel, and
pursuant to Florida Rules of Civil Procedure 1.380, hereby move the Court for an Order compelling
Plaintiffs’ to provide payment to Defendant, PLANTATION GENERAL HOSPTIAL’s Expert
Witness, Mona Brown Ketner, RN, MSN, C-EFM for her deposition and states as follows:
1. Plaintiff took the deposition of Defendant, Planation General Hospital’s Expert
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/7/2018 1:03:12 PM.****CASE NO: CACE14014218 (04)
Witness Mona Brown Ketner, RN, MSN, C-EFM on October 30, 2017.
A copy of the Notice of Taking Deposition is attached hereto as Exhibit “A”.
2. On or about, February 12, 2018, Nurse Ketner sent Plaintiff's counsel
correspondence requesting payment for her deposition taken on October 30, 2017 for the amount
of $800.00 along with her W-9 form for payment. A copy of correspondence to Plaintiff's counsel
is attached hereto as Exhibit “B”.
3. In addition, Defense counsel has sent several emails to Plaintiffs counsel
requesting the payment for its Expert Witness to be made and has not received a response.
4, To date, Defendant’s Expert Witness has not received payment for her deposition
taken in October, 2017.
5. Defendants, PLANTATION GENERAL HOSPITAL, LP. d/b/a PLANTATION
GENERAL HOSPITAL and DORI RATHBUN, have made a good faith effort to communicate
with Plaintiff's counsel to resolve the issues.
WHEREFORE, Defendants, PLANTATION GENERAL HOSPITAL, L.P. d/b/a
PLANTATION GENERAL HOSPITAL and DORI RATHBUN, respectfully request this Court
enter an Order (1) requiring Plaintiff to make the requested payment of the invoice provided by
Defendant’s Expert Witness Mona Brown Ketner, RN, MSN, C-EFM, within ten (10) days of
Defendant PLANTATION GENERAL HOSPITAL and DORI RATHBUN’s Motion to Compel.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been
furnished via Electronic Mail, to all counsel of record on the attached Service List this 7th day of
November, 2018.
LA CAVA & JACOBSON, P.A.
Attorneys for Defendants, Plantation General
Hospital and Dori RathbunCASE NO: CACE14014218 (04)
4901 N.W. 17" Way, Suite 606
Telephone:
Facsimile:
(754) 301-5060
(754) 551-6884
BY:__A/ Maret strauss.
LOUIS J. LaCAVA
Fla. Bar No: 507880
MARCI L. STRAUSS
Fla. Bar No.: 857025
SERVICE LIST
Maria D. Tejedor, Esq.
Diez-Arguelles & Tejedor, P.A.
505 North Mills Avenue
Orlando, Florida 32803
Telephone: 407-705-2880
Eservice: mail@theorlandolawyers.com
leah@theorlandolawyers.com
Attorneys for Plaintiff
Alex Alvarez, Esq.
The Alvarez Law Firm
355 Palermo Avenue
Coral Gables, FL 33134
Telephone: 305-444-7675
Eservice: alex@talf.law
maria@talf.law
Co-Counsel for Plaintiff
Peter Mineo, Jr., Esq.
The Mineo Salcedo Law Firm, P.A.
5400 S. University Drive, Suite 502
Davie, FL 33328
Telephone: 954-463-8100
Eservice: servi ineolaw.com
jsoto@mineolaw.com
Counsel for Georges Edouard, M.D.Filing # 63227397 E-Filed 10/24/2017 10:42:22 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
KHAI NGUYEN, individually, and as CASE NO.; CACE-14-014218 Div: 04
Personal Representative of the Estate of MAI
TUYET NGUYEN, deceased, and on behalf
of KRISTEN HUYNH, KYLIE NGUYEN,
KADEN NGUYEN, the surviving children of
MAI TUYET NGUYEN, and as the natural
parent of KADEN NGUYEN, a minor,
Plaintiffs,
Vv.
PLANTATION GENERAL HOSPITAL, L.P.
d/b/a PLANTATION GENERAL
HOSPITAL, ALEX BIRMAN, M.D.,
SUNLIFE OB/GYN SERVICES OF FT.
LAUDERDALE, P.A., GEORGES
EDOUARD, M.D., GEORGES EDOUARD,
M.D., P.A. d/b/a PLANTATION PAVILION
OB/GYN, MELISSA MACHAN, ARNP,
ROBERTA SANTINI, M.D., DORI
RATHBUN, FLORIDA UNITED
RADIOLOGY, L.C.,
Defendants.
/
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that Plaintiff, KHAI NGUYEN, individually, and as Personal
Representative of the Estate of MAl TUYET NGUYEN, deceased, and on behalf of KRISTEN
HUYNH, KYLIE NGUYEN, KADEN NGUYEN, the surviving children of MA] TUYET
NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, by and through their
undersigned counsel will take the deposition of the below listed individual as follows:
DEPONENT: Mona Ketner, RN
LOCATION: At a Court Reporter’s Office in Winston-Salem, North Carolina
DATE/ TIME: October 30, 2017 at 9:00 a.m.
EXH. "A"upon oral examination pursuant to Florida Rules of Civil Procedure before an official reporter,
Milestone Reporting, Notary public, or some officer authorized by law to take depositions. Said
deposition is to be taken for discovery purposes, for use as evidence at trial or both. *Deponent
must have with him on the above date and time all requested documents on the attached
“Schedule A”
In accordance with the Americans with Disabilities Act, persons with disabilities needing
a special accommodation to participate in the proceeding should contact, Maria D, Tejedor, Esq.
of Diez-Arguelles & Tejedor P.A., 505 N. Mills Avenue., Orlando, Florida 32803, (407) 705-
2880, not later than seven (7) days prior to the proceeding. If hearing impaired, (TTD) 1-800-
955-8771, or Voice (V) 1-800-955-8770, via Florida Relay Service
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via service through the e-filing portal to all counsel on the attached counsel list this 24th day of
October, 2017.
/s/ Maria D, Tejedor
Maria D. Tejedor
FBN: 95834
DIEZ-ARGUELLES & TEJEDOR
505 North Mills Avenue
Orlando, Florida 32803
Telephone: (407) 705-2880
Attorney for Plaintiffs
mail @theorlandolawyers.com
Service List
William V. Carcioppolo, Esq.
LaCava & Jacobson, P.A.
4901 N.W. 17th Way Suite 302
Fort Lauderdale, FL 33309
P: 754-301-5060
F; 754-551-6884
w.carcioppolo@lacavajacobson.com
abenson@lacavajacobson.com
holeski@lavacajacobson.com
Counsel for Plantation General Hospital and Dori Rathburn
Georges Edouard, M.D. (pro se)
4330 W. Broward Blvd. Suite C
Plantation, FL 3331710.
11.
12.
13.
15,
SCHEDULE A
Your Curriculum Vitae along with those of anyone else at your company who has worked
on this case.
You entire case file regarding this matter.
All correspondence, facsimiles, emails, note, messages, transmittals by and between
counsel for Defendant and you or your company.
Any and all engagement letter, contract, retainer agreements or other written instructions
received or agreed to by you in connection with this case.
All writing setting forth your opinion or observation in this case.
Each and every document created by you or your company in connection with this
matter.
The raw data, results, videotapes, photographs or any other documentation related to any
testing that you or your company have conducted in connection with this matter.
All articles, books, papers, manuals, studies or similar documents both formal and
informal, written by you or to which you contributed.
Any opinions which were revised or modified.
All written reports or material, records, depositions, answers to interrogatories or other
documentation relied upon you in formulating your opinions in this case.
All documents or material, records, reports, depositions, answer to interrogatories or
other documentation reviewed by you but not relied on in formulating your opinion or in
the process of review for the formation of your opinion.
All documents or material, records, reports, depositions, answer to interrogatories or
other documentation reviewed by you in formulating your opinion in this case.
All photographs, diagrams, surveys, plots or other like materials, or any and all tangible
matters or items relied upon reviewed by you or anyone at your company in the
formation of your opinion or in the process of review for the formation of your opinion.
