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Filing # 116734651 E-Filed 11/16/2020 03:32:32 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).
/
PLAINTIFF'S RESPONSE TO UNIVERSITY OF FLORIDA BOARD OF TRUSTEES
D/B/A UF HEALTH EYE CENTER'S REQUEST TO PRODUCE
COMES NOW Plaintiff, BRENDA SNOW, by and through undersigned counsel, and
hereby files her Response to Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES
d/b/a UF HEALTH EYE CENTER's Request to Produce, dated October 16, 2020, and states as
follows:
1. Birth certificate of the Plaintiff.
RESPONSE: Will provide upon receipt. See answers to interrogatories. My birth
certificate is at home. I am currently not residing at my home due to my daughter being a
nurse/essential worker and COVID epidemic.
2. All marriage licenses and divorce decrees pertaining to the Plaintiff, if applicable.
RESPONSE: Not in Plaintiff's possession.
3. If the plaintiff is making a loss of earnings claim or loss of income earning capacity
claim, please produce copies of the Plaintiff's tax returns, whether joint or, single returns, during
"2020 CA 001350" 116734651 Filed at Alachua County Clerk 11/16/2020 03:32:38 PM ESTthe past six (6) years. This includes both personal and corporate tax returns of corporations or
businesses in which the Plaintiff had a financial interest.
RESPONSE: Not applicable - no lost wage claim.
4. Copies of cover sheets of any and all health insurance policies in effect during the
past ten years, which covered the Plaintiff.
RESPONSE: Copy of health insurance card attached, otherwise none in Plaintiff's
possession.
5. Copies of all photographs of the plaintiff taken during her treatment by this
Defendant, ifthe area of complaint or part of the body which is the subject of this claim is depicted.
RESPONSE: Photos in the Plaintiff’s possession are attached. Also see medical
records.
6. Copies of any photographs taken by the plaintiff or on the plaintiff's behalf for
purposes of depicting the post diagnosis and post treatment condition or subject of any failure to
diagnose or delayed diagnosis or disfigurement associated allegedly with the Defendant’s
treatment.
RESPONSE: Attached. Also see medical records.
7. Any and all videotapes that have been taken of the plaintiff, which are pertinent to
the treatment being sued upon.
RESPONSE: To Plaintiff's knowledge, the procedure/treatment was not video
recorded.
8. Medical records of the Plaintiff for the past ten (10) years.
RESPONSE: Records in Plaintiff’s possession are attached.9. All medical bills and statements, including, but not limited to, statements of
physicians, hospitals, and other institutions or individuals providing care and treatment to the
Plaintiff for the past ten years showing the amounts paid and billed alike. If the plaintiff is a
Medicaid or Medicare recipient, a signed authorization, which is attached hereto, for production
of a payout listing identifying any providers paid, is to be provided.
RESPONSE: Objection, relevance, overly burdensome, overbroad in time and scope,
not reasonably calculated to lead to the discovery of admissible evidence.
10. Medical records of the Plaintiff from the time of this Defendant’s treatment until
the present, which you contend tend to prove any negligence on the part of this Defendant.
RESPONSE: Records in Plaintiff’s possession are attached.
ll. All medical bills and statements, including, but not limited to, statements of
physicians, hospitals, and other institutions or individuals providing care and treatment to the
Plaintiff from the date of the Defendant’s treatment at issue until the present, which you intend to
claim as economic damages, which show the amounts actually paid and billed as well as any
collateral source payments and the extent of any health insurers’ liens.
RESPONSE: Records in Plaintiffs possession are attached.
12. All statements made by this Defendant, his agents or employees, that are in
possession of the Plaintiff, or Plaintiff's attorneys, or Plaintiffs agents, regarding the treatment
complained of or in any way relating to the issues raised by the Complaint and the responses
thereto.
RESPONSE: See medical records.
13. All statements made by any Defendant, his agents or employees, that are in
possession of the Plaintiff, or Plaintiffs attorneys, or Plaintiff's agents, regarding the treatmentcomplained of or in any way relating to the issues raised by the Complaint and the responses
thereto.
RESPONSE: None in Plaintiff's possession other than medical records.
