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Filing # 120714747 E-Filed 02/03/2021 08:39:08 AM
2010-041
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR
ALACHUA COUNTY, FLORIDA
BRENDA SNOW,
Plaintiff(s),
vs. CASE NO.: 01 2020 CA 001350
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).
/
DEFENDANT'S MOTION TO COMPEL
DEPOSITION OF JOHN W. SHORE, M.D.
COMES NOW Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES
d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate, by and through the
undersigned attorneys, and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure
and section 766.206, Florida Statutes, files this Motion to Compel the deposition of John W.
Shore, M.D., and in support thereof states:
1, This is a medical malpractice action in which Plaintiffs allege negligence in
care and treatment of Brenda Snow.
2. On August 26, 2020, Defendant moved to dismiss Plaintiff's Amended
Complaint on multiple grounds including Plaintiff’s failure to comply with the presuit
screening requirement of Chapter 766. In particular, Defendants alleged that Plaintiff's
presuit expert, Dr. Shore, was not competent under 766.102(7), Florida Statutes, to give
expert testimony on the appropriate standard of care as to administrative and other
nonclinical issues. Based upon this contention, Defendant moved to dismiss Count II of
"2020 CA 001350" 120714747 Filed at Alachua County Clerk 02/03/2021 08:39:12 AM ESTCase No.: 01 2020 CA 001350
Plaintiffs Amended Complaint. Count III asserts a claim for negligence based upon
Defendant’s non-compliance with Section 766.110, Florida Statutes.
3. A hearing on Defendant’s Motion to Dismiss Plaintiff's Amended
Complaint was heard by the Court on October 15, 2020.
4, On December 10, 2020, this Court issued its Order on Defendant’s Motion
to Dismiss. The Court denied the motion in part and reserved ruling on the arguments
related to Dr. Shore’s qualifications. Additionally, the Court ordered an evidentiary
hearing to address the issue. The evidentiary hearing is scheduled for February 23, 2021.
5. Defendant has made multiple requests for the deposition of Dr. Shore.
Exhibit A, Exhibit B and Exhibit C. The deposition is necessary to determine Dr.
Shore’s experience and qualifications on the issues raised in Defendant’s Motion to
Dismiss and on the issues to be addressed during the evidentiary hearing. To date,
Plaintiff has failed to provide any dates of availability for Dr. Shore.
6. The deposition is necessary for Defendant to properly prepare for the
evidentiary hearing scheduled by the Court for February 23, 2021.
WHEREFORE, Defendant respectfully request this Court enter an order
compelling Plaintiff to provide dates for the deposition of Dr. Shore to address issues
related to his qualifications.
CERTIFICATE OF SERVICE
I hereby certify that on this 3% day of February, 2021, a true and correct copy of
the foregoing has been electronically filed with the Clerk of the Court by using the
Florida Courts E-Filing Portal, and furnished via email to the following: Andrea A.
Lewis, Esquire, SEARCY DENNEY SCAROLA BARNHART & SHIPLEY P.A., 2139
Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Francis E. Pierce, III,
Esquire, MATEER HARBERT, P.A., 225 East Robinson Street, Suite 600, Orlando, FL
32801; at the following email addresses:
alewis@searcylaw.com;
lewisteam@searcylaw.com;
mweschrek@searcylaw.com;litpleadings@mateerharbert.com
Case No.: 01 2020 CA 001350
/s/ Wilbert R. Vancol
Rafael E. Martinez
Florida Bar No.: 0243248
rmartinez@mmdorl.com
Wilbert R. Vancol
Florida Bar No.: 0093132
wvancol@mmdorl.com
McEwan, Martinez, Dukes & Hall, P.A.
Post Office Box 753
Orlando, FL 32802-0753
Telephone: (407) 423-8571
Facsimile: (407) 423-8637
E-Service: | NOS@mmdorl.com
Attorneys for Defendant, UNIVERSITY
OF FLORIDA BOARD OF TRUSTEES
d/b/a UF HEALTH EYE CENTER, a
Florida Public Body CorporateMCEwaN, MARTINEZ, DUKES & HALL, P.A.
