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Filing # 123517752 E-Filed 03/22/2021 02:20:47 PM
IN THE CIRCUIT COURT OF THE EIGHTH
JUDICIAL CIRCUIT IN AND FOR
ALACHUA COUNTY, FLORIDA.
CASE NO: 2020CA001350XXXXXX
BRENDA SNOW,
Plaintiff(s),
vs.
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,
Defendant(s).
a
NOTICE OF TAKING VIDEO DEPOSITION - DUCES TECUM* - VIA ZOOM
TO: All counsel on the attached Counsel List
PLEASE TAKE NOTICE that the undersigned attorneys will take the Duces Tecum
deposition(s) of:
NAME AND ADDRESS DATE AND TIME LOCATION
Philip Ames, M.D. July 8, 2021 *VIA ZOOM
c/o Wilbert Vancol, Esquire at 10:30 a.m. LINK PROVIDED BY
ABOVE AND BEYOND
REPROGRAPHICS
(561-478-4774)
*ZOOM INFORMATION TO BE PROVIDED BY ABOVE AND BEYOND
*DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF THE
DEPOSITION THE FOLLOWING:
"2020 CA 001350" 123517752 Filed at Alachua County Clerk 03/22/2021 02:20:51 PM EDTSnow, Brenda vs. University of Florida Board of Trustees, et al.
Case No.: 2020CA001350 XXXXXX
Notice of Taking VideoDeposition - Duces Tecum
Page 2
To bring and then and there produce all records, x-rays, reports, copies of
reports from consulting physicians, clinical records, patient cards,
memoranda, the medical record folder or jacket inside and out and all other
information concerning the physical examinations of, treatment of, and
consultations with the above referenced Plaintiff AND any and all materials
which you have reviewed in preparation for your testimony. If you have a
paperless chart within your computer system, please print out the entire chart
including billing records so that it is available for inspection/marking at your
deposition.
upon oral examination before Florida Court Reporting Co., Inc., a Notary Public; or any other
officer authorized by law to take depositions in the State of Florida. The oral examination is being
taken for the purpose of discovery, for uses at trial, or for such other purposes as are permitted
under the applicable Statutes or Rules.
*"Documents" shall include, but not be limited to all non-identical copies of writings,
drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data
compilations from which information can be obtained, translated, if necessary, by the party to
whom the request is directed through detection devices into reasonably usable form. “Documents”
also include all electronic data as well as application metadata and system metadata. All
inventories and rosters of your information technology (IT) systems—e.g., hardware, software and
data, including but not limited to network drawings, lists of computing devices (servers, PCs,
laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps
and security tools and protocols.
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
to all Counsel on the attached list, this 22nd day of March, 2021.Snow, Brenda vs. University of Florida Board of Trustees, et al.
Case No.: 2020CA001350 XXXXXX
Notice of Taking VideoDeposition - Duces Tecum
Page 3
4s/Andrea A, Lewis
Andrea A. Lewis, Esquire
Florida Bar No.: 85331
Attorney E-Mail: alweis@searcylaw.com
Primary E-Mail: lewisteam@searcylaw.com
Secondary E-Mail: mweschrek@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9441
Attorney for Plaintiff
ce: Scheduling@floridacourtreporting.com
css@aboveandbeyondrepro.com
COUNSEL LIST
Andrea A. Lewis, Esq.
Florida Bar No.: 85331
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
Phone: (561) 686-6300
Fax: (561) 383-9441
Primary E-Mail: lewisteam@searcylaw.com
Attorney Email: alewis@searcylaw.com
Secondary Email: mweschrek@searcylaw.com
Attorney for Plaintiff, BRENDA SNOW
Francis E. Pierce, Esq.
Florida Bar No.: 0270921
Mateer Harbert, P.A.
225 East Robinson Street, Suite 600
Orlando, FL 32801
Phone: (407)425-9044
Fax: (407)425-9044
Primary Email: litpleadings@mateerharbert.com
Secondary Email: mdavis@mateerharbert.com
Secondary Email: ckozimor@mateerharbert.com
Attorneys for SHANDS TEACHING HOSPITAL AND CLINICS, INC.Snow, Brenda vs. University of Florida Board of Trustees, et al.
Case No.: 2020CA001350 XXXXXX
Notice of Taking VideoDeposition - Duces Tecum
Page 4
Rafael E. Martinez, Esq.
Florida Bar No. 0243248
Wilbert R. Vancol. Esq.
Florida Bar No. 0093132
McEwan, Martinez, Dukes & Hall, P.A.