14. All statements made by any individual, including former employees, of any
Defendant, that are in possession of the Plaintiff, or Plaintiffs attorneys, or Plaintiffs agents,
regarding the treatment complained of or in any way relating to the issues raised by the Complaint
and the responses thereto.
RESPONSE: None in Plaintiff's possession other than medical records.
15. Copies of all educational and professional degrees, diplomas or certificates of
achievement or competency of the Plaintiff if a wage loss or economic claim is being pursued.
RESPONSE: Not applicable - no lost wage claim.
16. Certificates of title for all property, real or personal that was in the name of the
Plaintiff either individually or with others.
RESPONSE: Objection - relevance.
17. All documents in possession of the Plaintiff, the Plaintiff's agents, which support
the allegation that any other Defendant was in any way negligent and that negligence resulted in
injury or damage to the Plaintiff.
RESPONSE: Medical records and photographs attached.
18. Copies of any and all notices of intent to collect damages from the tort-feasor
directed towards any provider of collateral source payments pursuant to Florida Statute §
768.76(6). Please also include proof that the notice was sent by certified or registered mail.
RESPONSE: Copy of updated lien and letter from Medicare attached.19. Copies of any statements from providers of collateral source payments which assert
a right to subrogation or reimbursement pursuant to Florida Statute § 768.76(7).
RESPONSE: Copy of updated lien and letter from Medicare attached.
20. Copies of any correspondence written to anyone, other than this Defendant,
constituting notices of intent or referencing the Plaintiff's belief that the recipient of such
correspondence is or may be liable for all or some of the damages being claimed against this
Defendant.
RESPONSE: Objection: Vague, overbroad in time and scope. The Notice of Intent
was sent to UFBOT and UF Health Shands.
21. Copies of any journal, diary, or notes generated by or maintained by Plaintiff
concerning any discussion, doctor's visit, treatment or procedure which in any way discusses or
impacts upon the Defendant’s treatment, the alleged liability of this Defendant or any issue related
to the claims made in this lawsuit.
RESPONSE: I have not created any journals, diaries, timelines or notes, etc.
22. Copies of any papers served upon the Plaintiff in this cause by other Defendants
and not referenced as having been served upon this Defendant through his undersigned counsel.
RESPONSE: I am not sure what you are referring to specifically, but to the best of
my knowledge — none.
23. Copies of any other documents not otherwise produced which describe the basis
and reason for any damages being claimed by the Plaintiff in this cause.
RESPONSE: Objection: Vague, overbroad in time and scope, calls for work product
and attorney-client privilege information.24. Copies of any records concerning any petitions for injunctive relief involving the
Plaintiff and spouse or any other records of a domestic relations nature concerning any of the
relationships or legal obligations towards one another, including, but not limited to, dissolution
petitions or the like; paternity proceedings; child support proceedings; adoption proceedings;
separations etc.
RESPONSE: None.
25. Copies of all medical reports received by the Plaintiff(s), Plaintiff(s)' attorneys,
investigators, agents, servants, or employees, from doctors, physicians or anyone else who has
rendered treatment to the Plaintiff(s), for injuries incurred as a result of the accident or incident
which is the subject matter of this lawsuit.
RESPONSE: All records attached.
26. Copies of all medical reports received by the Plaintiff(s), Plaintiff(s)' attorneys,
investigators, agents, servants, or employees, from any doctor, physician, or member of the healing
arts who has examined the Plaintiff(s)'s physical or mental condition subsequent to the accident or
incident which is the subject matter of this lawsuit.
RESPONSE: Objection: Vague, over broad in time and scope, calls for information
that is protected by privilege, including attorney-client, work product and presuit/mediation
privilege.
27. All documents reflecting payments made to Plaintiff(s) or on their behalf, as a result
of the incident and/or damages that are the subject of this case by the following:
a. The United States Social Security Act; any Federal State or local Disability Act;
any other public programs providing medical benefits or payment for medical expenses, disability,
or other similar benefits.RESPONSE: None.
b. Any health, sickness or disability income insurance or other similar insurance
benefits.
RESPONSE: Attached.
c. Any contract or agreements of any group, organization, partnership or corporation
to provide, pay or reimburse costs of hospital, medical or other health care services.
