Preview
Filing # 56115030 E-Filed 05/08/2017 12:25:09 PM
06-3972 IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 14-014218 (04)
KHAI NGUYEN, Individually, and as
Personal Representative of the Estate of
MAI TUYET NGUYEN, Deceased, and
on behalf of KRISTEN HUYNH, KYLIE
NGUYEN and i the
surviving children of MAI TUYET
NGUYEN, and as the natural parent of
EEE, 2 inor,
Plaintiffs,
vs.
PLANTATION GENERAL HOSPITAL,
L.P. d/b/a PLANTATION GENERAL
HOSPITAL, ALEX BIRMAN, MD,
SUNLIFE OB/GYN SERVICES OF FT.
LAUDERDALE, P.A., © GEORGES
EDOUARD, MD, GEORGES
EDOUARD, MD, PA. d/b/a
PLANTATION PAVILION OB/GYN,
MELISSA MACHAN, ARNP,
ROBERTA SANTINI, MD, DORI
RATHBUN and FLORIDA UNITED
RADIOLOGY, L.C.,
Defendants.
/
DEFENDANTS’ MOTION TO COMPEL
COME NOW the Defendants, FLORIDA UNITED RADIOLOGY, L.C. and
ROBERTA SANTINI, MD, by and through their undersigned counsel, and request this
Honorable Court for the entry of an Order compelling the Plaintiff to produce exhibits to the
deposition of Dr. Carolyn Crawford, and as grounds therefor would show:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 5/8/2017 12:25:09 PM.****1. This is a wrongful death matter arising out of alleged medical malpractice.
2. On March 14, 2017, the undersigned took the duces tecum deposition of Dr.
Carolyn Crawford, Plaintiff's Pediatric and Neonatal Medicine.
3. When Dr. Crawford was asked if she had received any correspondence from
Plaintiffs counsel regarding this matter, Dr. Crawford responded in the affirmative that she
was in possession of approximately nine (9) letters received from Plaintiff's counsel.
4. Undersigned had the referenced letters marked as Exhibit Number one (1) to the
deposition. (See pages 20-21, deposition of Carolyn Crawford, taken March 14, 2017,
attached hereto as Exhibit “A”).
5. | When Dr. Crawford was asked if she maintained a list of cases of matters in which
she has provided testimony, Dr. Crawford responded in the affirmative.
6. When asked if she had the list with her, Dr. Crawford responded that it was going
to be faxed by her office to Dr. Crawford at the deposition site.
7. Plaintiffs counsel denied having the list at the time of the deposition. (See pages
12 - 13, of the deposition of Carolyn Crawford, taken March 14, 2017, attached hereto as
Exhibit “B”).
8. Undersigned requested that once the list was received it be produced and marked
as Exhibit Two (2). (See page 22 of the deposition of Carolyn Crawford, taken March 14,
2017, attached hereto as Exhibit “C”).
9. At the conclusion of Dr. Crawford’s testimony, neither Exhibit One (1) nor
Exhibit (2) were provided to the reporter by the witness or Plaintiff's counsel and were in
fact retained by counsel. (See page 3 of the deposition of Carolyn Crawford, taken March
14, 2017, attached hereto as Exhibit “D”).10. Accordingly, on March 21, 2017, undersigned wrote to Plaintiff's counsel
requesting production of the documents identified as Exhibit One (1) and Exhibit (2) so that
they could be submitted to the reporter and included as part of the official transcript of Dr.
Crawford’s testimony. (See Exhibit “E”, attached hereto).
11. To date, the Plaintiff has not provided the documents to counsel or to the reporter.
12. The documents are relevant, material and necessary to the defense of this case.
13. Defendants will be prejudiced if not provided with the documents referenced by
Dr. Crawford in her deposition.
