On January 20, 2005 a
Motion,Ex Parte
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.
Preview
Filing # 26316634 E-Filed 04/20/2015 10:08:19 PM
LN 1H CLRCULL COURT UF THE ELEVENTH JUDICIAL CLKUUIT,
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 SUPPLEMENTAL MOTION FOR EXTENSION OF
TIME TO PROVIDE RESPONSES TO DEFENDANT NOTH SHORE’S EXPERT
WITNESS INTERROGATORIES
Plaintiff, BILLY L. BOOTH (“Plaintiffs”), by and through his undersigned
counsel, files this Motion requesting additional time to provide responses to
DEFENDANT’S EXPERT WITNESS INTERROGATORIES and in support thereof
states:
1. Defendant served its expert witness interrogatories on March 4,
2015.
2. Plaintiff continues to work on the answers and responses to the
expert witness interrogatories. However, there are outstanding record and
documents which the parties are currently seeking in discovery which will have
an effect upon the expert witness interrogatory answers.
3. Booth’s counsel has had successive discovery due for other cases
and has been short on time to complete the responses and answers.4. Furthermore, there is an upcoming hearing to specially set the
case for trial which will extend the trial date which will allow more time for
Booth to respond to the expert witness interrogatories.
4. Accordingly, Plaintiff needs additional time to complete the
responses due.
5. This Motion is filed in good faith and without dilatory intent.
WHEREFORE, the Plaintiff, BILLY L. BOOTH, respectfully request this
Honorable Court grant him an extension of time to respond to Defendant’s
Expert Witness Interrogatories, and such further relief this Court deems just.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was
sent this 20th 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.comBY: /s/ Kevin H. Fabrikant
KEVIN H. FABRIKANT, ESQ.
Florida Bar No.: 0170070
Document Filed Date
April 20, 2015
Case Filing Date
January 20, 2005
Category
Other Negligence
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 26316634 E-Filed 04/20/2015 10:08:19 PM LN 1H CLRCULL COURT UF THE ELEVENTH JUDICIAL CLKUUIT, 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 SUPPLEMENTAL MOTION FOR EXTENSION OF TIME TO PROVIDE RESPONSES TO DEFENDANT NOTH SHORE’S EXPERT WITNESS INTERROGATORIES Plaintiff, BILLY L. BOOTH (“Plaintiffs”), by and through his undersigned counsel, files this Motion requesting additional time to provide responses to DEFENDANT’S EXPERT WITNESS INTERROGATORIES and in support thereof states: 1. Defendant served its expert witness interrogatories on March 4, 2015. 2. Plaintiff continues to work on the answers and responses to the expert witness interrogatories. However, there are outstanding record and documents which the parties are currently seeking in discovery which will have an effect upon the expert witness interrogatory answers. 3. Booth’s counsel has had successive discovery due for other cases and has been short on time to complete the responses and answers.4. Furthermore, there is an upcoming hearing to specially set the case for trial which will extend the trial date which will allow more time for Booth to respond to the expert witness interrogatories. 4. Accordingly, Plaintiff needs additional time to complete the responses due. 5. This Motion is filed in good faith and without dilatory intent. WHEREFORE, the Plaintiff, BILLY L. BOOTH, respectfully request this Honorable Court grant him an extension of time to respond to Defendant’s Expert Witness Interrogatories, and such further relief this Court deems just. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent this 20th 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.comBY: /s/ Kevin H. Fabrikant KEVIN H. FABRIKANT, ESQ. Florida Bar No.: 0170070