RESPONSE: None.
d. Any contractual or voluntary wage continuation plan provided by any employers
of the Plaintiff(s) or any other system intended to provide wages during any period of alleged
disability of the Plaintiff(s).
RESPONSE: None.
e. Any other collateral source whatsoever providing compensation as a result of the
damages incurred as a result of the incident or incidents which are the subject of this claim.
RESPONSE: None.
28. The complete reports of all governmental agencies who may have investigated the
allegations made in this lawsuit.
RESPONSE: Plaintiff has attached everything in her possession. Plaintiff provided
notice to the state as required by statute, but Plaintiff does not know what steps the state has
taken. Further, the Defendants have refused to produce any and all documents related to its
investigation, incident reports, etc. Discovery ongoing.
29. Copies of all reports received from experts Plaintiff(s) intend to call at trial to testify
and copies of all documents the experts have reviewed in preparation for rendering any opinions
in this case.RESPONSE: Undetermined at this time. Discovery ongoing. Will provide pursuant
to Pretrial Order.
30. Copies of all documents which the experts have reviewed in arriving at their
opinions in this case. (This request only relates to experts Plaintiff(s) intend to call at trial to
testify.)
RESPONSE: Undetermined at this time. Discovery ongoing. Will provide pursuant
to Pretrial Order.
31. All other documents in the possession or control of the Plaintiff(s) which support
the Plaintiff(s)' claims that the Defendants are liable for the damages being claimed in this case.
RESPONSE: Objection: Overbroad in time and scope, vague and potentially calls for
privileged information. See #26. Medical records have been provided. Discovery ongoing.
32. Any and all documents upon which Plaintiff relies in support of Plaintiffs claim
for damages or liability, and which have not been produced pursuant to other requests specifically
enumerated above.
RESPONSE: See #31. Medical records and photographs attached. Discovery
ongoing.
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 16th day of November, 2020.
4s/Andrea Lewis
Andrea A. Lewis, Esq.
Florida Bar No.: 85331
Attorney E-Mail: alewis@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, FL 33409
Phone: 561-686-6300Fax: 561-383-9402
Attorney for Plaintiff(s)
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@searcvlaw.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.
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: wyancol@mmdorl.com
Primary Email: mearter@mmdorl.com
Attorney Email: rmartinez@mmdorl.com
Secondary Email: aguzman@mmdorl.com
Secondary Email: glichtenberger@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 # 116734651 E-Filed 11/16/2020 03:32:32 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). / PLAINTIFF'S RESPONSE TO UNIVERSITY OF FLORIDA BOARD OF TRUSTEES D/B/A UF HEALTH EYE CENTER'S REQUEST TO PRODUCE COMES NOW Plaintiff, BRENDA SNOW, by and through undersigned counsel, and hereby files her Response to Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER's Request to Produce, dated October 16, 2020, and states as follows: 1. Birth certificate of the Plaintiff. RESPONSE: Will provide upon receipt. See answers to interrogatories. My birth certificate is at home. I am currently not residing at my home due to my daughter being a nurse/essential worker and COVID epidemic. 2. All marriage licenses and divorce decrees pertaining to the Plaintiff, if applicable. RESPONSE: Not in Plaintiff's possession. 3. If the plaintiff is making a loss of earnings claim or loss of income earning capacity claim, please produce copies of the Plaintiff's tax returns, whether joint or, single returns, during "2020 CA 001350" 116734651 Filed at Alachua County Clerk 11/16/2020 03:32:38 PM ESTthe past six (6) years. This includes both personal and corporate tax returns of corporations or businesses in which the Plaintiff had a financial interest. RESPONSE: Not applicable - no lost wage claim. 4. Copies of cover sheets of any and all health insurance policies in effect during the past ten years, which covered the Plaintiff. RESPONSE: Copy of health insurance card attached, otherwise none in Plaintiff's possession. 5. Copies of all photographs of the plaintiff taken during her treatment by this Defendant, ifthe area of complaint or part of the body which is the subject of this claim is depicted. RESPONSE: Photos in the Plaintiff’s possession are attached. Also see medical records. 6. Copies of any photographs taken by the plaintiff or on the plaintiff's behalf for purposes of depicting the post diagnosis and post treatment condition or subject of any failure to diagnose or delayed diagnosis or disfigurement associated allegedly with the Defendant’s treatment. RESPONSE: Attached. Also see medical records. 