Any and all written or recorded statements taken from Plaintiff.
Each and every article, treatise, book, study, chapter, page, paper, study, law regulation,
guideline, suggestion, recommendation, ordinance, table, statistic, statute, rule, chart,
graph, summary, census, other document, tangible evidence including electronically
stored evidence in tangible form, or other similar source of information considered or
reviewed by you or upon which you relied in evaluating, investigating, or formulating
your opinion in connection with this matter.16.
17,
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
Any other information reviewed by you in connection with this case.
Your fee schedule.
If you intended to opine regarding the reasonableness of medical expenses, a copy of
your fee schedule for all similar procedures to which you intend to opine.
Any and all invoices, ledgers, bills and other documentation of the time and costs you or
your company has expended in connection with this case, including any payments
received,
All documents or tangible items of whatsoever nature pertaining to the following:
a. The scope of your employment in this case and the compensation for such service.
b. Your general litigation experience, including the percentage of work performed
for plaintiffs and defendants
c. The identity of other insurance claims or legal actions in which each of you have
rendered opinions or evaluations during the last three years. (You are not
tequested to identify instances where treatment was provided to a patient.)
d. The identity of other cases in which you have testified by deposition or a trial
during the last five years.
e. An approximation of the portion of your involvement as an expert witness, which
may be based on the number of hours, percentage of hours or percentage of
earned income derived from serving as an expert witness.
The documents requested in 11 above for your entire company
Copies of any and all bills, invoices, records, memoranda, checks, check stubs, receipts,
1099's, tax records or any other form of financial information evidencing payment or
compensation paid by any of the above named Defendants and from Defense counsel or
her firm for services provided by you for the last three (3) years.
Copies of any and all bills, invoices, records, memoranda, checks, check stubs, receipts,
1099’s, tax records or any other form of financial information evidencing payment or
compensation paid by Defendant, and Defendant’s counsel entire firm for services
provided by your company for the last three (3) years.
Any and all depositions and trial transcripts taken in any other action where you have
testified as a treating or retained expert witness.
Each and every Witness List, Notice of Deposition or Other Pleading wherein you were
named or retained during the past three years by the Defendant.
A copy of your most recent letterhead
Any advertising done by you within the last three calendar years, including but not
limited to internet websites and emails.28,
29.
Any document pertaining to presentations to lawyers with respect to your work as a
retained expert.
Any documentation regarding professional privileges, duties, limitations, suspension,
revocation, termination or resignation from any position including by not limited to
teaching positions, groups, organizations and employers.1033 Wessyngton Road
Winston-Salem, NC 27104
mketner@wakehealth.edu
336.713.7730
February 12, 2018
Re: Nguyen v. PGH
Maria D. Tejedor
Diez-Arguelles & Tejedor
505 North Mills Avenue
Orlando, Florida 32803
Dear Ms. Tejedor:
Below is a listing of hours spent-in the above-referenced matter:
October 30, 2017: deposition testimony of 4 hours @ $200/hour = $800.00 total.’
FEB 15 2ug
Please make payment to me at the above address; a tax form is enclosed for your use.
Thank you.
Sincerely,
Unocal Prnmbetra— |
Mona Brown Ketner MSN, RN, C-EFM
EXH. "B"om W-9
Request for Taxpayer
Give form to the
requester. Do not
{Rev, January 2005) H i Afi,
Perdido a'r rein Identification Number and Certification send to the IRS.
Intemat Reverue Sonvice
Name (as shown on your income tax return)
Mona Brown Ketner
Business name, if different from above
Check appropriate box: Oo Sob proprietor oO Corporation oO Partnership Oo Other ® _. wanna” ore
‘Address (number, street, end apt. or suite no)
1033 Wessyngton Road
Requester's name and address (optional)
Gity, state, and ZIP code
Winston Salem, NC 27104
List account number(s) here (optional)
Print or type
ee Specific Instructions on page 2.
a
Taxpayer Identification Number (TIN)
Enter your TIN in the appropriate box. The TIN provided must match the name given on Line 1 to avoid
backup withholding, For individuals, this is your social security number (SSN). However, for a resident
alien, sole proprietor, or disregarded entity, see the Part | instructions on page 3. For other entities, it is
your employer identification number (EIN). if you do not have a number, see How to get a TIN on page 3.
