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Filing # 125197287 E-Filed 04/19/2021 04:54:55 PM
IN THE CIRUCUIT COURT
OF THE EIGHTH JUDICIAL CIRCUIT IN AND
FOR ALACHUA COUNTY, FLORIDA
BRENDA SNOW, CASE NO. 01 2020-CA-001350
Plaintiffs,
v.
SHANDS TEACHING HOSPITAL
AND CLINICS, INC. d/b/a UF
HEALTH SHANDS HOSPITAL, A
Florida Non-Profit Corporation and
UNIVERSITY OF FLORIDA BOARD
OF TRUSTEES d/b/a UF HEALTH
EYE CENTER a Florida Public Body
Corporate,
Defendants.
/
DEFENDANT’S SHANDS TEACHING HOSPITAL AND CLINICS, INC.
ADDITIONAL RESPONSE TO PLAINTIFF’S MOTION TO COMPEL DISCOVERY
RESPONSES
COMES NOW Defendant SHANDS TEACHING HOSPITAL AND CLINICS, INC.,
(Shands), by and through its undersigned counsel, and serves this additional response to
Plaintiff's Motion to Compel Shands Teaching Hospital and Clinics, Inc. d/b/a UF Health
Shands Hospital’s Better Answers to First Set of Interrogatories and Better Responses to First
Request to Produce, and would state as follows:
1. Co-Counsel for Defendant Shands has served a response to Plaintiffs Motion to
Compel dealing with Interrogatories to Defendant Shands, 13, 16, 17 and 18 and
responses to Requests to Produce 14, 15 and 17 and Defendant adopts those
responses.
"2020 CA 001350" 125197287 Filed at Alachua County Clerk 04/19/2021 04:54:58 PM EDT2. Counsel for Plaintiff and Defendant did confer concerning the Requests for
Production and discussed the following requests:
10, Defendant would determine if any table of contents was available. However, the
Medical Staff Bylaws produced in response to Request 12 has the Medical Staff
Rules and Regulations included therein and as such, those have been produced.
13. Defendant would determine if any table of contents was available. What inquiry
has disclosed is that Shands has extensive policies and procedures involving clinical
and non-clinical matters, Therefore, Plaintiffs request is overly broad and does
request information that is not reasonably calculated to lead to the discovery of
admissible evidence.
18. and 21. These documents were produced and the documents produced for Request
18 are responsive to Request 21.
23, These documents have been produced.
24, Defendant has no documents from the Veterans Administration.
3. As to those documents that were not affirmatively dealt with in Counsel’s meet and
confer discussion:
1. These documents were produced as noted in Defendant’s response.
8, These documents are privileged pursuant to §395.0191(8), Fla. Stat. Tarpon Springs
Hospital Foundation Ine. v White, 286 So. 3d 879 (Fla. 24 DCA 2019). Without waiving that
privilege, additional documents were served responding to this request.
9. See objection and case law to response 8 above. Additionally, these documents were
produced by Co-Defendant, Request 9 to Co-Defendant.
20. This response is complete as stated.27. See response to 13, above. Without waiving the prior objection, additional
documents were served responding to this request.
28. There are no documents responsive to this request.
I HEREBY CERTIFY that a true and correct copy hereof was filed with the Florida
Courts E-Filing Portal and that a copy hereof has been furnished by electronic mail this __/ PL
day of APkIK _, 2021 to Andrea A, Lewis, Esquire, Searcy, Denney, Scarola, Barnhart &
Shipley, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, attorney for Plaintiff,
lewisteam@searcylaw.com; alewis@searcylaw.com; mweschrek@searcylaw.com; Rafael E.
Martinez, Esquire, and Wilbert R. Vancol, Esquire, McEwan, Martinez, Dukes & Hall, P.A., 108
E. Central Blvd., Orlando, FL 32801, attorneys for University of Florida Board of Trustees,
sdouglas@carltonfields.com.
Francis E. Pierce, III
Florida Bar No. 0270921
Mateer Harbert, P.A.
225 East Robinson St., Suite 600
Orlando, FL 32801
Ph, 407-425-9044
Facsimile 407-423-2016
litpleadings@mateerharbert.com
Attorneys for SHANDS
4825-6992-0704, v. 2
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Filing # 125197287 E-Filed 04/19/2021 04:54:55 PM IN THE CIRUCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA BRENDA SNOW, CASE NO. 01 2020-CA-001350 Plaintiffs, v. SHANDS TEACHING HOSPITAL AND CLINICS, INC. d/b/a UF HEALTH SHANDS HOSPITAL, A Florida Non-Profit Corporation and UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER a Florida Public Body Corporate, Defendants. / DEFENDANT’S SHANDS TEACHING HOSPITAL AND CLINICS, INC. ADDITIONAL RESPONSE TO PLAINTIFF’S MOTION TO COMPEL DISCOVERY RESPONSES COMES NOW Defendant SHANDS TEACHING HOSPITAL AND CLINICS, INC., (Shands), by and through its undersigned counsel, and serves this additional response to Plaintiff's Motion to Compel Shands Teaching Hospital and Clinics, Inc. d/b/a UF Health Shands Hospital’s Better Answers to First Set of Interrogatories and Better Responses to First Request to Produce, and would state as follows: 1. Co-Counsel for Defendant Shands has served a response to Plaintiffs Motion to Compel dealing with Interrogatories to Defendant Shands, 13, 16, 17 and 18 and responses to Requests to Produce 14, 15 and 17 and Defendant adopts those responses. "2020 CA 001350" 125197287 Filed at Alachua County Clerk 04/19/2021 04:54:58 PM EDT2. Counsel for Plaintiff and Defendant did confer concerning the Requests for Production and discussed the following requests: 10, Defendant would determine if any table of contents was available. However, the Medical Staff Bylaws produced in response to Request 12 has the Medical Staff Rules and Regulations included therein and as such, those have been produced. 13. Defendant would determine if any table of contents was available. What inquiry has disclosed is that Shands has extensive policies and procedures involving clinical and non-clinical matters, Therefore, Plaintiffs request is overly broad and does request information that is not reasonably calculated to lead to the discovery of admissible evidence. 18. and 21. These documents were produced and the documents produced for Request 18 are responsive to Request 21. 23, These documents have been produced. 24, Defendant has no documents from the Veterans Administration. 3. As to those documents that were not affirmatively dealt with in Counsel’s meet and confer discussion: 1. These documents were produced as noted in Defendant’s response. 8, These documents are privileged pursuant to §395.0191(8), Fla. Stat. Tarpon Springs Hospital Foundation Ine. v White, 286 So. 3d 879 (Fla. 24 DCA 2019). Without waiving that privilege, additional documents were served responding to this request. 9. See objection and case law to response 8 above. Additionally, these documents were produced by Co-Defendant, Request 9 to Co-Defendant. 20. This response is complete as stated.27. See response to 13, above. Without waiving the prior objection, additional documents were served responding to this request. 28. There are no documents responsive to this request. I HEREBY CERTIFY that a true and correct copy hereof was filed with the Florida Courts E-Filing Portal and that a copy hereof has been furnished by electronic mail this __/ PL day of APkIK _, 2021 to Andrea A, Lewis, Esquire, Searcy, Denney, Scarola, Barnhart & Shipley, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, attorney for Plaintiff, lewisteam@searcylaw.com; alewis@searcylaw.com; mweschrek@searcylaw.com; Rafael E. Martinez, Esquire, and Wilbert R. Vancol, Esquire, McEwan, Martinez, Dukes & Hall, P.A., 108 E. Central Blvd., Orlando, FL 32801, attorneys for University of Florida Board of Trustees, sdouglas@carltonfields.com. Francis E. Pierce, III Florida Bar No. 0270921 Mateer Harbert, P.A. 225 East Robinson St., Suite 600 Orlando, FL 32801 Ph, 407-425-9044 Facsimile 407-423-2016 litpleadings@mateerharbert.com Attorneys for SHANDS 4825-6992-0704, v. 2