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Filing # 52989718 E-Filed 02/27/2017 09:41:31 AM
IN THE CIRCUIT COURT OF THE
17% JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. 14-14218 (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, the surviving children of
MAI TUYET NGUYEN, and as the natural parent
of KADEN NGUYEN, a minor,
Plaintiff,
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.
/
DEFENDANT, PLANTATION GENERAL HOSPITAL’S
RESPONSE TO PLAINTIFFS’ REQUEST TO PRODUCE
COMES NOW the Defendant, PLANTATION GENERAL HOSPITAL, L.P. d/b/a
PLANTATION GENERAL HOSPITAL, by and through its undersigned counsel, and
hereby files this, its Response to the Plaintiffs’ Request to Produce dated November
16, 2016, and responds as follows:
1. A complete and entire copy of the audit trail for the electronic
medical records (EMR) and/or Electronic Health records (EHR) for
MAI TUYET NGUYEN relative to her care and treatment at
PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION
GENERAL HOSPITAL, beginning on or before July 25, 2012. Such
request includes, but is not limited to:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/27/2017 9:41:31 AM.****a.
Disclosures and/or log entries of each and every user who
accessed MAI TUYET NGUYEN 's medical, pharmacy, laboratory
or any other record during or after her care and treatment,
including the date and time of each and every access by each and
every user for each level of security;
See enclosed audit trail.
Identification of each login by number and user (to include full
name and department and the location of the terminal from
which the file was accessed) (passwords are not requested);
See enclosed audit trail.
The action that each user authorized, ordered, or completed;
the portion of the MAl TUYET NGUYEN 's record which was
accessed, whether or not any modifications or additions were
made; the specific modifications made to the medical records;
any amendment to any record, any supplement to any part of
the record; any deletion of any part of the record; any change
to the record in ANY way and the time and reason of such
access and/or change of record;
See enclosed audit trail.
A log or printout listing each and every time any x-ray, MR1,
CT scan, or other imaging or radiology study was viewed
and/or ordered; each and every time any EEG study was
viewed and/or ordered; and each and every time any other
study, laboratory result, or data relating to MAI TUYET
NGUYEN 's care was viewed and/or ordered on the computer
system; and by whom, with date, time and location of viewing.
See enclosed audit trail.
The complete audit trail for the electronic medical records (EMR)
and/or Electronic Health records (EHR) for KADEN NGUYEN
pertaining to any and all hospitalizations at PLANTATION GENERAL
HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, to
include, but not limited to, KADEN NGUYEN's EMR and/or EHRs
surrounding his birth in July 2012. Such request includes, but is not
limited to:
a.
Disclosures and /or log entries of each and every user who
accessed KADEN NGUYEN 's medical, pharmacy, laboratory or
any other record during or after his hospitalization, including thedate and time of each and every access by each and every user
for each level of security;
See enclosed audit trail.
b. Identification of each login by number and user (include full
name and department and the location of the terminal from
which the file was accessed) (passwords are not requested);
See enclosed audit trail.
Cc. The action that each user authorized, ordered, or completed;
the portion of the KADEN NGUYEN's record which was
accessed, whether or not any modifications or additions were
made; the specific modifications made to the medical records;
any amendment to any record; any supplement to any part of
the record; any deletion of any part of the record; any change
to the record in ANY way; and the time and reason of such
access and/or change of record;
See enclosed audit trail.
d. A log or printout listing each and every time any x-ray, MRI, CT
scan, or other imaging or radiology study was viewed and/or
ordered; each and every time any EEG study was viewed and/or
ordered; and each and every time any other study, laboratory
result, or data relating to KADEN NGUYEN 's care was viewed
and/or ordered on the computer system; and by whom, with date,
time and location of viewing.
See enclosed audit trail.
A corresponding legend, reference or guide that defines any and all
abbreviations or codes which appear in the documents provided pursuant
to this request.
Requested and a supplemental response will be provided.CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing document was
e-filed and e-served to all on the attached mailing list this 27" day of February, 2017.
BY:
/s/ JOHN W. MAURO, ESQ.
JOHN W. MAURO, ESQ.
jwm@bclmr.com
Florida Bar No: 276634
CAROL J. HEALY GLASGOW, ESQ.
cijg@belmr.com
Florida Bar No. 026239
BILLING, COCHRAN, LYLES,
MAURO & RAMSEY, P.A.
Attorneys for Defendants, PGH and Rathbun
SunTrust Center, 6!" Floor
515 E. Las Olas Blvd.,
Fort Lauderdale, Florida 33301
Ofe: (954) 764-7150; Fax: (954) 764-7279
E-Filing Address: ftl-pleadings@bclmr.com
$:\34412204\PLDS\DISC\RTP & Resp\RRTP.PI 11-16-16 (audit trail).docx/lasMaria D. Tejedor, Esq.
Diez-Arguelles Tejedor
505 N. Mills Avenue
Orlando, FL 32803
407-705-2880
mail@theorlandolawyers.com
robin@theorlandolawyers.com
jack@theorlandolawyers.com
M. Katherine Hunter, Esq.
Chimpoulis, Hunter & Lynn, P.A.
150 S. Pine Island Road, Suite 510
Plantation, FL 33324
954-463-0033
954-463-9562 — fax
ahoney@chl-law.com
khunter@chl-law.com
cwieland@chl-law.com
Georges Edouard, M.D.