WHEREFORE, Defendants, respectfully request this Honorable Court for the entry of
an Order compelling the Plaintiff to produce the documents identified as Exhibit One (1) and
Exhibit (2) of the deposition of Dr. Carolyn Crawford, taken March 14, 2017, and any further
relief as this Court deems just and proper.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-filed
with the Clerk of Court through the E-Filing Portal on , and e-served by the
Court Clerk to: ALL COUNSEL OF RECORD ON THE ATTACHED SERVICE LIST,
and a copy was furnished by U.S. mail to Pro Se Defendant, GEORGES EDOUARD, MD,
4330 West Broward Boulevard, Suite C, Plantation, Florida 33317.
CHIMPOULIS, HUNTER & LYNN, P.A.
Attorneys for Defs ROBERTA SANTINI, MD
and FLORIDA UNITED RADIOLOGY, L.C.,
150 South Pine Island Road | Suite 510
Plantation, Florida 33324
Phone: (954) 463-0033
Fax: (954) 463-9562
BY: _/s/ M. Katherine Hunter
M. KATHERINE HUNTER, ESQUIRE
Florida Bar No.: 981877
khunter@échl-law.com
\chl-sbs 1 \files-04and06-27\06-3972\pleadings\m-compel.007 - exh to crawford depo.docxSERVICE LIST
NGUYEN vs. SANTINI, MD, ET AL
Case No.: CACE 14-014218 (04)
Counsel for Plaintiffs:
MARIA D. TEJEDOR, ESQUIRE
Diez-Arguelles | Tejedor
505 North Mills Avenue
Orlando, FL 32803
(407) 705-2880 Phone
SERVICE OF PLEADINGS: mail@theorlandolawyers.com; phillip@theorlandolawyers.com;
mardala@theorlandolawyers.com
Counsel for Defendants/Plantation General Hospital and Dori Rathbun:
JOHN W. MAURO, ESQUIRE / CAROL J. HEALY GLASGOW, ESQUIRE
Billing, Cochran, Lyles, Mauro & Ramsey, P.A.
515 East Las Olas Boulevard
6th Floor SunTrust Center
Fort Lauderdale, FL 33301
(954) 764-7150
SERVICE OF PLEADINGS: fil-pleadings@belmr.com; aliciag@cbelmr.com; cjg(@belmr.com
Co-Counsel for Defendant/Plantation General Hospital:
Paul R. Borr, Esquire
Tache, Bronis, Christianson and Descalzo, P.A.
150 SE Second Avenue, Suite 600
Miami, FL 33131
(305) 537-9573
(305) 537-9567
SERVICE OF PLEADINGS: pbort@tachebronis.comEXHIBIT “A”10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Carolyn Crawford, M.D.
March 14, 2017 20
MS. HUNTER: Maria, don't start with me
today, okay?
MS. TEJEDOR: I know. Well, let's go.
MS. HUNTER: We're going to get through
this deposition very quickly --
MS. TEJEDOR: Great.
MS. HUNTER: -- if you don't interrupt.
THE WITNESS: Oh, attitude. I like this.
MS. HUNTER: I promise you that. Just
don't interrupt me.
THE WITNESS: Okay. Let's go.
Q (By Ms. Hunter) Okay. In this case, when
were you first retained?
A Last year sometime.
Q Do you have any letters from Miss
Tejedor's office --
A Yes.
Q -- with you today?
A Yes. I do.
Q Okay. How many letters have you received
from Miss Tejedor.
(Pause. )
A It's like nine.
Are any of them dated?
A Yes.
U.S. LEGAL SUPPORT
(813) 876-472210
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Carolyn Crawford, M.D.
March 14, 2017 21
Q What's the earliest dated letter you have
there?
(Pause.)
A October, 2016. So some of them aren't
dated, so that's the earliest I can tell you.
Q Okay. Let me do this. Let me attach that
as a cumulative of this, Exhibit Number One to the
deposition.
(Discussion held off record.)
A There's -- oh, wait. It was earlier than
that, because there's a letter that says, "Thank you
for agreeing to review," which I would think is the
first letter.
Q (By Ms. Hunter) Okay.
A So sometime before October 26, 2016.
(Exhibit No. 1 marked for identification.)
Q (By Ms. Hunter) Thank you.
Are you having that expert-witness list of
cases faxed to you or e-mailed to you today?
A Well, I will. As soon as we take a break,
I will make a call to my office and take care of
that.
Q Okay.
A I thought the -- I thought it had been
done, so I apologize.
U.S. LEGAL SUPPORT
(813) 876-4722EXHIBIT “B”10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Carolyn Crawford, M.D.
March 14, 2017 12
Q Okay. How many cases do you currently
have pending with Maria Tejedor or her office?
A I have no.idea. I wouldn't have any way
of being able to answer that. I don't ... those
kinds of records.
Q Well, you do have a list of cases that you
keep, correct?
A I do.
Q All right. So on that list of cases, does
it list the name of the lawyer that's retained you?
A Yes.
Q Okay. So you could look at that list and
tell me how many cases you currently have with
Miss Tejedor?
A No, I can't. Those are just -- the list
only includes cases that I've testified in terms of
deposition or trial. You know, sometimes I get a
case, and I tell her, there's no case here, and
that's the end of it. So I wouldn't have any record
of that.
Q So there are cases that you've reviewed
for Miss Tejedor that are not cases where you've
given deposition testimony?
A True. You know, if I don't think there's
a case, I'm not going to give a deposition.
U.S. LEGAL SUPPORT
(813) 876-472210
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Carolyn Crawford, M.D.
March 14, 2017 13
Q All right. How many cases have you
reviewed for Maria Tejedor in the last three
years?
A Oh, my God, I don't know.
Q More than five?
A Probably.
Q More than ten?
MS. TEJEDOR: Objection. Calls for
speculation. If you don't know, I don't want
you to guess.
A I don't know.
Q (By Ms. Hunter) How many depositions have
you given for Miss Tejedor or her office in the last
three years?
A Again, I don't know. They'd be listed on
the case list.
Q Did you bring that with you today?
A I think it's supposed to be sent from my
office.
THE WITNESS: Did it get here?
MS. TEJEDOR: I don't have the case list.
THE WITNESS: No. Okay.
MS. TEJEDOR: You asked her to bring it?
THE WITNESS: I asked my office to send
it.
U.S. LEGAL SUPPORT
(813) 876-4722EXHIBIT “C”10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Carolyn Crawford, M.D.
March 14, 2017 22
Q That's fine. I get it. Can we attach
that as Number Two, please. Once you get it, okay?
(Exhibit No. 2 to be marked
for identification.)
Q (By Ms. Hunter) What materials have you
reviewed in preparation of giving your opinions
today?
A Okay. I reviewed the prenatal records for
Mai Nguyen, from ... Dr. George Edouard.
I reviewed the --
MS. TEJEDOR: Can we get those cover
letters, please? Hand that to us. They have a
list of what she's reviewed.
A I viewed the medical records from
Plantation General Hospital Mai Nguyen and for Kaden
Nguyen.
The medical records for I from
Joe DiMaggio Children's hospital.
The ... placental pathology and autopsy
report Mai Nguyen.
I reviewed follow-up neuro imaging for
es .
Reviewed ... follow-up records for Kaden
Nguyen from ... Pediatric Neurologists.
I reviewed Plantation General Hospital's
U.S. LEGAL SUPPORT
(813) 876-4722EXHIBIT “D”10
121
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Carolyn Crawford, M.D.
March 14, 2017
INDEX OF PROCEEDINGS
Deposition of CAROLYN CRAWFORD, M.D.
Direct Examination by Ms. Hunter
Cross-Examination by Mr. Mauro
Cross-Examination by Ms. Tejedor
Certificate of Oath
Court Reporter's Certificate
PLAINTIFF'S/DEFENDANT'S EXHIBITS
Number Description
1 Letters from Ms. Tejedor
2 Expert-witness list of cases
3 Copy of ultrasound, 7/25/2012
4 Notes
(Exhibits 1 and 2 retained)
NOTE 1: Ellipses (...) used to reflect pauses
between words.
NOTE 2: "(Nods)" can mean either yes or no.