Note. if the account is in more than one name, see the chart on page 4 for guidelines on whose number
to enter.
‘Social security number
O19]
or
Emptoyer identification number
L+tLiil tI
EEE Certification
Under penalties of perjury, | certify that:
1. The number shown on this form is my correct taxpayer identification number (or | am waiting for a number to be issued to me}, and
2. [am not subject to backup withholding because: (a) | am exempt from backup withholding, or (0) | have not been notified by the intemal
Revenue Service (IRS) that | am subject to backup withholding as a result of a failure to report all interest or dividends, or (c) the IRS has
Notified me that | am no ionger subject to backup withholding, and
3. |ama U.S. person (including a U.S. resident alien).
Certification instructions. You must cross out item 2 above If you have been notified by the IRS that you are currently subject to backup
withholding because you have failed to report all interest and dividends on your tax return. For real estate transactions, item 2 does not apply.
For mortgage interest paid, acquisition or abandonment of secured property, cancellation of debt, contributions to an individual retirement
arrangement (IRA), and generally, payments other than interest and dividends, you are not required to sign the Certification, but you must
provide your correct TIN, (See the instructions on page 4.)
Sign | signature of
Here _| us. person > Unerat Poo alct non
Purpose of Form
A person who is required to file an information return with the
IRS, must obtain your correct taxpayer identification number
(TIN) to report, for example, income paid to you, real estate
transactions, mortgage interest you paid, acquisition or
abandonment of secured property, cancellation of debt, or
contributions you made to an IRA.
U.S. person. Use Form W-9 only if you are a U.S. person
(including a resident alien), to provide your correct TIN to the
person requesting it (the requester) and, when applicable, to:
1. Gertify that the TIN you are giving is correct (or you are
waiting for a number to be issued),
2. Certify that you are not subject to backup withholding,
or,
3. Claim exemption from backup withholding if you are a
U.S. exempt payee.
Note. /f a requester gives you a form other than Form W-9 to
request your TIN, you must use the requester’s form if it is
substantially similar to this Form W-9.
For federal tax purposes you are considered a person if you
are:
© An individual who is a citizen or resident of the United
States,
® A partnership, corporation, company, or association
created or organized in the United States or under the laws
of the United States, or
Cat, No, 10231X
AAAI
© Any estate (other than a foreign estate) or trust. See
Regulations sections 301.7701-6(a) and 7(a) for additional
information.
Foreign person. If you are a foreign person, do not use
Form W-9. instead, use the appropriate Form W-8 (see
Publication 515, Withholding of Tax on Nonresident Allens
and Foreign Entities).
Nonresident alien who becomes a resident alien.
Generally, only a nonresident alien individual may use the
terms of a tax treaty to reduce or eliminate U.S. tax on
certain types of income. However, most tax treaties contain a
provision known as a “saving clause.” Exceptions specified
in the saving clause may permit an exemption from tax to
continue for certain types of income even after the recipient
has otherwise become a U.S. resident alien for tax purposes.
If you are a U.S. resident alien who is relying on an
exception contained in the saving clause of a tax treaty to
claim an exemption from U.S. tax on certain types of Income,
you must attach a statement to Form W-9 that specifies the
following five items:
1. The treaty country. Generally, this must be the same
treaty under which you claimed exemption from tax as a
nonresident alien.
2. The treaty article addressing the income.
3. The article number (or location) in the tax treaty that
contains the saving clause and its exceptions.