Post Office Box 753
Orlando, FL 32802-0753
Phone: (407)423-8571
Fax: (407)423-8637
Primary Email: NOS@mmdorl.com
Primary Email: wvancol@mmdorl.com
Primary Email: mearter@mmdorl.com
Attorney Email: rmartinez@mmdorl.com
Secondary Email: glichtenberger@mmdorl.com
Secondary Email: _dmcalpin@mmdorl.com
Attorneys for Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF
HEALTH EYE CENTER, a Florida Public Body Corporate
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Filing # 123517752 E-Filed 03/22/2021 02:20:47 PM IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA. CASE NO: 2020CA001350XXXXXX BRENDA SNOW, Plaintiff(s), vs. 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, Defendant(s). a NOTICE OF TAKING VIDEO DEPOSITION - DUCES TECUM* - VIA ZOOM TO: All counsel on the attached Counsel List PLEASE TAKE NOTICE that the undersigned attorneys will take the Duces Tecum deposition(s) of: NAME AND ADDRESS DATE AND TIME LOCATION Philip Ames, M.D. July 8, 2021 *VIA ZOOM c/o Wilbert Vancol, Esquire at 10:30 a.m. LINK PROVIDED BY ABOVE AND BEYOND REPROGRAPHICS (561-478-4774) *ZOOM INFORMATION TO BE PROVIDED BY ABOVE AND BEYOND *DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF THE DEPOSITION THE FOLLOWING: "2020 CA 001350" 123517752 Filed at Alachua County Clerk 03/22/2021 02:20:51 PM EDTSnow, Brenda vs. University of Florida Board of Trustees, et al. Case No.: 2020CA001350 XXXXXX Notice of Taking VideoDeposition - Duces Tecum Page 2 To bring and then and there produce all records, x-rays, reports, copies of reports from consulting physicians, clinical records, patient cards, memoranda, the medical record folder or jacket inside and out and all other information concerning the physical examinations of, treatment of, and consultations with the above referenced Plaintiff AND any and all materials which you have reviewed in preparation for your testimony. If you have a paperless chart within your computer system, please print out the entire chart including billing records so that it is available for inspection/marking at your deposition. upon oral examination before Florida Court Reporting Co., Inc., a Notary Public; or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for uses at trial, or for such other purposes as are permitted under the applicable Statutes or Rules. *"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. “Documents” also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems—e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools and protocols. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 22nd day of March, 2021.Snow, Brenda vs. University of Florida Board of Trustees, et al. Case No.: 2020CA001350 XXXXXX Notice of Taking VideoDeposition - Duces Tecum Page 3 4s/Andrea A, Lewis Andrea A. Lewis, Esquire Florida Bar No.: 85331 Attorney E-Mail: alweis@searcylaw.com Primary E-Mail: lewisteam@searcylaw.com Secondary E-Mail: mweschrek@searcylaw.com Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9441 Attorney for Plaintiff ce: Scheduling@floridacourtreporting.com css@aboveandbeyondrepro.com COUNSEL LIST Andrea A. Lewis, Esq. Florida Bar No.: 85331 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: (561) 686-6300 Fax: (561) 383-9441 Primary E-Mail: lewisteam@searcylaw.com Attorney Email: alewis@searcylaw.com Secondary Email: mweschrek@searcylaw.com Attorney for Plaintiff, BRENDA SNOW Francis E. Pierce, Esq. Florida Bar No.: 0270921 Mateer Harbert, P.A. 225 East Robinson Street, Suite 600 Orlando, FL 32801 Phone: (407)425-9044 Fax: (407)425-9044 Primary Email: litpleadings@mateerharbert.com Secondary Email: mdavis@mateerharbert.com Secondary Email: ckozimor@mateerharbert.com Attorneys for SHANDS TEACHING HOSPITAL AND CLINICS, INC.Snow, Brenda vs. University of Florida Board of Trustees, et al. Case No.: 2020CA001350 XXXXXX Notice of Taking VideoDeposition - Duces Tecum Page 4 Rafael E. Martinez, Esq. Florida Bar No. 0243248 Wilbert R. Vancol. Esq. Florida Bar No. 0093132 McEwan, Martinez, Dukes & Hall, P.A. Post Office Box 753 Orlando, FL 32802-0753 Phone: (407)423-8571 Fax: (407)423-8637 Primary Email: NOS@mmdorl.com Primary Email: wvancol@mmdorl.com Primary Email: mearter@mmdorl.com Attorney Email: rmartinez@mmdorl.com Secondary Email: glichtenberger@mmdorl.com Secondary Email: _dmcalpin@mmdorl.com Attorneys for Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate