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Filing # 23669257 E-Filed 02/12/2015 08:09:55 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,
PLANTATION GENERAL HOSPITAL, L.P.
d/b/a PLANTATION GENERAL
HOSPITAL, ALEX BIRMAN, M_D.,
SUNLIFE OB/GYN SERVICES OF FT.
LAUDERDALE, PA, 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.
/
PLAINTIFFS’ OBJECTION TO DEFENDANTS, PLANTATION GENERAL
HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL
AND DORI RATHBUN’S NOTICE OF PRODUCTION
FROM NON-PARTY DATED February 5, 2015
COMES NOW, the Plaintiffs, 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, by
and through their undersigned counsel and hereby files this Objection to Defendants,
PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 2/12/2015 8:09:55 AM.****HOSPITAL and DORI RATHBUN’s Notice of Production from Non-Party dated February
5, 2015 and would state the following:
1. Defendants, PLANTATION GENERAL HOSPITAL, L.P. d/b/a
PLANTATION GENERAL HOSPITAL and DORI RATHBUN filed a Notice of
Production from Non-Party on or about February 5, 2015, in order to subpoena records
pertaining to the non-party, KYLIE NGUYEN, from PARK LAKES ELEMENTARY,
2. Plaintiffs file this objection based upon relevance as the records requested
are not reasonably calculated to lead to the discovery of admissible evidence.
3. Furthermore, Plaintiffs objects that as KYLIE NGUYEN, a minor, is a
claimant and Non-Party to this action and has the right to privacy as guaranteed by the
Florida Constitution.
WHEREFORE, Plaintiffs’ object to the production of any and all documentation,
records or any depositions of any records custodians from PARK LAKES ELEMENTARY
in the notice filed by the Defendant on February 5, 2015.
CERTIFICATE OF SERVICE
IT HEREBY CERTIFY that a true and correct copy of the foregoing has was sent
by Electronic Mail this 11" day of February, 2015 to: atherine Hunter, Esq.,
(khunter@chl-law.com), John W. Mauro, Esq., (wm@belmr, and (cjg@belmr.com)
Ariel Widlansky, Esq. (ariel@lubellrosen.com). past
Florida Bar Number: 95834
Jack T. Cook
Florida Bar Number: 88589
Diez-Arguelles & Tejedor, PA
Attorney for Plaintiffs
505 N. Mills Ave.
Orlando, FL 32803
P: 407-705-2880
mail@theorlandolawyers.com
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Filing # 23669257 E-Filed 02/12/2015 08:09:55 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, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, ALEX BIRMAN, M_D., SUNLIFE OB/GYN SERVICES OF FT. LAUDERDALE, PA, 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. / PLAINTIFFS’ OBJECTION TO DEFENDANTS, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL AND DORI RATHBUN’S NOTICE OF PRODUCTION FROM NON-PARTY DATED February 5, 2015 COMES NOW, the Plaintiffs, 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, by and through their undersigned counsel and hereby files this Objection to Defendants, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 2/12/2015 8:09:55 AM.****HOSPITAL and DORI RATHBUN’s Notice of Production from Non-Party dated February 5, 2015 and would state the following: 1. Defendants, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL and DORI RATHBUN filed a Notice of Production from Non-Party on or about February 5, 2015, in order to subpoena records pertaining to the non-party, KYLIE NGUYEN, from PARK LAKES ELEMENTARY, 2. Plaintiffs file this objection based upon relevance as the records requested are not reasonably calculated to lead to the discovery of admissible evidence. 3. Furthermore, Plaintiffs objects that as KYLIE NGUYEN, a minor, is a claimant and Non-Party to this action and has the right to privacy as guaranteed by the Florida Constitution. WHEREFORE, Plaintiffs’ object to the production of any and all documentation, records or any depositions of any records custodians from PARK LAKES ELEMENTARY in the notice filed by the Defendant on February 5, 2015. CERTIFICATE OF SERVICE IT HEREBY CERTIFY that a true and correct copy of the foregoing has was sent by Electronic Mail this 11" day of February, 2015 to: atherine Hunter, Esq., (khunter@chl-law.com), John W. Mauro, Esq., (wm@belmr, and (cjg@belmr.com) Ariel Widlansky, Esq. (ariel@lubellrosen.com). past Florida Bar Number: 95834 Jack T. Cook Florida Bar Number: 88589 Diez-Arguelles & Tejedor, PA Attorney for Plaintiffs 505 N. Mills Ave. Orlando, FL 32803 P: 407-705-2880 mail@theorlandolawyers.com