Page
68
103
132
Page
21
22
28
28
U.S. LEGAL SUPPORT
(813) 876-4722EXHIBIT “E”LAW OFFICE
CHIMPOULIS, HUNTER & LYNN, P.A.
150 SOUTH PINE ISLAND ROAD
MASSEL, J, ABISROR SUITE B10
STAR L. BOYCE PLANTATION, FLORIDA 33324
JAY P, CHIMPOULIS*
DANIEL T. DOYLE NURSE CONSULTANTS
KATY JONES, RN, BSN, MSN
RIC D. FREEDMAN
BAILE A GOL DIANE Te (954) 463-0083 NANGY A, VAZQUEZ, RN, BSN
M, KATHERINE HUNTER: Fax (954) 463-9562 MEDICAL, ANALYST
JESSICA LO MENZO, R.N. :
SONATHON P. LYNN JOANNA B, HOFFMAN
‘SSA T, PICCIRILLOF*
eee eee March 21, 2017 PARALEGALS
ELIZABETH CHIMPOULIS, CLA
BRIAN C. HUNTER ALIGE HONEY, AS.
FIRM ADMINISTRATOR
WILLIAM f, LEMOS DIANE B. STEAD
Also Admitted in Ilinois
‘Admitted to New Jersey & Connecticut only
VIA EMAIL - maria@theorlandolawyers.com; mail@theorlandolawyers.com; amanda@theorlandolawyers.com;
margi corlandolawyers.com; Kristen@theorlandolawyers.con
Maria D. Tejedor, Esquire
Diez-Arguelles & Tejedor, P.A.
505 North Mills Avenue
Orlando, Florida 32803
RE: Nguyen vs, Santini, MD and Florida United Radiology, L.C,
Our File No.: 06-3972
Dear Ms. Tejedor:
Enclosed please find the Notices of Availability for our experts. Please let us know when you will
be providing dates for Drs. Waters and Lichtblau to re-notice their depositions.
As to Dr. Crawford’s deposition that took place on Tuesday, March 14", please provide our office
with the exhibits produced at the time so that we can submit to the court reporter’s office,
Thank you for your attention to this matter.
Very truly yours,
On Kethivine Toler
M. KATHERINE HUNTER
MKH/bp
Enclosures
ce: Carol Glasgow, Esquire (via email)
John Mauro, Esquire (via email)
k\06-397A\letters\ejedor-46-
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Filing # 56115030 E-Filed 05/08/2017 12:25:09 PM 06-3972 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 14-014218 (04) KHAI NGUYEN, Individually, and as Personal Representative of the Estate of MAI TUYET NGUYEN, Deceased, and on behalf of KRISTEN HUYNH, KYLIE NGUYEN and i the surviving children of MAI TUYET NGUYEN, and as the natural parent of EEE, 2 inor, Plaintiffs, vs. PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, ALEX BIRMAN, MD, SUNLIFE OB/GYN SERVICES OF FT. LAUDERDALE, P.A., © GEORGES EDOUARD, MD, GEORGES EDOUARD, MD, PA. d/b/a PLANTATION PAVILION OB/GYN, MELISSA MACHAN, ARNP, ROBERTA SANTINI, MD, DORI RATHBUN and FLORIDA UNITED RADIOLOGY, L.C., Defendants. / DEFENDANTS’ MOTION TO COMPEL COME NOW the Defendants, FLORIDA UNITED RADIOLOGY, L.C. and ROBERTA SANTINI, MD, by and through their undersigned counsel, and request this Honorable Court for the entry of an Order compelling the Plaintiff to produce exhibits to the deposition of Dr. Carolyn Crawford, and as grounds therefor would show: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 5/8/2017 12:25:09 PM.****1. This is a wrongful death matter arising out of alleged medical malpractice. 2. On March 14, 2017, the undersigned took the duces tecum deposition of Dr. Carolyn Crawford, Plaintiff's Pediatric and Neonatal Medicine. 3. When Dr. Crawford was asked if she had received any correspondence from Plaintiffs counsel regarding this matter, Dr. Crawford responded in the affirmative that she was in possession of approximately nine (9) letters received from Plaintiff's counsel. 4. Undersigned had the referenced letters marked as Exhibit Number one (1) to the deposition. (See pages 20-21, deposition of Carolyn Crawford, taken March 14, 2017, attached hereto as Exhibit “A”). 