Form W-9 (Rev. 1-205)
Date >
Preview
Filing # 80460895 E-Filed 11/07/2018 01:03:13 PM CASE NO: CACE14014218 (04) MLS/md (173532) IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: CACE14014218 (04) KHAI NGUYEN, individually, and as Personal Representative of the Estate of MAI TUYET NGUYEN, deceased and on behalf of KRISTEN HUYNH, KYLIE NGUYEN, KADEN NGUYEN and as the Natural parent of KADEN NGUYEN, a Minor, Plaintiffs, vs. PLANTATION GENERAL HOSPITAL, L.P., d/b/a PLANTATION GENERAL HOSPITAL; ALEX BIRMAN, M.D.; SUNLIFE OB/GYN SERVICES OF FORT LAUDERDALE, P.A.; GEORGES EDOUARD, M.D.; GEORGES EDOUARD, M.LD., P.A., d/b/a PLANTATION PAVILION OB/GYN; MELISSA MACHAN, ARNP; ROBERTA SANTINI, M.D.; DORI RATHBUN; FLORIDA UNITED RADIOLOGY, L.C., Defendants. / DEFENDANTS’ MOTION TO COMPEL PLAINTIFF TO PROVIDE PAYMENT TO. EXPERT WITNESS MONA BROWN KETNER, RN, MSN, C-EFM Defendants, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL and DORI RATHBUN, by and through their undersigned counsel, and pursuant to Florida Rules of Civil Procedure 1.380, hereby move the Court for an Order compelling Plaintiffs’ to provide payment to Defendant, PLANTATION GENERAL HOSPTIAL’s Expert Witness, Mona Brown Ketner, RN, MSN, C-EFM for her deposition and states as follows: 1. Plaintiff took the deposition of Defendant, Planation General Hospital’s Expert *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/7/2018 1:03:12 PM.****CASE NO: CACE14014218 (04) Witness Mona Brown Ketner, RN, MSN, C-EFM on October 30, 2017. A copy of the Notice of Taking Deposition is attached hereto as Exhibit “A”. 2. On or about, February 12, 2018, Nurse Ketner sent Plaintiff's counsel correspondence requesting payment for her deposition taken on October 30, 2017 for the amount of $800.00 along with her W-9 form for payment. A copy of correspondence to Plaintiff's counsel is attached hereto as Exhibit “B”. 3. In addition, Defense counsel has sent several emails to Plaintiffs counsel requesting the payment for its Expert Witness to be made and has not received a response. 4, To date, Defendant’s Expert Witness has not received payment for her deposition taken in October, 2017. 5. Defendants, PLANTATION GENERAL HOSPITAL, LP. d/b/a PLANTATION GENERAL HOSPITAL and DORI RATHBUN, have made a good faith effort to communicate with Plaintiff's counsel to resolve the issues. WHEREFORE, Defendants, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL and DORI RATHBUN, respectfully request this Court enter an Order (1) requiring Plaintiff to make the requested payment of the invoice provided by Defendant’s Expert Witness Mona Brown Ketner, RN, MSN, C-EFM, within ten (10) days of Defendant PLANTATION GENERAL HOSPITAL and DORI RATHBUN’s Motion to Compel. CERTIFICATE OF SERVICE IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been furnished via Electronic Mail, to all counsel of record on the attached Service List this 7th day of November, 2018. LA CAVA & JACOBSON, P.A. Attorneys for Defendants, Plantation General Hospital and Dori RathbunCASE NO: CACE14014218 (04) 4901 N.W. 17" Way, Suite 606 Telephone: Facsimile: (754) 301-5060 (754) 551-6884 BY:__A/ Maret strauss. LOUIS J. LaCAVA Fla. Bar No: 507880 MARCI L. STRAUSS Fla. Bar No.: 857025 SERVICE LIST Maria D. Tejedor, Esq. Diez-Arguelles & Tejedor, P.A. 505 North Mills Avenue Orlando, Florida 32803 Telephone: 407-705-2880 Eservice: mail@theorlandolawyers.com leah@theorlandolawyers.com Attorneys for Plaintiff Alex Alvarez, Esq. The Alvarez Law Firm 355 Palermo Avenue Coral Gables, FL 33134 Telephone: 305-444-7675 Eservice: alex@talf.law maria@talf.law Co-Counsel for Plaintiff Peter Mineo, Jr., Esq. The Mineo Salcedo Law Firm, P.A. 5400 S. University Drive, Suite 502 Davie, FL 33328 Telephone: 954-463-8100 Eservice: servi ineolaw.com jsoto@mineolaw.com Counsel for Georges Edouard, M.D.Filing # 63227397 E-Filed 10/24/2017 10:42:22 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA KHAI NGUYEN, individually, and as CASE NO.; CACE-14-014218 Div: 04 Personal Representative of the Estate of MAI TUYET NGUYEN, deceased, and on behalf of KRISTEN HUYNH, KYLIE NGUYEN, KADEN NGUYEN, the surviving children of MAI TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, Plaintiffs, Vv. PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, ALEX BIRMAN, M.D., SUNLIFE OB/GYN SERVICES OF FT. LAUDERDALE, P.A., GEORGES