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Filing # 77907480 E-Filed 09/14/2018 12:05:41 PM
WAL- 22024 /HMCNMC
IN THE CIRCUIT COURT OF THE
71TH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO. 17-014926 CA-01 (31)
XIOMARA LLERENA AND
ROBERTO LLERENA,
Plaintiff(s},
v.
QUINTANA FAMILY DAY CARE HOME
D/B/A LEARNING AND GROWING FAMILY
CHILD CARE,
Defendant(s).
(Please advise if interpreter is necessary)
(Stote issued photo identification with current address is required at time of
examination)
Defendant, QUINTANA FAMILY DAY CARE HOME D/B/A LEARNING AND
GROWING FAMILY CHILD CARE, by and through undersigned counsel, pursuant to Fla. R.
Civ. P. 1.360, and states:
1. TYPE OF EXAMINATION REQUESTED - The Defendant(s) request(s) the
Plaintiff, XOMARA LLERENA, to submit to an ORTHOPEDIC EXAMINATION with Richard
Rozenvwaig, MLD.CASE NO.: 17-014926 CA-O1 (31)
Page 2
2 TIME AND PLACE OF EXAMINATIGN - This examination will be held on
October 22, 2018 at 3:30 p.m. (Plaintiff/patient should arrive at 3:15 pm) at the office of
Dr. Richard Rozencwaig, Orthopedic Care Center, 21000 NE 28” Avenue, Suite 104,
Aventura, Florida 33160.
3. MANNER, CONDITIONS AND SCOPE OF EXAMINATION - This examination
would be conducted in the normal manner all such examinations are done, and will
include, but not be limited to: the taking of a written and/or oral history, x-rays and other
radiographs, if appropriate, testing and examination. The scope of the examination would
be to inquire into all issues raised by the particular problems alleged within the examiner's
field of expertise as designated above. A detailed written report, setting out the findings,
including results of all tests made, diagnosis and conclusions would be prepared by the
expert which would be available to counsel of the examined party if requested under the
provisions of Fla. R. Civ. P. 1.360. The requesting party will pay for the examination, subject
to being taxed as costs, if applicable, All similar reports of all earlier examinations of the
same condition would be made available as well. The requesting party reserves all rights
under Fla. R. Civ. P, 1.360(b)(1) and (3), THE PARTY TO BE EXAMINED IS REQUESTED
TO GIVE NO LESS THAN 72 HOURS NOTICE (EXCLUDING WEEKENDS and
HOLIDAYS) IF THE APPOINTMENT CANNOT BE KEPT. THE EXAMINER MAY SEEK A
ELLATION FEE OF $256.00 IF APPROPRIATE NOTICE IS NOT GIVEN,CASE NO.: 17-014926 CA-01 81}
Page 3
4. REASON FOR EXAI
personal injuries and placed those allegations in issue. There is good cause for the
examination as the requesting party is permitted to inquire into the alleged condition(s).
5. DESIGNATION OF EXPERT - The examiner shail be referred to as a “Defense
requested expert.”
6. RESPONSE REQUESTED- In accordance with the provisions of Fla, R. Civ. P.
1.360, a response is requested. Should there be no objection, in order to prevent delay,
it Is respectfully requested counsel for the party to be examined respond upon receipt of
this request.
7, REQUEST FOR NOTIFICATION OF THIRD PARTY PARTICIPATION: Fla. R.
Civ. P. 1.360 requires the request for the examination to indicate it will be recorded
and to specify the number of people attending, their role, and the method of
recording.
The Plaintiff is requested to notify the undersigned counsel if the examination is
going to be videotaped, attended by counsel, by a Court reporter or any other person.
The identity of the person to attend and the capacity he or she will attend the examination
in is requested with the response to this notice.CASE NO. 17-014926 CA-01 (31)
Page 4
ice
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via Electronic Mail, to all counsel of record on the attached Service List, this 14"
day of September, 2018.
LUKS, SANTANIELLO, PETRILLO & JONES
Attormeys for Defendant
150 W. Flagler Street
Suite 2600
Miami, FL 33130
Telephone: (305) 377-8900
Facsimile: (305) 377-8901
DANIEL J. SANTANIELLO
Florida Bar No.: 860948
HEATHER M. CALHOON
Florida Bar No. 495573
LURSMIS Baseline! 23 gue cen
SERVICE LIST
Michael J. Carmona, Esq.