5. | When Dr. Crawford was asked if she maintained a list of cases of matters in which she has provided testimony, Dr. Crawford responded in the affirmative. 6. When asked if she had the list with her, Dr. Crawford responded that it was going to be faxed by her office to Dr. Crawford at the deposition site. 7. Plaintiffs counsel denied having the list at the time of the deposition. (See pages 12 - 13, of the deposition of Carolyn Crawford, taken March 14, 2017, attached hereto as Exhibit “B”). 8. Undersigned requested that once the list was received it be produced and marked as Exhibit Two (2). (See page 22 of the deposition of Carolyn Crawford, taken March 14, 2017, attached hereto as Exhibit “C”). 9. At the conclusion of Dr. Crawford’s testimony, neither Exhibit One (1) nor Exhibit (2) were provided to the reporter by the witness or Plaintiff's counsel and were in fact retained by counsel. (See page 3 of the deposition of Carolyn Crawford, taken March 14, 2017, attached hereto as Exhibit “D”).10. Accordingly, on March 21, 2017, undersigned wrote to Plaintiff's counsel requesting production of the documents identified as Exhibit One (1) and Exhibit (2) so that they could be submitted to the reporter and included as part of the official transcript of Dr. Crawford’s testimony. (See Exhibit “E”, attached hereto). 11. To date, the Plaintiff has not provided the documents to counsel or to the reporter. 12. The documents are relevant, material and necessary to the defense of this case. 13. Defendants will be prejudiced if not provided with the documents referenced by Dr. Crawford in her deposition. WHEREFORE, Defendants, respectfully request this Honorable Court for the entry of an Order compelling the Plaintiff to produce the documents identified as Exhibit One (1) and Exhibit (2) of the deposition of Dr. Carolyn Crawford, taken March 14, 2017, and any further relief as this Court deems just and proper.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-filed with the Clerk of Court through the E-Filing Portal on , and e-served by the Court Clerk to: ALL COUNSEL OF RECORD ON THE ATTACHED SERVICE LIST, and a copy was furnished by U.S. mail to Pro Se Defendant, GEORGES EDOUARD, MD, 4330 West Broward Boulevard, Suite C, Plantation, Florida 33317. CHIMPOULIS, HUNTER & LYNN, P.A. Attorneys for Defs ROBERTA SANTINI, MD and FLORIDA UNITED RADIOLOGY, L.C., 150 South Pine Island Road | Suite 510 Plantation, Florida 33324 Phone: (954) 463-0033 Fax: (954) 463-9562 BY: _/s/ M. Katherine Hunter M. KATHERINE HUNTER, ESQUIRE Florida Bar No.: 981877 khunter@échl-law.com \chl-sbs 1 \files-04and06-27\06-3972\pleadings\m-compel.007 - exh to crawford depo.docxSERVICE LIST NGUYEN vs. SANTINI, MD, ET AL Case No.: CACE 14-014218 (04) Counsel for Plaintiffs: MARIA D. TEJEDOR, ESQUIRE Diez-Arguelles | Tejedor 505 North Mills Avenue Orlando, FL 32803 (407) 705-2880 Phone SERVICE OF PLEADINGS: mail@theorlandolawyers.com; phillip@theorlandolawyers.com; mardala@theorlandolawyers.com Counsel for Defendants/Plantation General Hospital and Dori Rathbun: JOHN W. MAURO, ESQUIRE / CAROL J. HEALY GLASGOW, ESQUIRE Billing, Cochran, Lyles, Mauro & Ramsey, P.A. 515 East Las Olas Boulevard 6th Floor SunTrust Center Fort Lauderdale, FL 33301 (954) 764-7150 SERVICE OF PLEADINGS: fil-pleadings@belmr.com; aliciag@cbelmr.com; cjg(@belmr.com Co-Counsel for Defendant/Plantation General Hospital: Paul R. Borr, Esquire Tache, Bronis, Christianson and Descalzo, P.A. 150 SE Second Avenue, Suite 