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Filing # 138726012 E-Filed 11/17/2021 02:46:23 PM
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 50-2018-CA-15763-XXXX-
MB
ELIZABETH L. BALZARANO, Individually,
and as Personal Representative of the
ESTATE OF MICHELLE L. BALZARANO,
Plaintiffs,
v.
LIFELINE RECOVERY, LLC d/b/a LIFELINE
RECOVERY SUPPORT SERVICES, a
Foreign Corporation; JOHN BROGAN; LIFE
CHANGES ADDICTION TREATMENT
CENTER OF THE PALM BEACHES;
WARBIRD PROPERTIES, LLC,
d/b/a CAMERON VILLA, LLC, a Florida
Corporation;
EMILIO DUBOY, M.D.; and JANINE
BEATTIE, ARNP,
Defendants.
/
DEFENDANT, JANINE BEATTIE, ARNP’S RESPONSE TO PLAINTIFF’S
FIRST SET OF INTERROGATORIES
COMES NOW, Defendant, Janine Beattie, ARNP, by and through its undersigned
counsel, and pursuant to Florida Rule of Civil Procedure 1.340 and responds to Plaintiff's
First Set of Interrogatories and states the following in support thereof.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 17th day of November, 2021, a true and correct
copy of the foregoing was filed with the Clerk of Palm Beach County by using the Florida
Courts e-Filing Portal, which will send an automatic e-mail message to the following
parties registered with the e-Filing Portal system: Warbird Properties LLC dba
CAMERON VILLA, LLC, Thomas D. Graham, Esq., Leesfield Scolaro, P.A.,
Page 1
«FIRM_NAME_LINE_1»
COLE, SCOTT & KISSANE BUILDING - 9190 SOUTH DADELAND BOULEVARD ~SUITE 1490 - P.O. BOX 569015 - MIAMI FLORIDA 39256 - (305) 50-5900 - (905) 373-2294 FAX
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/17/2021 02:46:23 PM ***CASE NO.: «Court_court_case_no»
graham@leesfiled.com;leon@leesfield.com, 2350 S. Dixie Highway, Miami, FL 33133,
(305) 854-4900/(305) 854-8266 (F), Attorney for Plaintiff, Elizabeth L. Balzarano, Nicole
Sauvola LaMay, Esq., Nicole Sauvola PA, Colelaw36@gmail.com, 10152 Indiantown
Road, Box 138, Jupiter, FL 33478, (561) 506-5606/(561) 229-0169 (F), Attorney for
Defendant, Warbird Properties LLC dba CAMERON VILLA, LLC, Thomas Scolaro, Esq.,
Leesfield Scolaro, P.A., scolaro@leesfield.com; Shapiro@leesfield.com;
diaz@leesfield.com, 2350 South Dixie Highway, Miami, FL 33133, (305) 854-4900/(305)
854-8266 (F), Attorney for Plaintiff, Elizabeth L. Balzarano and Noelle Sheehan, Esq.,
Wilson Elser Moskowitz Edelman & Dicker, LLP,
Noelle.Sheehan@wilsonelser.com;Annette.Corchado@wilsonelser.com;Alejandra.Bosc
an@wilsonelser.com, 111 N. Orange Ave., Suite 1200, Orlando, FL 32801, (407) 203-
7599/(407) 648-1376 (F), Attorney for Defendant, Emilio Duboy.
COLE, SCOTT & KISSANE, P.A.
Counsel! for Defendant Life Changes Addition
Treatment Center of The Palm Beaches and
Jeanine Beattie, ARNP;
Cole, Scott & Kissane Building
9150 South Dadeland Boulevard, Suite 1400
P.O. Box 569015
Miami, Florida 33256
Telephone (305) 350-5354
Facsimile (305) 373-2294
Primary e-mail: jonathan.midwall@csklegal.com
Secondary e-mail:
omaira.rodriguez@csklegal.com
By: _s/ Jonathan M. Midwall
JONATHAN M. MIDWALL
Florida Bar No.: 182011
ALYSSA M. TORNBERG
Florida Bar No.: 127409
1943.0485-00
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COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no»
RESPONSES AND/OR OBJECTIONS TO INTERROGATORIES
DIRECTED TO JANINE BEATTIE, ARNP
1. What is the name and address of the person answering these interrogatories,
and, if applicable, the person's official position or relationship with the party
to whom theinterrogatories are directed?