EDOUARD, M.D., GEORGES EDOUARD, M.D., P.A. d/b/a PLANTATION PAVILION OB/GYN, MELISSA MACHAN, ARNP, ROBERTA SANTINI, M.D., DORI RATHBUN, FLORIDA UNITED RADIOLOGY, L.C., Defendants. / AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that Plaintiff, KHAI NGUYEN, individually, and as Personal Representative of the Estate of MAl TUYET NGUYEN, deceased, and on behalf of KRISTEN HUYNH, KYLIE NGUYEN, KADEN NGUYEN, the surviving children of MA] TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, by and through their undersigned counsel will take the deposition of the below listed individual as follows: DEPONENT: Mona Ketner, RN LOCATION: At a Court Reporter’s Office in Winston-Salem, North Carolina DATE/ TIME: October 30, 2017 at 9:00 a.m. EXH. "A"upon oral examination pursuant to Florida Rules of Civil Procedure before an official reporter, Milestone Reporting, Notary public, or some officer authorized by law to take depositions. Said deposition is to be taken for discovery purposes, for use as evidence at trial or both. *Deponent must have with him on the above date and time all requested documents on the attached “Schedule A” In accordance with the Americans with Disabilities Act, persons with disabilities needing a special accommodation to participate in the proceeding should contact, Maria D, Tejedor, Esq. of Diez-Arguelles & Tejedor P.A., 505 N. Mills Avenue., Orlando, Florida 32803, (407) 705- 2880, not later than seven (7) days prior to the proceeding. If hearing impaired, (TTD) 1-800- 955-8771, or Voice (V) 1-800-955-8770, via Florida Relay Service CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via service through the e-filing portal to all counsel on the attached counsel list this 24th day of October, 2017. /s/ Maria D, Tejedor Maria D. Tejedor FBN: 95834 DIEZ-ARGUELLES & TEJEDOR 505 North Mills Avenue Orlando, Florida 32803 Telephone: (407) 705-2880 Attorney for Plaintiffs mail @theorlandolawyers.com Service List William V. Carcioppolo, Esq. LaCava & Jacobson, P.A. 4901 N.W. 17th Way Suite 302 Fort Lauderdale, FL 33309 P: 754-301-5060 F; 754-551-6884 w.carcioppolo@lacavajacobson.com abenson@lacavajacobson.com holeski@lavacajacobson.com Counsel for Plantation General Hospital and Dori Rathburn Georges Edouard, M.D. (pro se) 4330 W. Broward Blvd. Suite C Plantation, FL 3331710. 11. 12. 13. 15, SCHEDULE A Your Curriculum Vitae along with those of anyone else at your company who has worked on this case. You entire case file regarding this matter. All correspondence, facsimiles, emails, note, messages, transmittals by and between counsel for Defendant and you or your company. Any and all engagement letter, contract, retainer agreements or other written instructions received or agreed to by you in connection with this case. All writing setting forth your opinion or observation in this case. Each and every document created by you or your company in connection with this matter. The raw data, results, videotapes, photographs or any other documentation related to any testing that you or your company have conducted in connection with this matter. All articles, books, papers, manuals, studies or similar documents both formal and informal, written by you or to which you contributed. Any opinions which were revised or modified. All written reports or material, records, depositions, answers to interrogatories or other documentation relied upon you in formulating your opinions in this case. All documents or material, records, reports, depositions, answer to interrogatories or other documentation reviewed by you but not relied on in formulating your opinion or in the process of review for the formation of your opinion. All documents or material, records, reports, depositions, answer to interrogatories or other documentation reviewed by you in formulating your opinion in this case. All photographs, diagrams, surveys, plots or other like materials, or any and all tangible matters or items relied upon reviewed by you or anyone at your company in the formation of your opinion or in the process of review for the formation of your opinion. Any and all written or recorded statements taken from Plaintiff. Each and every article, treatise, book, study, chapter, page, paper, study, law regulation, guideline, suggestion, recommendation, ordinance, table, statistic, statute, rule, chart, graph, summary, census, other document, tangible evidence including electronically stored evidence in tangible form, or other similar source of information considered or reviewed by you or upon which you relied in evaluating, investigating, or formulating your opinion in connection with this matter.16. 