600 Miami, FL 33131 (305) 537-9573 (305) 537-9567 SERVICE OF PLEADINGS: pbort@tachebronis.comEXHIBIT “A”10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Carolyn Crawford, M.D. March 14, 2017 20 MS. HUNTER: Maria, don't start with me today, okay? MS. TEJEDOR: I know. Well, let's go. MS. HUNTER: We're going to get through this deposition very quickly -- MS. TEJEDOR: Great. MS. HUNTER: -- if you don't interrupt. THE WITNESS: Oh, attitude. I like this. MS. HUNTER: I promise you that. Just don't interrupt me. THE WITNESS: Okay. Let's go. Q (By Ms. Hunter) Okay. In this case, when were you first retained? A Last year sometime. Q Do you have any letters from Miss Tejedor's office -- A Yes. Q -- with you today? A Yes. I do. Q Okay. How many letters have you received from Miss Tejedor. (Pause. ) A It's like nine. Are any of them dated? A Yes. U.S. LEGAL SUPPORT (813) 876-472210 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Carolyn Crawford, M.D. March 14, 2017 21 Q What's the earliest dated letter you have there? (Pause.) A October, 2016. So some of them aren't dated, so that's the earliest I can tell you. Q Okay. Let me do this. Let me attach that as a cumulative of this, Exhibit Number One to the deposition. (Discussion held off record.) A There's -- oh, wait. It was earlier than that, because there's a letter that says, "Thank you for agreeing to review," which I would think is the first letter. Q (By Ms. Hunter) Okay. A So sometime before October 26, 2016. (Exhibit No. 1 marked for identification.) Q (By Ms. Hunter) Thank you. Are you having that expert-witness list of cases faxed to you or e-mailed to you today? A Well, I will. As soon as we take a break, I will make a call to my office and take care of that. Q Okay. A I thought the -- I thought it had been done, so I apologize. U.S. LEGAL SUPPORT (813) 876-4722EXHIBIT “B”10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Carolyn Crawford, M.D. March 14, 2017 12 Q Okay. How many cases do you currently have pending with Maria Tejedor or her office? A I have no.idea. I wouldn't have any way of being able to answer that. I don't ... those kinds of records. Q Well, you do have a list of cases that you keep, correct? A I do. Q All right. So on that list of cases, does it list the name of the lawyer that's retained you? A Yes. Q Okay. So you could look at that list and tell me how many cases you currently have with Miss Tejedor? A No, I can't. Those are just -- the list only includes cases that I've testified in terms of deposition or trial. You know, sometimes I get a case, and I tell her, there's no case here, and that's the end of it. So I wouldn't have any record of that. Q So there are cases that you've reviewed for Miss Tejedor that are not cases where you've given deposition testimony? A True. You know, if I don't think there's a case, I'm not going to give a deposition. U.S. LEGAL SUPPORT (813) 876-472210 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Carolyn Crawford, M.D. March 14, 2017 13 Q All right. How many cases have you reviewed for Maria Tejedor in the last three years? A Oh, my God, I don't know. Q More than five? A Probably. Q More than ten? MS. TEJEDOR: Objection. Calls for speculation. If you don't know, I don't want you to guess. A I don't know. Q (By Ms. Hunter) How many depositions have you given for Miss Tejedor or her office in the last three years? A Again, I don't know. They'd be listed on the case list. Q Did you bring that with you today? A