7. Any and all videotapes that have been taken of the plaintiff, which are pertinent to the treatment being sued upon. RESPONSE: To Plaintiff's knowledge, the procedure/treatment was not video recorded. 8. Medical records of the Plaintiff for the past ten (10) years. RESPONSE: Records in Plaintiff’s possession are attached.9. All medical bills and statements, including, but not limited to, statements of physicians, hospitals, and other institutions or individuals providing care and treatment to the Plaintiff for the past ten years showing the amounts paid and billed alike. If the plaintiff is a Medicaid or Medicare recipient, a signed authorization, which is attached hereto, for production of a payout listing identifying any providers paid, is to be provided. RESPONSE: Objection, relevance, overly burdensome, overbroad in time and scope, not reasonably calculated to lead to the discovery of admissible evidence. 10. Medical records of the Plaintiff from the time of this Defendant’s treatment until the present, which you contend tend to prove any negligence on the part of this Defendant. RESPONSE: Records in Plaintiff’s possession are attached. ll. All medical bills and statements, including, but not limited to, statements of physicians, hospitals, and other institutions or individuals providing care and treatment to the Plaintiff from the date of the Defendant’s treatment at issue until the present, which you intend to claim as economic damages, which show the amounts actually paid and billed as well as any collateral source payments and the extent of any health insurers’ liens. RESPONSE: Records in Plaintiffs possession are attached. 12. All statements made by this Defendant, his agents or employees, that are in possession of the Plaintiff, or Plaintiff's attorneys, or Plaintiffs agents, regarding the treatment complained of or in any way relating to the issues raised by the Complaint and the responses thereto. RESPONSE: See medical records. 13. All statements made by any Defendant, his agents or employees, that are in possession of the Plaintiff, or Plaintiffs attorneys, or Plaintiff's agents, regarding the treatmentcomplained of or in any way relating to the issues raised by the Complaint and the responses thereto. RESPONSE: None in Plaintiff's possession other than medical records. 14. All statements made by any individual, including former employees, of any Defendant, that are in possession of the Plaintiff, or Plaintiffs attorneys, or Plaintiffs agents, regarding the treatment complained of or in any way relating to the issues raised by the Complaint and the responses thereto. RESPONSE: None in Plaintiff's possession other than medical records. 15. Copies of all educational and professional degrees, diplomas or certificates of achievement or competency of the Plaintiff if a wage loss or economic claim is being pursued. RESPONSE: Not applicable - no lost wage claim. 16. Certificates of title for all property, real or personal that was in the name of the Plaintiff either individually or with others. RESPONSE: Objection - relevance. 17. All documents in possession of the Plaintiff, the Plaintiff's agents, which support the allegation that any other Defendant was in any way negligent and that negligence resulted in injury or damage to the Plaintiff. RESPONSE: Medical records and photographs attached. 18. Copies of any and all notices of intent to collect damages from the tort-feasor directed towards any provider of collateral source payments pursuant to Florida Statute § 768.76(6). Please also include proof that the notice was sent by certified or registered mail. RESPONSE: Copy of updated lien and letter from Medicare attached.19. Copies of any statements from providers of collateral source payments which assert a right to subrogation or reimbursement pursuant to Florida Statute § 768.76(7). RESPONSE: Copy of updated lien and letter from Medicare attached. 20. Copies of any correspondence written to anyone, other than this Defendant, constituting notices of intent or referencing the Plaintiff's belief that the recipient of such correspondence is or may be liable for all or some of the damages being claimed against this Defendant. RESPONSE: Objection: Vague, overbroad in time and scope. The Notice of Intent was sent to UFBOT and UF Health Shands. 21. Copies of any journal, diary, or notes generated by or maintained by Plaintiff concerning any discussion, doctor's visit, treatment or procedure which in any way discusses or impacts upon the Defendant’s treatment, the alleged liability of this Defendant or any issue related to the claims made in this lawsuit. RESPONSE: I have not created any journals, diaries, timelines or notes, etc. 22. Copies of any papers served upon the Plaintiff in this cause by other Defendants and not referenced as having been served upon this Defendant through his undersigned counsel. RESPONSE: I am not sure what you are referring to specifically, but to the best of my knowledge — none. 23. Copies of any other documents not otherwise produced which describe the