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Filing # 16972106 Electronically Filed 08/12/2014 08:30:24 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
KHAI NGUYEN, individually, and as Personal CASE NO.: CACE-14014218 Div: 04
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, P.A., GEORGES
EDOUARD, M.D., GEORGES EDOUARD, M.D.,
PA. d/b/a PLANTATION PAVILION
OB/GYN, MELISSA =MACHAN, — ARNP,
ROBERTA SANTINI, M.D., DORI RATHBUN,
FLORIDA UNITED RADIOLOGY, L.C.,
Defendants.
/
REQUEST TO PRODUCE TO DEFENDANT, FLORIDA UNITED RADIOLOGY, L.C.
TO: — Florida United Radiology, LC
Through its Registered Agent,
Jay A. Martus
1613 North Harrison Pkwy., Ste. 200
Sunrise, FL 33323
PURSUANT TO Rule 1.350, Florida Rules of Civil Procedure, Plaintiff, KHAl 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 MAI
TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, by and through the
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/12/2014 8:30:22 AM.****undersigned attorney, requests the Defendant, FLORIDA UNITED RADIOLOGY, L.C., within forty-
five (45) days from the date of service, to produce the items below:
1
10.
A color laser copy of any and all charts/medical records of MAl TUYET NGUYEN
and KADEN NGUYEN, a minor.
Copies of any and all insurance forms submitted to any carrier/State of Florida for
payment regarding MAI TUYET NGUYEN and KADEN NGUYEN, a minor.
Copies of any and all correspondence from any insurance carrier/State of Florida
regarding MAI TUYET NGUYEN and KADEN NGUYEN, a minor.
Copies of any and all proof of payment from any insurance carrier/State of
Florida regarding MAI TUYET NGUYEN and KADEN NGUYEN, a minor.
Copies of any and all policies, procedures and/or the operations manual(s) in
place during June 2012 and July 2012, pertaining to pregnancies involving
amniotic fluid embolisms, cardiopulmonary arrest, hemorrages, fetal heart
monitoring, rapid response, use of Cytotec, and/or forceps delivery.
Copies of the sign-in log for July 25, 2012, the date in question; however, you may
redact the records of those names that do not pertain to the treatment of MAI
TUYET NGUYEN and KADEN NGUYEN.
All photographs of MAI TUYET NGUYEN and KADEN NGUYEN.
All correspondence between FLORIDA UNITED RADIOLOGY, L.C. and MAI TUYET
NGUYEN and KADEN NGUYEN.
All nursing notes regarding the medical treatment rendered to MAl TUYET NGUYEN
and KADEN NGUYEN.
All copies of any prescriptions prescribed to MAI TUYET NGUYEN and KADEN
NGUYEN in Defendant's possession.1.
12.
13.
14.
15.
16.
Copies of any and all monitoring reports, including, but not limited to, fetal monitor
tracing, of the treatment rendered to MAI TUYET NGUYEN and KADEN NGUYEN.
Copies of each ultrasound report taken of MAl TUYET NGUYEN on July 25, 2012.
Copies of each ultrasound taken of MAI TUYET NGUYEN in electronic format.
Copies of any reports, data, or any other information indicating the number of
deliveries involving amniotic fluid embolisms, cardiopulmonary arrest, and
hemorrhageing at your facility in 2011, 2012, and 2013. Please redact the
records as provided in subsection (b) of the Patients’ Right to Know about Adverse
Medical Incidents.
Pursuant to Section 25 of the Florida Constitution (the Patients’ Right to Know About
Adverse Medical Incidents) and the definitions contained therein, please provide for
the inspection and copying all records made or received in the course of business
by FLORIDA UNITED RADIOLOGY, L.C. relating to any adverse medical incident
involving ALEX BIRMAN, M.D., GEORGES EDOUARD, M.D.,ROBERTA SANTINI,
M.D., MELISSA MACHAN, ARNP, DORI RATHBUN and/or PLANTATION GENERAL
HOSPITAL LIMITED PARTNERSHIP d/b/a PLANTATION GENERAL HOSPITAL.
Please redact the records as provided in subsection (b) of the Patients’ Right to
Know about Adverse Medical Incidents.
Any and all contacts, agreements, employment contracts and/or joint venture
agreements between ALEX BIRMAN, M.D., GEORGES EDOUARD, M.D., SUNLIFE
OB/GYN SERVICIES OF FT. LAUDERDALE, P.A.,.ROBERTA SANTINI, M.D., DORI
RATHBUN, MELISSA MACHAN, ARNP, PLANTATION GENERAL HOSPITAL LIMITED
PARTNERSHIP d/b/a PLANTATION GENERAL HOSPITAL and FLORIDA UNITED
RADIOLOGY, L.P. that were in place in July 2012.17. Any and all documents provided by health care providers of MAI TUYET NGUYEN
and KADEN NGUYEN to any billing personnel or departments for the purpose of
preparing billing logs or billing sheets in this case.
18. Any and all claim forms, billing logs, billing sheets, statements and/or ledgers,
regarding MAI TUYET NGUYEN and KADEN NGUYEN.
It is requested that the above documents and materials shall be produced within forty-five
(45) days from the date of service hereof, at the offices of Diez-Arguelles & Tejedor, P.A., 505 N.
Mills Ave., Orlando, Florida 32803.
In support of this Request to Produce, it is shown that the documents and/or materials being
herein requested are believed to be in the possession, custody or control of the party to whom this
Request is directed. The information sought by this Request is relevant to the subject matter of this
action and cannot otherwise be obtained without undue hardship. In the event that all or part of the
documents and/or materials herein requested is not in the possession or control of the above
addressee, then the undersigned counsel further requests the identity and location of all persons
having such possession and control. This request is made in good faith and for the purposes herein
expressed.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that the foregoing has been furnished, along with the Complaint, Summons,
Request for Admissions, and Interrogatories, via service of process to Florida United Radiology, LC
Through its Registered Agent, Jay A. Martus, 1613 North Harrison Pkwy., Ste. 200, Sunrise, FL
33323 on this 12th day of August, 2014.
[s/ Jack T. Cook
Maria D. Tejedor
FBN: 0095834
Jack T. Cook
FBN: 88589
DIEZ-ARGUELLES & TEJEDOR, P.A.
505 N. Mills Avenue
Orlando, FL 32803Telephone: (407) 705-2880
Attorney for Plaintiffs
mail@theorlandolawyers.com
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Filing # 16972106 Electronically Filed 08/12/2014 08:30:24 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA KHAI NGUYEN, individually, and as Personal CASE NO.: CACE-14014218 Div: 04 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, P.A., GEORGES EDOUARD, M.D., GEORGES EDOUARD, M.D., PA. d/b/a PLANTATION PAVILION OB/GYN, MELISSA =MACHAN, — ARNP, ROBERTA SANTINI, M.D., DORI RATHBUN, FLORIDA UNITED RADIOLOGY, L.C., Defendants. / REQUEST TO PRODUCE TO DEFENDANT, FLORIDA UNITED RADIOLOGY, L.C. TO: — Florida United Radiology, LC Through its Registered Agent, Jay A. Martus 1613 North Harrison Pkwy., Ste. 200 Sunrise, FL 33323 PURSUANT TO Rule 1.350, Florida Rules of Civil Procedure, Plaintiff, KHAl 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 MAI TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, by and through the *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/12/2014 8:30:22 AM.****undersigned attorney, requests the Defendant, FLORIDA UNITED RADIOLOGY, L.C., within forty- five (45) days from the date of service, to produce the items below: 1 10. A color laser copy of any and all charts/medical records of MAl TUYET NGUYEN and KADEN NGUYEN, a minor. Copies of any and all insurance forms submitted to any carrier/State of Florida for payment regarding MAI TUYET NGUYEN and KADEN NGUYEN, a minor. Copies of any and all correspondence from any insurance carrier/State of Florida regarding MAI TUYET NGUYEN and KADEN NGUYEN, a minor. Copies of any and all proof of payment from any insurance carrier/State of Florida regarding MAI TUYET NGUYEN and KADEN NGUYEN, a minor. Copies of any and all policies, procedures and/or the operations manual(s) in place during June 2012 and July 2012, pertaining to pregnancies involving amniotic fluid embolisms, cardiopulmonary arrest, hemorrages, fetal heart monitoring, rapid response, use of Cytotec, and/or forceps delivery. Copies of the sign-in log for July 25, 2012, the date in question; however, you may redact the records of those names that do not pertain to the treatment of MAI TUYET NGUYEN and KADEN NGUYEN. All photographs of MAI TUYET NGUYEN and KADEN NGUYEN. All correspondence between FLORIDA UNITED RADIOLOGY, L.C. and MAI TUYET NGUYEN and KADEN NGUYEN. All nursing notes regarding the medical treatment rendered to MAl TUYET NGUYEN and KADEN NGUYEN. All copies of any prescriptions prescribed to MAI TUYET NGUYEN and KADEN NGUYEN in Defendant's possession.1. 12. 13. 14. 15. 16. Copies of any and all monitoring reports, including, but not limited to, fetal monitor tracing, of the treatment rendered to MAI TUYET NGUYEN and KADEN NGUYEN. Copies of each ultrasound report taken of MAl TUYET NGUYEN on July 25, 2012. Copies of each ultrasound taken of MAI TUYET NGUYEN in electronic format. Copies of any reports, data, or any other information indicating the number of deliveries involving amniotic fluid embolisms, cardiopulmonary arrest, and hemorrhageing at your facility in 2011, 2012, and 2013. Please redact the records as provided in subsection (b) of the Patients’ Right to Know about Adverse Medical Incidents. Pursuant to Section 25 of the Florida Constitution (the Patients’ Right to Know About Adverse Medical Incidents) and the definitions contained therein, please provide for the inspection and copying all records made or received in the course of business by FLORIDA UNITED RADIOLOGY, L.C. relating to any adverse medical incident involving ALEX BIRMAN, M.D., GEORGES EDOUARD, M.D.,ROBERTA SANTINI, M.D., MELISSA MACHAN, ARNP, DORI RATHBUN and/or PLANTATION GENERAL HOSPITAL LIMITED PARTNERSHIP d/b/a PLANTATION GENERAL HOSPITAL. Please redact the records as provided in subsection (b) of the Patients’ Right to Know about Adverse Medical Incidents. Any and all contacts, agreements, employment contracts and/or joint venture agreements between ALEX BIRMAN, M.D., GEORGES EDOUARD, M.D., SUNLIFE OB/GYN SERVICIES OF FT. LAUDERDALE, P.A.,.ROBERTA SANTINI, M.D., DORI RATHBUN, MELISSA MACHAN, ARNP, PLANTATION GENERAL HOSPITAL LIMITED PARTNERSHIP d/b/a PLANTATION GENERAL HOSPITAL and FLORIDA UNITED RADIOLOGY, L.P. that were in place in July 2012.17. Any and all documents provided by health care providers of MAI TUYET NGUYEN and KADEN NGUYEN to any billing personnel or departments for the purpose of preparing billing logs or billing sheets in this case. 18. Any and all claim forms, billing logs, billing sheets, statements and/or ledgers, regarding MAI TUYET NGUYEN and KADEN NGUYEN. It is requested that the above documents and materials shall be produced within forty-five (45) days from the date of service hereof, at the offices of Diez-Arguelles & Tejedor, P.A., 505 N. Mills Ave., Orlando, Florida 32803. In support of this Request to Produce, it is shown that the documents and/or materials being herein requested are believed to be in the possession, custody or control of the party to whom this Request is directed. The information sought by this Request is relevant to the subject matter of this action and cannot otherwise be obtained without undue hardship. In the event that all or part of the documents and/or materials herein requested is not in the possession or control of the above addressee, then the undersigned counsel further requests the identity and location of all persons having such possession and control. This request is made in good faith and for the purposes herein expressed. CERTIFICATE OF SERVICE | HEREBY CERTIFY that the foregoing has been furnished, along with the Complaint, Summons, Request for Admissions, and Interrogatories, via service of process to Florida United Radiology, LC Through its Registered Agent, Jay A. Martus, 1613 North Harrison Pkwy., Ste. 200, Sunrise, FL 33323 on this 12th day of August, 2014. [s/ Jack T. Cook Maria D. Tejedor FBN: 0095834 Jack T. Cook FBN: 88589 DIEZ-ARGUELLES & TEJEDOR, P.A. 505 N. Mills Avenue Orlando, FL 32803Telephone: (407) 705-2880 Attorney for Plaintiffs mail@theorlandolawyers.com