ATTORNEYS AND COUNSELORS AT LAW
RAFAEL E. MARTINEZ DAVID A. ZIKA
THOMAS E. DUKES, III 108 EAST CENTRAL BOULEVARD ZACHARY D. TRAPP
MARY JAYE HALL POST OFFICE BOX 753 JENNIFER L. PHILLIPS
PHILIP F. MORING ORLANDO, FLORIDA 32802-0753 STACEY J. CARLISLE
WILBERT R. VANCOL THOMAS A. SURI
TELEPHONE (407) 423-8571 DANIELLE T. BORING
FAX (407) 423-8637 Reply via e-mail to:
‘wvancol@mmdorl.com
December 16, 2020
Andrea A. Lewis, Esquire
Searcy Denney Scarola Barnhart & Shipley P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
Re: Snow, Brenda v. UFBOT
Our File No.: 2010-041
Claim No.: 05232018756
Dear Ms. Lewis:
As you know, the Court on December 10 issued an Order on our Motion to
Dismiss the Amended Complaint. The Court is requiring an evidentiary hearing on Dr.
Shore’s qualifications. Prior to that hearing, I would like to take the deposition of Dr.
Shore. The deposition will be limited to his qualifications. I do not object to stipulating
that the testimony can only be used for issues related to presuit compliance.
Please advise us of Dr. Shore’s availability for such deposition. I would ask Dr.
Shore reserve an hour for the deposition.
If you have any issues or questions, please do not hesitate to give me a call.
Very Truly Yours,
/s/ Wilbert R. Vancol
Wilbert R. Vancol
WRV/gb
ce: Frank Pierce, Esquire
Exhibit AWilbert Vancol
From: Wilbert Vancol
Sent: Tuesday, January 19, 2021 3:35 PM
To: ‘alewis@SearcyLaw.com’
Cc: ‘Frank Pierce’
Subject: Snow, Brenda v. UFBOT / 05232018756:
Attachments: Ltr to Opp Counsel re Qualification Depo PIf Exper.pdf
Andrea- | am following up on this request. Can you please provide us dates? The hearing on this is February 23 and we
need the deposition prior to the hearing. Thanks. Wil
Wilbert R. Vancol, Esq.
McEwan, Martinez, Dukes & Hall, PA
108 E Central Blvd
Orlando, Florida 32801
407-423-8571
407-423-8637 (fax)
wvancol@mmdorl.com
www.mmdorl.com
This email is covered by the Electronic Communication Privacy Act, 18, U.S.C. Secs 2510-2521 and is legally
privileged. This email, and any documents attached, may contain confidential information belonging to the sender
which is protected by the work product and/or other privileges. The information is intended only for the use of
individuals or entities named above. If you have received the e-mail in error, we would appreciate your immediately
notifying us by telephone call to arrange for the return of all copies of the e-mail. You should also delete this
transmission from your computer and/or server.
Exhibit BWilbert Vancol
From: Wilbert Vancol
Sent: Monday, February 1, 2021 7:41 PM
To: Andrea A. Lewis; 'mweschrek@searcylaw.com’
Cc: Melissa Carter
Subject: Snow, Brenda v. UFBOT / 05232018756:
Andrea- can you please provide us dates for Dr. Shore’s deposition on his qualifications? Thanks. Wil
Wilbert R. Vancol, Esq.
McEwan, Martinez, Dukes & Hall, PA
108 E Central Blvd
Orlando, Florida 32801
407-423-8571
407-423-8637 (fax)
wvyancol@mmdorl.com
www.mmdorl.com
This email is covered by the Electronic Communication Privacy Act, 18, U.S.C. Secs 2510-2521 and is legally
privileged. This email, and any documents attached, may contain confidential information belonging to the sender
which is protected by the work product and/or other privileges. The information is intended only for the use of
individuals or entities named above. If you have received the e-mail in error, we would appreciate your immediately
notifying us by telephone call to arrange for the return of all copies of the e-mail. You should also delete this
transmission from your computer and/or server.
Exhibit BWilbert Vancol
From: Melissa Carter
Sent: Tuesday, January 19, 2021 3:50 PM
To: ‘Maureen M. Weschrek'
Cc: ‘Marion Davis'
Subject: RE: Snow, Brenda v. UFBOT / 05232018756: 5th Request for dates for Dr. Shore
Importance: High
Following up again regarding our multiple request for Dr. Shores’ deposition prior to your 2/23 hearing.
From: Melissa Carter
Sent: Wednesday, January 13, 2021 12:38 PM
To: ‘Maureen M. Weschrek'
Cc: ‘Marion Davis'
Subject: RE: Snow, Brenda v. UFBOT / 05232018756: 4th Request for dates for Dr. Shore
Hi Maureen,
Following up on our request for dates that we sent on 12/16 for Dr. Shores’ deposition prior to the hearing you
have set on 2/23. Please provide us with dates.
Thank you,
Melissa Carter,
Legal Assistant to Wilbert R. Vancol, Esquire
McEwan, Martinez, Dukes & Hall, P.A.
108 East Central Bivd.
Post Office Box 753
Orlando, Florida 32802
mearter@mmdori.com
www.mmdorl.com
Main Office: (407) 423-8571
Facsimile: (407) 423-8637
*“"PLEASE SEND ALL INVOICES DIRECTLY TO ACCOUNTING@MMDORL.COM WITH A CURRENT W-9.
*“*SEND TRANSCRIPTS TO: ETRAN@MMDORL.COM**
**Scheduling Notice: Dates given in regard to scheduling are not being held unless specifically noted. In
addition, dates noted as being held will be released after three business days if written confirmation and/or a
filed Notice is not received.
This email is covered by the Electronic Communication Privacy Act, 18, U.S.C, Secs 2510-2521 and is legally
privileged. This email, and any documents attached, may contain confidential information belonging to the sender which
is protected by the work product and/or other privileges.
The information is intended only for the use of individuals or entities named above. If you have received the e-mail in
error, we would appreciate your immediately notifying us by telephone call to arrange for the return of al! copies of the e-
mail. You should also delete this transmission from your computer and/or server.
Exhibit ¢From: Melissa Carter
Sent: Tuesday, January 5, 2021 2:37 PM
To: Maureen M. Weschrek
Cc: 'Marion Davis'
Subject: FW: Snow, Brenda v. UFBOT / 05232018756:
Hi Maureen,
Tam following up again for dates for Dr. Shores depo prior to the 2/23 hearing.
Thank you,
Melissa Carter,
Legal Assistant to Wilbert R. Vancol, Esquire
McEwan, Martinez, Dukes & Hall, P.A.
108 East Central Blvd
Post Office Box 753
Orlando, Florida 32802
mearter@mmdorl.com
www.mmdorl.com
Main Office: (407) 423-8571
Facsimile: (407) 423-8637
*“PLEASE SEND ALL INVOICES DIRECTLY TO ACCOUNTING@MMDORL.COM WITH A CURRENT W-9.
*“SEND TRANSCRIPTS TO: ETRAN@MMDORL.COM***
**Scheduling Notice: Dates given in regard to scheduling are not being held unless specifically noted. In
addition, dates noted as being held will be released after three business days if written confirmation and/or a
filed Notice is not received.
This email is covered by the Electronic Communication Privacy Act, 18, U.S.C, Secs 2510-2521 and is legally
privileged. This email, and any documents attached, may contain confidential information belonging to the sender which
is protected by the work product and/or other privileges.
The information is intended only for the use of individuals or entities named above. If you have received the e-mail in
error, we would appreciate your immediately notifying us by telephone call to arrange for the return of all copies of the e-
mail. You should also delete this transmission from your computer and/or server.
From: Melissa Carter
Sent: Tuesday, December 22, 2020 10:00 AM
To: 'mweschrek@searcylaw.com'
Cc: 'mdavis@mateerharbert.com'
Subject: FW: Snow, Brenda v. UFBOT / 05232018756:
Exhibit ¢Good Morning Maureen,
1am following up on our letter from last week and dates for Dr. Shores’ deposition prior to the 2/23 hearing.
Thanks so much.
Melissa
Thank you,
Melissa Carter,
Legal Assistant to Wilbert R. Vancol, Esquire
McEwan, Martinez, Dukes & Hail, P.A.