basis and reason for any damages being claimed by the Plaintiff in this cause. RESPONSE: Objection: Vague, overbroad in time and scope, calls for work product and attorney-client privilege information.24. Copies of any records concerning any petitions for injunctive relief involving the Plaintiff and spouse or any other records of a domestic relations nature concerning any of the relationships or legal obligations towards one another, including, but not limited to, dissolution petitions or the like; paternity proceedings; child support proceedings; adoption proceedings; separations etc. RESPONSE: None. 25. Copies of all medical reports received by the Plaintiff(s), Plaintiff(s)' attorneys, investigators, agents, servants, or employees, from doctors, physicians or anyone else who has rendered treatment to the Plaintiff(s), for injuries incurred as a result of the accident or incident which is the subject matter of this lawsuit. RESPONSE: All records attached. 26. Copies of all medical reports received by the Plaintiff(s), Plaintiff(s)' attorneys, investigators, agents, servants, or employees, from any doctor, physician, or member of the healing arts who has examined the Plaintiff(s)'s physical or mental condition subsequent to the accident or incident which is the subject matter of this lawsuit. RESPONSE: Objection: Vague, over broad in time and scope, calls for information that is protected by privilege, including attorney-client, work product and presuit/mediation privilege. 27. All documents reflecting payments made to Plaintiff(s) or on their behalf, as a result of the incident and/or damages that are the subject of this case by the following: a. The United States Social Security Act; any Federal State or local Disability Act; any other public programs providing medical benefits or payment for medical expenses, disability, or other similar benefits.RESPONSE: None. b. Any health, sickness or disability income insurance or other similar insurance benefits. RESPONSE: Attached. c. Any contract or agreements of any group, organization, partnership or corporation to provide, pay or reimburse costs of hospital, medical or other health care services. RESPONSE: None. d. Any contractual or voluntary wage continuation plan provided by any employers of the Plaintiff(s) or any other system intended to provide wages during any period of alleged disability of the Plaintiff(s). RESPONSE: None. e. Any other collateral source whatsoever providing compensation as a result of the damages incurred as a result of the incident or incidents which are the subject of this claim. RESPONSE: None. 28. The complete reports of all governmental agencies who may have investigated the allegations made in this lawsuit. RESPONSE: Plaintiff has attached everything in her possession. Plaintiff provided notice to the state as required by statute, but Plaintiff does not know what steps the state has taken. Further, the Defendants have refused to produce any and all documents related to its investigation, incident reports, etc. Discovery ongoing. 29. Copies of all reports received from experts Plaintiff(s) intend to call at trial to testify and copies of all documents the experts have reviewed in preparation for rendering any opinions in this case.RESPONSE: Undetermined at this time. Discovery ongoing. Will provide pursuant to Pretrial Order. 30. Copies of all documents which the experts have reviewed in arriving at their opinions in this case. (This request only relates to experts Plaintiff(s) intend to call at trial to testify.) RESPONSE: Undetermined at this time. Discovery ongoing. Will provide pursuant to Pretrial Order. 31. All other documents in the possession or control of the Plaintiff(s) which support the Plaintiff(s)' claims that the Defendants are liable for the damages being claimed in this case. RESPONSE: Objection: Overbroad in time and scope, vague and potentially calls for privileged information. See #26. Medical records have been provided. Discovery ongoing. 32. Any and all documents upon which Plaintiff relies in support of Plaintiffs claim for damages or liability, and which have not been produced pursuant to other requests specifically enumerated above. RESPONSE: See #31. Medical records and photographs attached. Discovery ongoing. 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 16th day of November, 2020. 4s/Andrea Lewis Andrea A. Lewis, Esq. Florida Bar No.: 85331 Attorney E-Mail: alewis@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, FL 33409 Phone: 561-686-6300Fax: 561-383-9402 Attorney for Plaintiff(s) 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@searcvlaw.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. 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: wyancol@mmdorl.com Primary Email: mearter@mmdorl.com Attorney Email: rmartinez@mmdorl.com Secondary Email: aguzman@mmdorl.com Secondary Email: glichtenberger@mmdorl.com Attorneys for Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate