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Filing # 59543886 E-Filed 07/26/2017 02:20:27 PM
IN THE CIRCUIT COURT OF THE
1174 JUDICIAL CIRCUIT, IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
CASENO.: 17-CA-014511-01
ISABEL LEVINE, as Personal
Representative of the Estate of
JOSE L. CLEMENTE, Deceased,
Plaintiff,
vs.
SENIOR HEALTH - TREASURE
ISLES, LLC. d/b/a TREASURE
ISLE CARE CENTER,
Defendant.
/
PLAINTIFF’S ANSWERS TO DEFENDANT’S FIRST SET OF INTERROGATORIES
COMES NOW the Plaintiff, ISABEL LEVINE, as Personal Representative of the Estate of
JOSE L. CLEMENTE, Deceased, by and through her undersigned counsel, and pursuant to Rule
1.340, Fla.R.Civ.P., hereby files this, her Answers to Defendant, SENIOR HEALTH - TREASURE
ISLES, LLC. d/b/a TREASURE ISLE CARE CENTER, First set of Interrogatories served on July
12, 2017.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the
Florida Courts E-filing Portal: Amy L. Christiansen, Esq.; achristiansen@lawsgr.com; this 26" day
of July, 2017.
FORD, DEAN & ROTUNDO, P.A.
Attorneys for Plaintiff
Turnberry Plaza, Suite 600
2875 N.E. 191 Street
Aventura, FL 33180
Tel: (305) 670-2000
Fax: (305) 670-1353
Bill@forddean.com
Zee@forddean.com
Service@forddean.com
. DEAN, B.C.S.
fo.: 118354
Florida BaPLAINTIFF’S ANSWERS TO DEFENDANT’S FIRST SET OF INTERROGATORIES
Miami VA Hospital
1201 NW 16th St
Miami, FL 33125
Broward General Hospital
1600 S Andrews Ave
Fort Lauderdale, FL 33316
Wilton Manors
2675 N Andrews Ave
Fort Lauderdale, FL 33311
North Beach Rehab
2201 NE 170th St
North Miami Beach, FL 33160
Bay Medical Center
615 N Bonita Ave
Panama City, FL 32401
Fawcett Hospital
21298 Olean Blvd
Port Charlotte, FL 33952
Signature Health Care of Port Charlotte
4033 Beaver Ln
Port Charlotte, FL 33952
Kindred Hospital
18414 Briggs Cir
Port Charlotte, FL 33948
North Dade Nursing and Rehab
1255 NE 135th St
North Miami, FL 33161
Isabel Levine (Sister)
Plaintiff expects these individuals to testify as to Jose Clemente’s overall physical and
medical condition prior to, during and subsequent to his treatment and care with the
Defendants.
Treating physicians of Jose Clemente:
Plaintiff expects treating physicians to testify as to Jose Clemente’s medical condition prior
to, during and subsequent to his care and treatment with the Defendants.
Nurses and other staff employed at Treasure Isles Care Center:6. a-n
10.
ll.
13.
14.
Plaintiff expect the nurses and other staff at Treasure Isles Care Center to have knowledge
concerning Jose Clemente’s condition during his care and treatment with Defendants.
Other healthcare providers of Claimant:
Plaintiff expects these healthcare providers to testify about Jose Clemente’s medical
condition during his treatment and care with Defendants.
AHCA Investigators:
Plaintiff expects these investigators to testify concerning their surveys, inspections and
investigations of Defendant’s facility, as well as the deficiencies and violations noted during
such survey.
Plaintiff reserves the right to supplement this list as informal discovery is still ongoing.
Unknown at this time.
No.
Plaintiff's theory of liability does not reference a single accident or incident, but rather a
pattern of substandard care, treatment and supervision rendered to Jose Clemente during his
residency at the defendant’s facility which included, but is not limited to Jose L. Clemente
suffering falls and unexplained injuries, failure of the facility to create the appropriate
records and follow the applicable charting requirements of an nursing home, failure to create
the appropriate care plans, failure to notify treating physicians and family members of
significant changes in Jose Clemente’s condition.
To date, none.
Clemente, Jose vs. Signature Healthcare
See response to Number 8.
She suffered due to the loss of her brother.
AHCA
To the best of Claimant’s knowledge, Jose Clemente is insured by Medicare #: 109-44-
8826-A. All subrogation liens will be provided to Defense counsel immediately upon receipt.
See response to Number 12.
1250 Taylor Street (Home)
Punta Gorda, FL
Miami VA Hospital
1201 NW 16th St
Miami, FL 3312515.
16.
18.
19.
20.
21.
Wilton Manors
2675 N Andrews Ave
Fort Lauderdale, FL 33311
North Beach Rehab
2201 NE 170th St
North Miami Beach, FL 33160
Bay Medical Center
615 N Bonita Ave
Panama City, FL 32401
Signature Health Care of Port Charlotte
4033 Beaver Ln
Port Charlotte, FL 33952
North Dade Nursing and Rehab
1255 NE 135th St
North Miami, FL 33161
My brother was at Treasure Isle Care Center for one month, I was able to visit him every day
from November 24, 2016 up to December 4, 2016.
My brother was admitted to the following facilities prior to Treasure Isle Care Center:
Signature Health Care of Port Charlotte
4033 Beaver Ln
Port Charlotte, FL 33952
North Dade Nursing and Rehab
1255 NE 135th St
North Miami, FL 33161
See response to Number 16.
Ido not recall any names, but I recall the following staff members:
African-American female nurse, about 6'1" tall, approximately 40-50 years old.
African-American male manager, average heigh, approximately in his 40's.
Yes. Copies of the medical bills and funeral bills are enclosed in the CD being forwarded to
Defense counsel contemporaneously with this responses.
North Beach Rehab
2201 NE 170th St
North Miami Beach, FL 33160
Unknown at this time.22.
23.
24,
See the Defendant’s admission documents which detail all the health conditions the Plaintiff
was suffering from upon admission to the Defendant’s facility.
See response to Number 6.
See response to Number 12.ISABEL LEVINE, on Behalf of
JOSE CLEMENTE, and individually
STATE OF FLORIDA J
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared, (2O@el_¢
who being first duly sworn, deposes and says that the attached Answers to Defendant’s First Set
of Interrogatories to Plaintiff propounded on the \2-_ day of Duy » 2017, are trae
and correct to the best of his/her knowledge, and that he/she read the Answers and knows the
contents thereof.
The foregoing instrument was acknowledged before me this 25 day of why,
2017, by VA BH. CEN NUS : who is personally known to me or who has
produced as identification and who did take an oath.
NOTARY PUBLIC - STATE OF FLORIDA
VPSEECN oy LXE RAO
Print (Notary’s Name)
Notary Stamp: qt
VALERIA D'ALTERIO
Notary Public - State of Florida
Preview
Filing # 59543886 E-Filed 07/26/2017 02:20:27 PM IN THE CIRCUIT COURT OF THE 1174 JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION CASENO.: 17-CA-014511-01 ISABEL LEVINE, as Personal Representative of the Estate of JOSE L. CLEMENTE, Deceased, Plaintiff, vs. SENIOR HEALTH - TREASURE ISLES, LLC. d/b/a TREASURE ISLE CARE CENTER, Defendant. / PLAINTIFF’S ANSWERS TO DEFENDANT’S FIRST SET OF INTERROGATORIES COMES NOW the Plaintiff, ISABEL LEVINE, as Personal Representative of the Estate of JOSE L. CLEMENTE, Deceased, by and through her undersigned counsel, and pursuant to Rule 1.340, Fla.R.Civ.P., hereby files this, her Answers to Defendant, SENIOR HEALTH - TREASURE ISLES, LLC. d/b/a TREASURE ISLE CARE CENTER, First set of Interrogatories served on July 12, 2017. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the Florida Courts E-filing Portal: Amy L. Christiansen, Esq.; achristiansen@lawsgr.com; this 26" day of July, 2017. FORD, DEAN & ROTUNDO, P.A. Attorneys for Plaintiff Turnberry Plaza, Suite 600 2875 N.E. 191 Street Aventura, FL 33180 Tel: (305) 670-2000 Fax: (305) 670-1353 Bill@forddean.com Zee@forddean.com Service@forddean.com . DEAN, B.C.S. fo.: 118354 Florida BaPLAINTIFF’S ANSWERS TO DEFENDANT’S FIRST SET OF INTERROGATORIES Miami VA Hospital 1201 NW 16th St Miami, FL 33125 Broward General Hospital 1600 S Andrews Ave Fort Lauderdale, FL 33316 Wilton Manors 2675 N Andrews Ave Fort Lauderdale, FL 33311 North Beach Rehab 2201 NE 170th St North Miami Beach, FL 33160 Bay Medical Center 615 N Bonita Ave Panama City, FL 32401 Fawcett Hospital 21298 Olean Blvd Port Charlotte, FL 33952 Signature Health Care of Port Charlotte 4033 Beaver Ln Port Charlotte, FL 33952 Kindred Hospital 18414 Briggs Cir Port Charlotte, FL 33948 North Dade Nursing and Rehab 1255 NE 135th St North Miami, FL 33161 Isabel Levine (Sister) Plaintiff expects these individuals to testify as to Jose Clemente’s overall physical and medical condition prior to, during and subsequent to his treatment and care with the Defendants. Treating physicians of Jose Clemente: Plaintiff expects treating physicians to testify as to Jose Clemente’s medical condition prior to, during and subsequent to his care and treatment with the Defendants. Nurses and other staff employed at Treasure Isles Care Center:6. a-n 10. ll. 13. 