I think it's supposed to be sent from my office. THE WITNESS: Did it get here? MS. TEJEDOR: I don't have the case list. THE WITNESS: No. Okay. MS. TEJEDOR: You asked her to bring it? THE WITNESS: I asked my office to send it. U.S. LEGAL SUPPORT (813) 876-4722EXHIBIT “C”10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Carolyn Crawford, M.D. March 14, 2017 22 Q That's fine. I get it. Can we attach that as Number Two, please. Once you get it, okay? (Exhibit No. 2 to be marked for identification.) Q (By Ms. Hunter) What materials have you reviewed in preparation of giving your opinions today? A Okay. I reviewed the prenatal records for Mai Nguyen, from ... Dr. George Edouard. I reviewed the -- MS. TEJEDOR: Can we get those cover letters, please? Hand that to us. They have a list of what she's reviewed. A I viewed the medical records from Plantation General Hospital Mai Nguyen and for Kaden Nguyen. The medical records for I from Joe DiMaggio Children's hospital. The ... placental pathology and autopsy report Mai Nguyen. I reviewed follow-up neuro imaging for es . Reviewed ... follow-up records for Kaden Nguyen from ... Pediatric Neurologists. I reviewed Plantation General Hospital's U.S. LEGAL SUPPORT (813) 876-4722EXHIBIT “D”10 121 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Carolyn Crawford, M.D. March 14, 2017 INDEX OF PROCEEDINGS Deposition of CAROLYN CRAWFORD, M.D. Direct Examination by Ms. Hunter Cross-Examination by Mr. Mauro Cross-Examination by Ms. Tejedor Certificate of Oath Court Reporter's Certificate PLAINTIFF'S/DEFENDANT'S EXHIBITS Number Description 1 Letters from Ms. Tejedor 2 Expert-witness list of cases 3 Copy of ultrasound, 7/25/2012 4 Notes (Exhibits 1 and 2 retained) NOTE 1: Ellipses (...) used to reflect pauses between words. NOTE 2: "(Nods)" can mean either yes or no. Page 68 103 132 Page 21 22 28 28 U.S. LEGAL SUPPORT (813) 876-4722EXHIBIT “E”LAW OFFICE CHIMPOULIS, HUNTER & LYNN, P.A. 150 SOUTH PINE ISLAND ROAD MASSEL, J, ABISROR SUITE B10 STAR L. BOYCE PLANTATION, FLORIDA 33324 JAY P, CHIMPOULIS* DANIEL T. DOYLE NURSE CONSULTANTS KATY JONES, RN, BSN, MSN RIC D. FREEDMAN BAILE A GOL DIANE Te (954) 463-0083 NANGY A, VAZQUEZ, RN, BSN M, KATHERINE HUNTER: Fax (954) 463-9562 MEDICAL, ANALYST JESSICA LO MENZO, R.N. : SONATHON P. LYNN JOANNA B, HOFFMAN ‘SSA T, PICCIRILLOF* eee eee March 21, 2017 PARALEGALS ELIZABETH CHIMPOULIS, CLA BRIAN C. HUNTER ALIGE HONEY, AS. FIRM ADMINISTRATOR WILLIAM f, LEMOS DIANE B. STEAD Also Admitted in Ilinois ‘Admitted to New Jersey & Connecticut only VIA EMAIL - maria@theorlandolawyers.com; mail@theorlandolawyers.com; amanda@theorlandolawyers.com; margi corlandolawyers.com; Kristen@theorlandolawyers.con Maria D. Tejedor, Esquire Diez-Arguelles & Tejedor, P.A. 505 North Mills Avenue Orlando, Florida 32803 RE: Nguyen vs, Santini, MD and Florida United Radiology, L.C, Our File No.: 06-3972 Dear Ms. Tejedor: Enclosed please find the Notices of Availability for our experts. Please let us know when you will be providing dates for Drs. Waters and Lichtblau to re-notice their depositions. As to Dr. Crawford’s deposition that took place on Tuesday, March 14", please provide our office with the exhibits produced at the time so that we can submit to the court reporter’s office, Thank you for your attention to this matter. Very truly yours, On Kethivine Toler M. KATHERINE HUNTER MKH/bp Enclosures ce: Carol Glasgow, Esquire (via email) John Mauro, Esquire (via email) k\06-397A\letters\ejedor-46-