Friedland Law Group
1430 South Dixie Highway
Suite 305
Coral Gables, Florida 33146
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Filing # 77907480 E-Filed 09/14/2018 12:05:41 PM WAL- 22024 /HMCNMC IN THE CIRCUIT COURT OF THE 71TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO. 17-014926 CA-01 (31) XIOMARA LLERENA AND ROBERTO LLERENA, Plaintiff(s}, v. QUINTANA FAMILY DAY CARE HOME D/B/A LEARNING AND GROWING FAMILY CHILD CARE, Defendant(s). (Please advise if interpreter is necessary) (Stote issued photo identification with current address is required at time of examination) Defendant, QUINTANA FAMILY DAY CARE HOME D/B/A LEARNING AND GROWING FAMILY CHILD CARE, by and through undersigned counsel, pursuant to Fla. R. Civ. P. 1.360, and states: 1. TYPE OF EXAMINATION REQUESTED - The Defendant(s) request(s) the Plaintiff, XOMARA LLERENA, to submit to an ORTHOPEDIC EXAMINATION with Richard Rozenvwaig, MLD.CASE NO.: 17-014926 CA-O1 (31) Page 2 2 TIME AND PLACE OF EXAMINATIGN - This examination will be held on October 22, 2018 at 3:30 p.m. (Plaintiff/patient should arrive at 3:15 pm) at the office of Dr. Richard Rozencwaig, Orthopedic Care Center, 21000 NE 28” Avenue, Suite 104, Aventura, Florida 33160. 3. MANNER, CONDITIONS AND SCOPE OF EXAMINATION - This examination would be conducted in the normal manner all such examinations are done, and will include, but not be limited to: the taking of a written and/or oral history, x-rays and other radiographs, if appropriate, testing and examination. The scope of the examination would be to inquire into all issues raised by the particular problems alleged within the examiner's field of expertise as designated above. A detailed written report, setting out the findings, including results of all tests made, diagnosis and conclusions would be prepared by the expert which would be available to counsel of the examined party if requested under the provisions of Fla. R. Civ. P. 1.360. The requesting party will pay for the examination, subject to being taxed as costs, if applicable, All similar reports of all earlier examinations of the same condition would be made available as well. The requesting party reserves all rights under Fla. R. Civ. P, 1.360(b)(1) and (3), THE PARTY TO BE EXAMINED IS REQUESTED TO GIVE NO LESS THAN 72 HOURS NOTICE (EXCLUDING WEEKENDS and HOLIDAYS) IF THE APPOINTMENT CANNOT BE KEPT. THE EXAMINER MAY SEEK A ELLATION FEE OF $256.00 IF APPROPRIATE NOTICE IS NOT GIVEN,CASE NO.: 17-014926 CA-01 81} Page 3 4. REASON FOR EXAI personal injuries and placed those allegations in issue. There is good cause for the examination as the requesting party is permitted to inquire into the alleged condition(s). 5. DESIGNATION OF EXPERT - The examiner shail be referred to as a “Defense requested expert.” 6. RESPONSE REQUESTED- In accordance with the provisions of Fla, R. Civ. P. 1.360, a response is requested. Should there be no objection, in order to prevent delay, it Is respectfully requested counsel for the party to be examined respond upon receipt of this request. 7, REQUEST FOR NOTIFICATION OF THIRD PARTY PARTICIPATION: Fla. R. Civ. P. 1.360 requires the request for the examination to indicate it will be recorded and to specify the number of people attending, their role, and the method of recording. The Plaintiff is requested to notify the undersigned counsel if the examination is going to be videotaped, attended by counsel, by a Court reporter or any other person. The identity of the person to attend and the capacity he or she will attend the examination in is requested with the response to this notice.CASE NO. 17-014926 CA-01 (31) Page 4 ice WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Electronic Mail, to all counsel of record on the attached Service List, this 14" day of September, 2018. LUKS, SANTANIELLO, PETRILLO & JONES Attormeys for Defendant 150 W. Flagler Street Suite 2600 Miami, FL 33130 Telephone: (305) 377-8900 Facsimile: (305) 377-8901 DANIEL J. SANTANIELLO Florida Bar No.: 860948 HEATHER M. CALHOON Florida Bar No. 495573 LURSMIS Baseline! 23 gue cen SERVICE LIST Michael J. Carmona, Esq. Friedland Law Group 1430 South Dixie Highway Suite 305 Coral Gables, Florida 33146