17, 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. Any other information reviewed by you in connection with this case. Your fee schedule. If you intended to opine regarding the reasonableness of medical expenses, a copy of your fee schedule for all similar procedures to which you intend to opine. Any and all invoices, ledgers, bills and other documentation of the time and costs you or your company has expended in connection with this case, including any payments received, All documents or tangible items of whatsoever nature pertaining to the following: a. The scope of your employment in this case and the compensation for such service. b. Your general litigation experience, including the percentage of work performed for plaintiffs and defendants c. The identity of other insurance claims or legal actions in which each of you have rendered opinions or evaluations during the last three years. (You are not tequested to identify instances where treatment was provided to a patient.) d. The identity of other cases in which you have testified by deposition or a trial during the last five years. e. An approximation of the portion of your involvement as an expert witness, which may be based on the number of hours, percentage of hours or percentage of earned income derived from serving as an expert witness. The documents requested in 11 above for your entire company Copies of any and all bills, invoices, records, memoranda, checks, check stubs, receipts, 1099's, tax records or any other form of financial information evidencing payment or compensation paid by any of the above named Defendants and from Defense counsel or her firm for services provided by you for the last three (3) years. Copies of any and all bills, invoices, records, memoranda, checks, check stubs, receipts, 1099’s, tax records or any other form of financial information evidencing payment or compensation paid by Defendant, and Defendant’s counsel entire firm for services provided by your company for the last three (3) years. Any and all depositions and trial transcripts taken in any other action where you have testified as a treating or retained expert witness. Each and every Witness List, Notice of Deposition or Other Pleading wherein you were named or retained during the past three years by the Defendant. A copy of your most recent letterhead Any advertising done by you within the last three calendar years, including but not limited to internet websites and emails.28, 29. Any document pertaining to presentations to lawyers with respect to your work as a retained expert. Any documentation regarding professional privileges, duties, limitations, suspension, revocation, termination or resignation from any position including by not limited to teaching positions, groups, organizations and employers.1033 Wessyngton Road Winston-Salem, NC 27104 mketner@wakehealth.edu 336.713.7730 February 12, 2018 Re: Nguyen v. PGH Maria D. Tejedor Diez-Arguelles & Tejedor 505 North Mills Avenue Orlando, Florida 32803 Dear Ms. Tejedor: Below is a listing of hours spent-in the above-referenced matter: October 30, 2017: deposition testimony of 4 hours @ $200/hour = $800.00 total.’ FEB 15 2ug Please make payment to me at the above address; a tax form is enclosed for your use. Thank you. Sincerely, Unocal Prnmbetra— | Mona Brown Ketner MSN, RN, C-EFM EXH. "B"om W-9 Request for Taxpayer Give form to the requester. Do not {Rev, January 2005) H i Afi, Perdido a'r rein Identification Number and Certification send to the IRS. Intemat Reverue Sonvice Name (as shown on your income tax return) Mona Brown Ketner Business name, if different from above Check appropriate box: Oo Sob proprietor oO Corporation oO Partnership Oo Other ® _. wanna” ore ‘Address (number, street, end apt. or suite no) 1033 Wessyngton Road Requester's name and address (optional) Gity, state, and ZIP code Winston Salem, NC 27104 List account number(s) here (optional) Print or type ee Specific Instructions on page 2. a Taxpayer Identification Number (TIN) Enter your TIN in the appropriate box. The TIN provided must match the name given on Line 1 to avoid backup withholding, For individuals, this is your social security number (SSN). However, for a resident alien, sole proprietor, or disregarded entity, see the Part | instructions on page 3. For other entities, it is your employer identification number (EIN). if you do not have a number, see How to get a TIN on page 3. Note. if the account is in more than one name, see the chart on page 4 for guidelines on whose number to enter. ‘Social security number O19] or Emptoyer identification number L+tLiil tI EEE Certification Under penalties of perjury, | certify that: 1. The number shown on this form is my correct taxpayer identification number (or | am waiting for a number to be issued to me}, and 2. [am not subject to backup withholding because: (a) | am exempt from backup withholding, or (0) | have not been notified by the intemal Revenue Service (IRS) that | am subject to backup withholding as a result of a failure to report all interest or dividends, or (c) the IRS has Notified me that | am no ionger subject to backup withholding, and 3. |ama U.S. person (including a U.S. resident alien). Certification instructions. You must cross out item 2 above If you have been notified by the IRS that you are currently subject to backup withholding because you have failed to report all interest and dividends on your tax return. For real estate transactions, item 2 does not apply. For mortgage interest paid, acquisition or abandonment of secured property, cancellation of debt, contributions to an individual retirement arrangement (IRA), and generally, payments other than interest and dividends, you are not required to sign the Certification, but you must provide your correct TIN, (See the instructions on page 4.) Sign | signature of Here _| us. person > Unerat Poo alct non Purpose of Form A person who is required to file an information return with the IRS, must obtain your correct taxpayer identification number (TIN) to report, for example, income paid to you, real estate transactions, mortgage interest you paid, acquisition or abandonment of secured property, cancellation of debt, or contributions you made to an IRA. U.S. person. Use Form W-9 only if you are a U.S. person (including a resident alien), to provide your correct TIN to the person requesting it (the requester) and, when applicable, to: 1. Gertify that the TIN you are giving is correct (or you are waiting for a number to be issued), 2. Certify that you are not subject to backup withholding, or, 3. Claim exemption from backup withholding if you are a U.S. exempt payee. Note. /f a requester gives you a form other than Form W-9 to request your TIN, you must use the requester’s form if it is substantially similar to this Form W-9. For federal tax purposes you are considered a person if you are: © An individual who is a citizen or resident of the United States, ® A partnership, corporation, company, or association created or organized in the United States or under the laws of the United States, or Cat, No, 10231X AAAI © Any estate (other than a foreign estate) or trust. See Regulations sections 301.7701-6(a) and 7(a) for additional information. Foreign person. If you are a foreign person, do not use Form W-9. instead, use the appropriate Form W-8 (see Publication 515, Withholding of Tax on Nonresident Allens and Foreign Entities). Nonresident alien who becomes a resident alien. Generally, only a nonresident alien individual may use the terms of a tax treaty to reduce or eliminate U.S. tax on certain types of income. However, most tax treaties contain a provision known as a “saving clause.” Exceptions specified in the saving clause may permit an exemption from tax to continue for certain types of income even after the recipient has otherwise become a U.S. resident alien for tax purposes. If you are a U.S. resident alien who is relying on an exception contained in the saving clause of a tax treaty to claim an exemption from U.S. tax on certain types of Income, you must attach a statement to Form W-9 that specifies the following five items: 1. The treaty country. Generally, this must be the same treaty under which you claimed exemption from tax as a nonresident alien. 2. The treaty article addressing the income. 3. The article number (or location) in the tax treaty that contains the saving clause and its exceptions. Form W-9 (Rev. 1-205) Date >