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Filing # 73807903 E-Filed 06/19/2018 06:30:24 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
SEAN DOMNICK, as Guardian Ad Litem for CASE NO.: CACE-14-014218 Div: 04
the minors, KYLIE NGUYEN and KADEN
NGUYEN, 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, the surviving
children of MAI TUYET NGUYEN, and as
the natural parent of KADEN NGUYEN, a
minor,
Plaintiffs,
PLANTATION GENERAL HOSPITAL, L.P.
d/b/a PLANTATION GENERAL
HOSPITAL, GEORGES EDOUARD, M.D.,
GEORGES EDOUARD, M.D., P.A. d/b/a
PLANTATION PAVILION OB/GYN, DORI
RATHBUN,
Defendants.
/
MOTION FOR VIDEO TELEPHONE CONFERENCE APPEARANCE OF WITNESS
COME NOWS, the Plaintiffs, SEAN DOMNICK, as Guardian Ad Litem for the minors,
KYLIE NGUYEN and KADEN NGUYEN, 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, the surviving children of MAI TUYET
NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, and files this Motion for
Video Telephone Conference Appearance of Witness and in support thereof, state as follows:
1, This matter is a medical malpractice matter which involves claims for both wrongful
death and personal injury. These claims arise from care and treatment provided by the
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/19/2018 6:30:24 PM.****above-named Defendants to MAI TUYET NGUYEN during her pregnancy, labor and
delivery of KADEN NGUYEN.
2. Defendants have scheduled a two (2) hour hearing on their Daubert motion. This motion
was scheduled to be heard by the Court for June 27, 2018 at 1:30 p.m.
3. The treating physician addressed in Defendant’s Daubert motion is Fernando Miranda,
MD. Dr. Miranda has a practice in Vero Beach, Florida and in California. He travels back
and forth in between his practices to see patients.
4, Due to short notice of the scheduling of this hearing, Dr. Miranda is unable to attend live.
5. Plaintiffs’ Counsel respectfully requests this Honorable Court enter an order allowing Dr.
Miranda to appear via video telephone conference for the upcoming hearing.
6. Plaintiffs’ Counsel will coordinate the same with a court reporting agency and incur the
cost for the same.
7. No party will be prejudiced by the video telephone conference appearance of Dr.
Miranda.
Wherefore, Plaintiffs, Plaintiffs, SEAN DOMNICK, as Guardian Ad Litem for the
minors, KYLIE NGUYEN and KADEN NGUYEN, 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, the surviving children of MAI
TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, hereby request the
Court grant this Motion for Video Telephone Conference Appearance of Witness allowing Dr.
Miranda to appear video telephone conference for the June 27, 2018 hearing at 1:30 p.m.
CERTIFICATIEOF SERVICE
I hereby certify that a true and corre
mail to all counsel on the service list below, ¢
y of the forgoing was furnished via electronic
i~day of June, 2018.Louis J. La Cava, Esquire
LaCava & Jacobson, P.A.
4901 N.W. 17th Way Suite 302
Fort Lauderdale, FL 33309
Llacava@lacavajacobson.com; Leddings@lacavajacobson.com
Counsel for Plantation General Hospital and Dori Rathburn
Peter Mineo, Jr., Esq.
The Mineo Salcedo Law Firm, PA
5400 S. University Drive, Suite 502
Davie, FL 33328
Service@mineolaw.com
jsoto@mineolaw.com
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Filing # 73807903 E-Filed 06/19/2018 06:30:24 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA SEAN DOMNICK, as Guardian Ad Litem for CASE NO.: CACE-14-014218 Div: 04 the minors, KYLIE NGUYEN and KADEN NGUYEN, 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, the surviving children of MAI TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, Plaintiffs, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, GEORGES EDOUARD, M.D., GEORGES EDOUARD, M.D., P.A. d/b/a PLANTATION PAVILION OB/GYN, DORI RATHBUN, Defendants. / MOTION FOR VIDEO TELEPHONE CONFERENCE APPEARANCE OF WITNESS COME NOWS, the Plaintiffs, SEAN DOMNICK, as Guardian Ad Litem for the minors, KYLIE NGUYEN and KADEN NGUYEN, 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, the surviving children of MAI TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, and files this Motion for Video Telephone Conference Appearance of Witness and in support thereof, state as follows: 1, This matter is a medical malpractice matter which involves claims for both wrongful death and personal injury. These claims arise from care and treatment provided by the *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/19/2018 6:30:24 PM.****above-named Defendants to MAI TUYET NGUYEN during her pregnancy, labor and delivery of KADEN NGUYEN. 2. Defendants have scheduled a two (2) hour hearing on their Daubert motion. This motion was scheduled to be heard by the Court for June 27, 2018 at 1:30 p.m. 3. The treating physician addressed in Defendant’s Daubert motion is Fernando Miranda, MD. Dr. Miranda has a practice in Vero Beach, Florida and in California. He travels back and forth in between his practices to see patients. 4, Due to short notice of the scheduling of this hearing, Dr. Miranda is unable to attend live. 5. Plaintiffs’ Counsel respectfully requests this Honorable Court enter an order allowing Dr. Miranda to appear via video telephone conference for the upcoming hearing. 6. Plaintiffs’ Counsel will coordinate the same with a court reporting agency and incur the cost for the same. 7. No party will be prejudiced by the video telephone conference appearance of Dr. Miranda. Wherefore, Plaintiffs, Plaintiffs, SEAN DOMNICK, as Guardian Ad Litem for the minors, KYLIE NGUYEN and KADEN NGUYEN, 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, the surviving children of MAI TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, hereby request the Court grant this Motion for Video Telephone Conference Appearance of Witness allowing Dr. Miranda to appear video telephone conference for the June 27, 2018 hearing at 1:30 p.m. CERTIFICATIEOF SERVICE I hereby certify that a true and corre mail to all counsel on the service list below, ¢ y of the forgoing was furnished via electronic i~day of June, 2018.Louis J. La Cava, Esquire LaCava & Jacobson, P.A. 4901 N.W. 17th Way Suite 302 Fort Lauderdale, FL 33309 Llacava@lacavajacobson.com; Leddings@lacavajacobson.com Counsel for Plantation General Hospital and Dori Rathburn Peter Mineo, Jr., Esq. The Mineo Salcedo Law Firm, PA 5400 S. University Drive, Suite 502 Davie, FL 33328 Service@mineolaw.com jsoto@mineolaw.com