108 East Central Bivd.
Post Office Box 753
Orlando, Florida 32802
mearter@mmdorl.com
www.mmdorl.com
Main Office: (407) 423-8571
Facsimile: (407) 423-8637
*“PLEASE SEND ALL INVOICES DIRECTLY TO ACCOUNTING@MMDORL.COM WITH A CURRENT W-9,
“SEND TRANSCRIPTS TO: ETRAN@MMDORL.COM***
“Scheduling Notice: Dates given in regard to scheduling are not being held unless specifically noted. In
addition, dates noted as being held will be released after three business days if written confirmation and/or a
filed Notice is not received.
This email is covered by the Electronic Communication Privacy Act, 18, U.S.C. Secs 2510-2521 and is legally
privileged. This email, and any documents attached, may contain confidential information belonging to the sender which
is protected by the work product and/or other privileges.
The information is intended only for the use of individuals or entities named above. If you have received the e-mail in
error, we would appreciate your immediately notifying us by telephone call to arrange for the return of all copies of the e-
mail. You should also delete this transmission from your computer and/or server.
From: Melissa Carter
Sent: Wednesday, December 16, 2020 10:55 AM
To: 'alewis@SearcyLaw.com' ; 'mweschrek@searcylaw.com'
Cc: 'mdavis@mateerharbert.com' ; 'fpierce@mateerharbert.com'
; Wilbert Vancol ; Donna McAlpin
Subject: Snow, Brenda v. UFBOT / 05232018756:
Please see the attached from Attorney Vancol.
Thank you,
Melissa Carter,
Legal Assistant to Wilbert R. Vancol, Esquire
McEwan, Martinez, Dukes & Hall, P.A.
Exhibit ¢108 East Central Blvd.
Post Office Box 753
Orlando, Florida 32802
mearter@mmdori.com
www.mmdorl.com
Main Office: (407) 423-8571
Facsimile: (407) 423-8637
“PLEASE SEND ALL INVOICES DIRECTLY TO ACCOUNTING@MMDOREL. COM WITH A CURRENT W-9.
“SEND TRANSCRIPTS TO: ETRAN@MMDORL.COM**
“Scheduling Notice: Dates given in regard to scheduling are not being held unless specifically noted. In
addition, dates noted as being held will be released after three business days if written confirmation and/or a
filed Notice is not received.
This email is covered by the Electronic Communication Privacy Act, 18, U.S.C. Secs 2510-2521 and is legally
privileged. This email, and any documents attached, may contain confidential information belonging to the sender which
is protected by the work product and/or other privileges.
The information is intended only for the use of individuals or entities named above. If you have received the e-mail in
error, we would appreciate your immediately notifying us by telephone call to arrange for the return of all copies of the e-
mail. You should also delete this transmission from your computer and/or server.
Exhibit ¢
Preview
Filing # 120714747 E-Filed 02/03/2021 08:39:08 AM 2010-041 IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA BRENDA SNOW, Plaintiff(s), vs. CASE NO.: 01 2020 CA 001350 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). / DEFENDANT'S MOTION TO COMPEL DEPOSITION OF JOHN W. SHORE, M.D. COMES NOW Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate, by and through the undersigned attorneys, and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure and section 766.206, Florida Statutes, files this Motion to Compel the deposition of John W. Shore, M.D., and in support thereof states: 1, This is a medical malpractice action in which Plaintiffs allege negligence in care and treatment of Brenda Snow. 2. On August 26, 2020, Defendant moved to dismiss Plaintiff's Amended Complaint on multiple grounds including Plaintiff’s failure to comply with the presuit screening requirement of Chapter 766. In particular, Defendants alleged that Plaintiff's presuit expert, Dr. Shore, was not competent under 766.102(7), Florida Statutes, to give expert testimony on the appropriate standard of care as to administrative and other nonclinical issues. Based upon this contention, Defendant moved to dismiss Count II of "2020 CA 001350" 120714747 Filed at Alachua County Clerk 02/03/2021 08:39:12 AM ESTCase No.: 01 2020 CA 001350 Plaintiffs Amended Complaint. Count III asserts a claim for negligence based upon Defendant’s non-compliance with Section 766.110, Florida Statutes. 3. A hearing on Defendant’s Motion to Dismiss Plaintiff's Amended Complaint was heard by the Court on October 15, 2020. 4, On December 10, 2020, this Court issued its Order on Defendant’s Motion to Dismiss. The Court denied the motion in part and reserved ruling on the arguments related to Dr. Shore’s qualifications. Additionally, the Court ordered an evidentiary hearing to address the issue. The evidentiary hearing is scheduled for February 23, 2021. 5. Defendant has made multiple requests for the deposition of Dr. Shore. Exhibit A, Exhibit B and Exhibit C. The deposition is necessary to determine Dr. Shore’s experience and qualifications on the issues raised in Defendant’s Motion to Dismiss and on the issues to be addressed during the evidentiary hearing. To date, Plaintiff has failed to provide any dates of availability for Dr. Shore. 6. The deposition is necessary for Defendant to properly prepare for the evidentiary hearing scheduled by the Court for February 23, 2021. WHEREFORE, Defendant respectfully request this Court enter an order compelling Plaintiff to provide dates for the deposition of Dr. Shore to address issues related to his qualifications. CERTIFICATE OF SERVICE I hereby certify that on this 3% day of February, 2021, a true and correct copy of the foregoing has been electronically filed with the Clerk of the Court by using the Florida Courts E-Filing Portal, and furnished via email to the following: Andrea A. Lewis, Esquire, SEARCY DENNEY SCAROLA BARNHART & SHIPLEY P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Francis E. Pierce, III, Esquire, MATEER HARBERT, P.A., 225 East Robinson Street, Suite 600, Orlando, FL 32801; at the following email addresses: alewis@searcylaw.com; lewisteam@searcylaw.com; mweschrek@searcylaw.com;litpleadings@mateerharbert.com Case No.: 01 2020 CA 001350 /s/ Wilbert R. Vancol Rafael E. Martinez Florida Bar No.: 0243248 rmartinez@mmdorl.com Wilbert R. Vancol Florida Bar No.: 0093132 wvancol@mmdorl.com McEwan, Martinez, Dukes & Hall, P.A. Post Office Box 753 Orlando, FL 32802-0753 Telephone: (407) 423-8571 Facsimile: (407) 423-8637 E-Service: | NOS@mmdorl.com Attorneys for Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body CorporateMCEwaN, MARTINEZ, DUKES & HALL, P.A. ATTORNEYS AND COUNSELORS AT LAW RAFAEL E. MARTINEZ DAVID A. ZIKA THOMAS E. DUKES, III 108 EAST CENTRAL BOULEVARD ZACHARY D. TRAPP MARY JAYE HALL POST OFFICE BOX 753 JENNIFER L. PHILLIPS PHILIP F. MORING ORLANDO, FLORIDA 32802-0753 STACEY J. CARLISLE WILBERT R. VANCOL THOMAS A. SURI TELEPHONE (407) 423-8571 DANIELLE T. BORING FAX (407) 423-8637 Reply via e-mail to: ‘wvancol@mmdorl.com December 16, 2020 Andrea A. Lewis, Esquire Searcy Denney Scarola Barnhart & Shipley P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Re: Snow, Brenda v. UFBOT Our File No.: 2010-041 Claim No.: 05232018756 Dear Ms. Lewis: As you know, the Court on December 10 issued an Order on our Motion to Dismiss the Amended Complaint. The Court is requiring an evidentiary hearing on Dr. Shore’s qualifications. Prior to that hearing, I would like to take the deposition of Dr. Shore. The deposition will be limited to his qualifications. I do not object to stipulating that the testimony can only be used for issues related to presuit compliance. Please advise us of Dr. Shore’s availability for such deposition. I would ask Dr. Shore reserve an hour for the deposition. If you have any issues or questions, please do not hesitate to give me a call. Very Truly Yours, /s/ Wilbert R. Vancol Wilbert R. Vancol WRV/gb ce: Frank Pierce, Esquire Exhibit AWilbert Vancol From: Wilbert Vancol Sent: Tuesday, January 19, 2021 3:35 PM To: ‘alewis@SearcyLaw.com’ Cc: ‘Frank Pierce’ Subject: Snow, Brenda v. UFBOT / 05232018756: Attachments: Ltr to Opp Counsel re Qualification Depo PIf Exper.pdf Andrea- | am following up on this request. Can you please provide us dates? The hearing on this is February 23 and we need the deposition prior to the hearing. Thanks. Wil Wilbert R. Vancol, Esq. McEwan, Martinez, Dukes & Hall, PA 108 E Central Blvd Orlando, Florida 32801 407-423-8571 407-423-8637 (fax) wvancol@mmdorl.com www.mmdorl.com This email is covered by the Electronic Communication Privacy Act, 18, U.S.C. Secs 2510-2521 and is legally privileged. This email, and any documents attached, may contain confidential information belonging to the sender which is protected by the work product and/or other privileges. The information is intended only for the use of individuals or entities named above. If you have received the e-mail in error, we would appreciate your immediately notifying us by telephone call to arrange for the return of all copies of the e-mail. You should also delete this transmission from your computer and/or server. Exhibit BWilbert Vancol From: Wilbert Vancol Sent: Monday, February 1, 2021 7:41 PM To: Andrea A. Lewis; 'mweschrek@searcylaw.com’ Cc: Melissa Carter Subject: Snow, Brenda v. UFBOT / 05232018756: Andrea- can you please provide us dates for Dr. Shore’s deposition on his qualifications? Thanks. Wil Wilbert R. Vancol, Esq. McEwan, Martinez, Dukes & Hall, PA 108 E Central Blvd Orlando, Florida 32801 407-423-8571 407-423-8637 (fax) wvyancol@mmdorl.com www.mmdorl.com This email is covered by the Electronic Communication Privacy Act, 18, U.S.C. Secs 2510-2521 and is legally privileged. This email, and any documents attached, may contain confidential information belonging to the sender which is protected by the work product and/or other privileges. The information is intended only for the use of individuals or entities named above. If you have received the e-mail in error, we would appreciate your immediately notifying us by telephone call to arrange for the return of all copies of the e-mail. You should also delete this transmission from your computer and/or server. Exhibit BWilbert Vancol From: Melissa Carter Sent: Tuesday, January 19, 2021 3:50 PM To: ‘Maureen M. Weschrek' Cc: ‘Marion Davis' Subject: RE: Snow, Brenda v. UFBOT / 05232018756: 5th Request for dates for Dr. Shore Importance: High Following up again regarding our multiple request for Dr. Shores’ deposition prior to your 2/23 hearing. From: Melissa Carter Sent: Wednesday, January 13, 2021 12:38 PM To: ‘Maureen M. Weschrek' Cc: ‘Marion Davis' Subject: RE: Snow, Brenda v. UFBOT / 05232018756: 4th Request for dates for Dr. Shore Hi Maureen, Following up on our request for dates that we sent on 12/16 for Dr. Shores’ deposition prior to the hearing you have set on 2/23. Please provide us with dates. Thank you, Melissa Carter, Legal Assistant to Wilbert R. Vancol, Esquire McEwan, Martinez, Dukes & Hall, P.A. 108 East Central Bivd. Post Office Box 753 Orlando, Florida 32802 mearter@mmdori.com www.mmdorl.com Main Office: (407) 423-8571 Facsimile: (407) 423-8637 *“"PLEASE SEND ALL INVOICES DIRECTLY TO ACCOUNTING@MMDORL.COM WITH A CURRENT W-9. *“*SEND TRANSCRIPTS TO: ETRAN@MMDORL.COM** **Scheduling Notice: Dates given in regard to scheduling are not being held unless specifically noted. In addition, dates noted as being held will be released after three business days if written confirmation and/or a filed Notice is not received. This email is covered by the Electronic Communication Privacy Act, 18, U.S.C, Secs 2510-2521 and is legally privileged. This email, and any documents attached, may contain confidential information belonging to the sender which is protected by the work product and/or other privileges. The information is intended only for the use of individuals or entities named above. If you have received the e-mail in error, we would appreciate your immediately notifying us by telephone call to arrange for the return of al! copies of the e- mail. You should also delete this transmission from your computer and/or server. Exhibit ¢From: Melissa Carter Sent: Tuesday, January 5, 2021 2:37 PM To: Maureen M. Weschrek Cc: 'Marion Davis' Subject: FW: Snow, Brenda v. UFBOT / 05232018756: Hi Maureen, Tam following up again for dates for Dr. Shores depo prior to the 2/23 hearing. Thank you, Melissa Carter, Legal Assistant to Wilbert R. Vancol, Esquire McEwan, Martinez, Dukes & Hall, P.A. 108 East Central Blvd Post Office Box 753 Orlando, Florida 32802 mearter@mmdorl.com www.mmdorl.com Main Office: (407) 423-8571 Facsimile: (407) 423-8637 *“PLEASE SEND ALL INVOICES DIRECTLY TO ACCOUNTING@MMDORL.COM WITH A CURRENT W-9. *“SEND TRANSCRIPTS TO: ETRAN@MMDORL.COM*** **Scheduling Notice: Dates given in regard to scheduling are not being held unless specifically noted. In addition, dates noted as being held will be released after three business days if written confirmation and/or a filed Notice is not received. This email is covered by the Electronic Communication Privacy Act, 18, U.S.C, Secs 2510-2521 and is legally privileged. This email, and any documents attached, may contain confidential information belonging to the sender which is protected by the work product and/or other privileges. The information is intended only for the use of individuals or entities named above. If you have received the e-mail in error, we would appreciate your immediately notifying us by telephone call to arrange for the return of all copies of the e- mail. You should also delete this transmission from your computer and/or server. From: Melissa Carter Sent: Tuesday, December 22, 2020 10:00 AM To: 'mweschrek@searcylaw.com' Cc: 'mdavis@mateerharbert.com' Subject: FW: Snow, Brenda v. UFBOT / 05232018756: Exhibit ¢Good Morning Maureen, 1am following up on our letter from last week and dates for Dr. Shores’ deposition prior to the 2/23 hearing. Thanks so much. Melissa Thank you, Melissa Carter, Legal Assistant to Wilbert R. Vancol, Esquire McEwan, Martinez, Dukes & Hail, P.A. 108 East Central Bivd. Post Office Box 753 Orlando, Florida 32802 mearter@mmdorl.com www.mmdorl.com Main Office: (407) 423-8571 Facsimile: (407) 423-8637 *“PLEASE SEND ALL INVOICES DIRECTLY TO ACCOUNTING@MMDORL.COM WITH A CURRENT W-9, “SEND TRANSCRIPTS TO: ETRAN@MMDORL.COM*** “Scheduling Notice: Dates given in regard to scheduling are not being held unless specifically noted. In addition, dates noted as being held will be released after three business days if written confirmation and/or a filed Notice is not received. This email is covered by the Electronic Communication Privacy Act, 18, U.S.C. Secs 2510-2521 and is legally privileged. This email, and any documents attached, may contain confidential information belonging to the sender which is protected by the work product and/or other privileges. The information is intended only for the use of individuals or entities named above. If you have received the e-mail in error, we would appreciate your immediately notifying us by telephone call to arrange for the return of all copies of the e- mail. You should also delete this transmission from your computer and/or server. From: Melissa Carter Sent: Wednesday, December 16, 2020 10:55 AM To: 'alewis@SearcyLaw.com' ; 'mweschrek@searcylaw.com' Cc: 'mdavis@mateerharbert.com' ; 'fpierce@mateerharbert.com' ; Wilbert Vancol ; Donna McAlpin Subject: Snow, Brenda v. UFBOT / 05232018756: Please see the attached from Attorney Vancol. Thank you, Melissa Carter, Legal Assistant to Wilbert R. Vancol, Esquire McEwan, Martinez, Dukes & Hall, P.A. Exhibit ¢108 East Central Blvd. Post Office Box 753 Orlando, Florida 32802 mearter@mmdori.com www.mmdorl.com Main Office: (407) 423-8571 Facsimile: (407) 423-8637 “PLEASE SEND ALL INVOICES DIRECTLY TO ACCOUNTING@MMDOREL. COM WITH A CURRENT W-9. “SEND TRANSCRIPTS TO: ETRAN@MMDORL.COM** “Scheduling Notice: Dates given in regard to scheduling are not being held unless specifically noted. In addition, dates noted as being held will be released after three business days if written confirmation and/or a filed Notice is not received. This email is covered by the Electronic Communication Privacy Act, 18, U.S.C. Secs 2510-2521 and is legally privileged. This email, and any documents attached, may contain confidential information belonging to the sender which is protected by the work product and/or other privileges. The information is intended only for the use of individuals or entities named above. If you have received the e-mail in error, we would appreciate your immediately notifying us by telephone call to arrange for the return of all copies of the e- mail. You should also delete this transmission from your computer and/or server. Exhibit ¢