14. Plaintiff expect the nurses and other staff at Treasure Isles Care Center to have knowledge concerning Jose Clemente’s condition during his care and treatment with Defendants. Other healthcare providers of Claimant: Plaintiff expects these healthcare providers to testify about Jose Clemente’s medical condition during his treatment and care with Defendants. AHCA Investigators: Plaintiff expects these investigators to testify concerning their surveys, inspections and investigations of Defendant’s facility, as well as the deficiencies and violations noted during such survey. Plaintiff reserves the right to supplement this list as informal discovery is still ongoing. Unknown at this time. No. Plaintiff's theory of liability does not reference a single accident or incident, but rather a pattern of substandard care, treatment and supervision rendered to Jose Clemente during his residency at the defendant’s facility which included, but is not limited to Jose L. Clemente suffering falls and unexplained injuries, failure of the facility to create the appropriate records and follow the applicable charting requirements of an nursing home, failure to create the appropriate care plans, failure to notify treating physicians and family members of significant changes in Jose Clemente’s condition. To date, none. Clemente, Jose vs. Signature Healthcare See response to Number 8. She suffered due to the loss of her brother. AHCA To the best of Claimant’s knowledge, Jose Clemente is insured by Medicare #: 109-44- 8826-A. All subrogation liens will be provided to Defense counsel immediately upon receipt. See response to Number 12. 1250 Taylor Street (Home) Punta Gorda, FL Miami VA Hospital 1201 NW 16th St Miami, FL 3312515. 16. 18. 19. 20. 21. Wilton Manors 2675 N Andrews Ave Fort Lauderdale, FL 33311 North Beach Rehab 2201 NE 170th St North Miami Beach, FL 33160 Bay Medical Center 615 N Bonita Ave Panama City, FL 32401 Signature Health Care of Port Charlotte 4033 Beaver Ln Port Charlotte, FL 33952 North Dade Nursing and Rehab 1255 NE 135th St North Miami, FL 33161 My brother was at Treasure Isle Care Center for one month, I was able to visit him every day from November 24, 2016 up to December 4, 2016. My brother was admitted to the following facilities prior to Treasure Isle Care Center: Signature Health Care of Port Charlotte 4033 Beaver Ln Port Charlotte, FL 33952 North Dade Nursing and Rehab 1255 NE 135th St North Miami, FL 33161 See response to Number 16. Ido not recall any names, but I recall the following staff members: African-American female nurse, about 6'1" tall, approximately 40-50 years old. African-American male manager, average heigh, approximately in his 40's. Yes. Copies of the medical bills and funeral bills are enclosed in the CD being forwarded to Defense counsel contemporaneously with this responses. North Beach Rehab 2201 NE 170th St North Miami Beach, FL 33160 Unknown at this time.22. 23. 24, See the Defendant’s admission documents which detail all the health conditions the Plaintiff was suffering from upon admission to the Defendant’s facility. See response to Number 6. See response to Number 12.ISABEL LEVINE, on Behalf of JOSE CLEMENTE, and individually STATE OF FLORIDA J COUNTY OF ) BEFORE ME, the undersigned authority, personally appeared, (2O@el_¢ who being first duly sworn, deposes and says that the attached Answers to Defendant’s First Set of Interrogatories to Plaintiff propounded on the \2-_ day of Duy » 2017, are trae and correct to the best of his/her knowledge, and that he/she read the Answers and knows the contents thereof. The foregoing instrument was acknowledged before me this 25 day of why, 2017, by VA BH. CEN NUS : who is personally known to me or who has produced as identification and who did take an oath. NOTARY PUBLIC - STATE OF FLORIDA VPSEECN oy LXE RAO Print (Notary’s Name) Notary Stamp: qt VALERIA D'ALTERIO Notary Public - State of Florida