On January 20, 2005 a
Trial Materials
was filed
involving a dispute between
Booth, Billy L,
and
Konell, Samuel,
North Shore Med Ctr,
Sanchez, Erick,
Southern Winds Hospital,
Tenet Health System North Shore Inc,
Tenet Healthsystems Med Inc,
Westchester Med Center Inc,
North Care Ltd,
North Shore General Svcs Inc,
North Shore Hosptial & Med Ctr,
North Shore Med Ctr Inc,
North Sore Med Ctr Physician Hospital,
for Other Negligence
in the District Court of Miami-Dade County.
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Filing # 31478495 E-Filed 08/28/2015 11:37:06 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
BILLY L. BOOTH, CASE NO.: 05-1408 CA 06
Plaintiff,
Vv.
TENET HEALTH SYSTEM NORTH SHORE,
INC., d/b/a NORTH SHORE MEDICAL CENTER,
a Delaware corporation; ERICK SANCHEZ,
Defendants.
/
PLAINTIFF BILLY BOOTH’S MOTION TO AMEND EXPERT WITNESS LIST
TO INCLUDE ADDITIONAL EXPERT FOR TRIAL
Plaintiff, BILLY L. BOOTH (‘Plaintiffs’), by and through their undersigned
counsel, files this Motion to amend his expert witness list to include an
additional expert witness, and states:
1. Plaintiff Booth has served his expert witness list!.
2. Defendant North Shore is seeking to plead and show at trial that
an additional Fabre Defendant, the State of Florida / Miami-Dade County /
Miami-Dade County Judiciary should be added based on the Custody Release
Order entered in Sanchez’ criminal case by Judge Israel Reyes?.
3. To contest this Fabre Defendant, and Plaintiff believes it would be
improper to permit Defendant to raise this possible Fabre Defendant, Plaintiff
‘Plaintiff Booth filed a motion for extension of time to serve his Expert Witness
List, however the motion as filed was principally based on the issue of
supplementing one witness and possibly replacing another.
2 Defendant North Shore has a pending request before this Court to amend its
affirmative defenses to name the State of Florida as a Fabre Defendant.
FABRIKANT & HERNANDEZ, P.A
954.966.0881/954.966.0886seeks to call Judge Ellen Leesfield (Ret.) as an expert witness concerning the
Custody Release Order entered in the criminal court case involving Sanchez.
4. This case trial is not set to commence for seven weeks. There is
ample time for North Shore to conduct expert witness discovery. Therefore, no
prejudice will result by the granting of this Motion.
WHEREFORE, the Plaintiff, BILLY L. BOOTH, respectfully requests this
Honorable Court enter an order allowing Booth to amend his expert witness list
to include Judge Ellen Leesfield as an expert witness, and for such further
relief this Court deems proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was
sent this 28th day of April, 2015 via email to Scott Mendlestein, Esq.,
smendlestein@falkwaas.com and via U.S. Mail to Erick Sanchez, 6095 West 19
Avenue, Apt. 304, Hialeah, FL 33014.
RESPECTFULLY SUBMITTED,
Kevin H. Fabrikant, Esq.
Fabrikant & Hernandez, P.A.
1909 Tyler Street
Suite 416
Hollywood, FL 33020
Tel (954) 966-0881
Fax (954) 966-0886
Kevinf@lawfh.com
BY: /s/ Kevin H. Fabrikant
KEVIN H. FABRIKANT, ESQ.
Florida Bar No.: 0170070
FABRIKANT & HERNANDEZ, P.A
954.966.0881/954.966.0886
Document Filed Date
August 28, 2015
Case Filing Date
January 20, 2005
Category
Other Negligence
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Filing # 31478495 E-Filed 08/28/2015 11:37:06 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA BILLY L. BOOTH, CASE NO.: 05-1408 CA 06 Plaintiff, Vv. TENET HEALTH SYSTEM NORTH SHORE, INC., d/b/a NORTH SHORE MEDICAL CENTER, a Delaware corporation; ERICK SANCHEZ, Defendants. / PLAINTIFF BILLY BOOTH’S MOTION TO AMEND EXPERT WITNESS LIST TO INCLUDE ADDITIONAL EXPERT FOR TRIAL Plaintiff, BILLY L. BOOTH (‘Plaintiffs’), by and through their undersigned counsel, files this Motion to amend his expert witness list to include an additional expert witness, and states: 1. Plaintiff Booth has served his expert witness list!. 2. Defendant North Shore is seeking to plead and show at trial that an additional Fabre Defendant, the State of Florida / Miami-Dade County / Miami-Dade County Judiciary should be added based on the Custody Release Order entered in Sanchez’ criminal case by Judge Israel Reyes?. 3. To contest this Fabre Defendant, and Plaintiff believes it would be improper to permit Defendant to raise this possible Fabre Defendant, Plaintiff ‘Plaintiff Booth filed a motion for extension of time to serve his Expert Witness List, however the motion as filed was principally based on the issue of supplementing one witness and possibly replacing another. 2 Defendant North Shore has a pending request before this Court to amend its affirmative defenses to name the State of Florida as a Fabre Defendant. FABRIKANT & HERNANDEZ, P.A 954.966.0881/954.966.0886seeks to call Judge Ellen Leesfield (Ret.) as an expert witness concerning the Custody Release Order entered in the criminal court case involving Sanchez. 4. This case trial is not set to commence for seven weeks. There is ample time for North Shore to conduct expert witness discovery. Therefore, no prejudice will result by the granting of this Motion. WHEREFORE, the Plaintiff, BILLY L. BOOTH, respectfully requests this Honorable Court enter an order allowing Booth to amend his expert witness list to include Judge Ellen Leesfield as an expert witness, and for such further relief this Court deems proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent this 28th day of April, 2015 via email to Scott Mendlestein, Esq., smendlestein@falkwaas.com and via U.S. Mail to Erick Sanchez, 6095 West 19 Avenue, Apt. 304, Hialeah, FL 33014. RESPECTFULLY SUBMITTED, Kevin H. Fabrikant, Esq. Fabrikant & Hernandez, P.A. 1909 Tyler Street Suite 416 Hollywood, FL 33020 Tel (954) 966-0881 Fax (954) 966-0886 Kevinf@lawfh.com BY: /s/ Kevin H. Fabrikant KEVIN H. FABRIKANT, ESQ. Florida Bar No.: 0170070 FABRIKANT & HERNANDEZ, P.A 954.966.0881/954.966.0886