4330 W. Broward Blvd. Suite C
Plantation, FL 33317
Mailing List
Nguyen/PGH
344.12204
Counsel for Plaintiff
Counsel for Dr. Santini & Florida United
Radiology
(pro se)3. A corresponding legend, reference, or guide that defines any and all abbreviations
or codes which appear in the documents provided pursuant to this request.
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Filing # 52989718 E-Filed 02/27/2017 09:41:31 AM IN THE CIRCUIT COURT OF THE 17% JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 14-14218 (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, the surviving children of MAI TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, Plaintiff, 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. / DEFENDANT, PLANTATION GENERAL HOSPITAL’S RESPONSE TO PLAINTIFFS’ REQUEST TO PRODUCE COMES NOW the Defendant, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, by and through its undersigned counsel, and hereby files this, its Response to the Plaintiffs’ Request to Produce dated November 16, 2016, and responds as follows: 1. A complete and entire copy of the audit trail for the electronic medical records (EMR) and/or Electronic Health records (EHR) for MAI TUYET NGUYEN relative to her care and treatment at PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, beginning on or before July 25, 2012. Such request includes, but is not limited to: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/27/2017 9:41:31 AM.****a. Disclosures and/or log entries of each and every user who accessed MAI TUYET NGUYEN 's medical, pharmacy, laboratory or any other record during or after her care and treatment, including the date and time of each and every access by each and every user for each level of security; See enclosed audit trail. Identification of each login by number and user (to include full name and department and the location of the terminal from which the file was accessed) (passwords are not requested); See enclosed audit trail. The action that each user authorized, ordered, or completed; the portion of the MAl TUYET NGUYEN 's record which was accessed, whether or not any modifications or additions were made; the specific modifications made to the medical records; any amendment to any record, any supplement to any part of the record; any deletion of any part of the record; any change to the record in ANY way and the time and reason of such access and/or change of record; See enclosed audit trail. A log or printout listing each and every time any x-ray, MR1, CT scan, or other imaging or radiology study was viewed and/or ordered; each and every time any EEG study was viewed and/or ordered; and each and every time any other study, laboratory result, or data relating to MAI TUYET NGUYEN 's care was viewed and/or ordered on the computer system; and by whom, with date, time and location of viewing. See enclosed audit trail. The complete audit trail for the electronic medical records (EMR) and/or Electronic Health records (EHR) for KADEN NGUYEN pertaining to any and all hospitalizations at PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, to include, but not limited to, KADEN NGUYEN's EMR and/or EHRs surrounding his birth in July 2012. Such request includes, but is not limited to: a. Disclosures and /or log entries of each and every user who accessed KADEN NGUYEN 's medical, pharmacy, laboratory or any other record during or after his hospitalization, including thedate and time of each and every access by each and every user for each level of security; See enclosed audit trail. b. Identification of each login by number and user (include full name and department and the location of the terminal from which the file was accessed) (passwords are not requested); See enclosed audit trail. Cc. The action that each user authorized, ordered, or completed; the portion of the KADEN NGUYEN's record which was accessed, whether or not any modifications or additions were made; the specific modifications made to the medical records; any amendment to any record; any supplement to any part of the record; any deletion of any part of the record; any change to the record in ANY way; and the time and reason of such access and/or change of record; See enclosed audit trail. d. A log or printout listing each and every time any x-ray, MRI, CT scan, or other imaging or radiology study was viewed and/or ordered; each and every time any EEG study was viewed and/or ordered; and each and every time any other study, laboratory result, or data relating to KADEN NGUYEN 's care was viewed and/or ordered on the computer system; and by whom, with date, time and location of viewing. See enclosed audit trail. A corresponding legend, reference or guide that defines any and all abbreviations or codes which appear in the documents provided pursuant to this request. Requested and a supplemental response will be provided.CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing document was e-filed and e-served to all on the attached mailing list this 27" day of February, 2017. BY: /s/ JOHN W. MAURO, ESQ. JOHN W. MAURO, ESQ. jwm@bclmr.com Florida Bar No: 276634 CAROL J. HEALY GLASGOW, ESQ. cijg@belmr.com Florida Bar No. 026239 BILLING, COCHRAN, LYLES, MAURO & RAMSEY, P.A. Attorneys for Defendants, PGH and Rathbun SunTrust Center, 6!" Floor 515 E. Las Olas Blvd., Fort Lauderdale, Florida 33301 Ofe: (954) 764-7150; Fax: (954) 764-7279 E-Filing Address: ftl-pleadings@bclmr.com $:\34412204\PLDS\DISC\RTP & Resp\RRTP.PI 11-16-16 (audit trail).docx/lasMaria D. Tejedor, Esq. Diez-Arguelles Tejedor 505 N. Mills Avenue Orlando, FL 32803 407-705-2880 mail@theorlandolawyers.com robin@theorlandolawyers.com jack@theorlandolawyers.com M. Katherine Hunter, Esq. Chimpoulis, Hunter & Lynn, P.A. 150 S. Pine Island Road, Suite 510 Plantation, FL 33324 954-463-0033 954-463-9562 — fax ahoney@chl-law.com khunter@chl-law.com cwieland@chl-law.com Georges Edouard, M.D. 4330 W. Broward Blvd. Suite C Plantation, FL 33317 Mailing List Nguyen/PGH 344.12204 Counsel for Plaintiff Counsel for Dr. Santini & Florida United Radiology (pro se)3. A corresponding legend, reference, or guide that defines any and all abbreviations or codes which appear in the documents provided pursuant to this request.