RESPONSE: Janine Bettie, ARNP with the assistance of counsel.
2. Describe any and all policies of insurance, including excess or umbrella
insurance, whichyou contend cover or may cover you for the allegations set forth
in Plaintiffs’ complaint, detailing as to such policies the name of the insurer, the
number of the policy, the effective dates of the policy, the available limits of
liability; the name and address of the custodian of the policy and whether there
is a coverage defense. Please describe the coverage defense if applicable.
RESPONSE: See attached.
3. Describe in detail how the incident described in the complaint happened,
including all actions taken by you to prevent the incident.
RESPONSE: Unknown at this time as discovery has just
commenced.
4. Describe in detail each act or omission on the part of any health care provider,
individual or other entity that you contend constituted negligence that was a
contributing legal causeof the incident described in the Complaint. Please state
the full name and address of eachsuch person or entity, the legal basis for
your contention, the facts or evidence uponwhich your contention is based,
and whether or not you have notified each such person orentity of your
contention.
RESPONSE: Unknown at this time as discovery has just commenced.
5. List the names and addresses of all persons who are believed or known by you,
your agents or your attorneys, to have any knowledge concerning any of the
issues in this lawsuit; and specify the subject matter about which the witness has
knowledge.
RESPONSE: None known to me other than the parties to this lawsuit
and the Plaintiff's treating providers.
6. Have you heard or do you know about any statement or remark made by or on
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COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (05) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no»
behalf of any party to this lawsuit, other than yourself, concerning any issue in
this lawsuit? If so, state the name and address of each person who made the
statement or statements, the name and address of each person who heard it,
and the date, time, place, and substance ofeach statement.
RESPONSE: None known to me.
7. Have you made an agreement with anyone that would limit that partys liability
to anyone for any of the damages sued upon in this case? If so, state the terms
of the agreement andthe parties to it.
RESPONSE: None.
8. Please state if you have ever been a party, either plaintiff or defendant, in a
lawsuit other than the present matter, and, if so, state whether you were plaintiff
or defendant, the nature of the action, and the date and court in which such suit
was filed.
RESPONSE: No.
9. Please give us your entire professional background up to the present time,
including datesof employment or association, the names of all physicians with
whom you have practiced, the form of employment or business relationship such
as whether by partnership, corporation, or sole proprietorship, and the dates of
the relationships, including hospital staff privileges and positions, and teaching
experience.
RESPONSE: See attached CV.
10. With respect to your office library or usual place of work, give us the name,
author, nameof publisher, and the date of publication for every medical book or
article, journal, or medical text to which you had access, which deals with the
overall subject matterdescribed in the complaint. (In lieu of answering this
interrogatory you may allow plaintiffs’ counsel to inspect your library at a
reasonable time).
RESPONSE: I do not maintain a library.
11. If you believe there was any risk to the treatment you rendered to the plaintiff,
state the nature of all risks, including whether the risks were communicated to
the plaintiff; when, where, and in what manner they were communicated; and
whether any of the risks in fact occurred.
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COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no»
RESPONSE: Objection, vague and overbroad as to the term “risk.”
Without waiving objection, there is risk involved in all medical care and
treatment.
12. Tell us your experience in giving the kind of treatment or examination that you
rendered to the plaintiff before it was given to the plaintiff, giving us such
information as the approximate number of times you have given similar
treatment or examinations, where the prior treatment or examinations took place,
and the successful or unsuccessful nature of the outcome of the treatment or
those examinations.
RESPONSE: See attached CV.
13. Please state whether any claim for medical malpractice has ever been made
against you alleging facts relating to the same or similar subject matter as this
lawsuit, and, if so, stateas to each such claim the names of the parties, the claim
number, the date of the alleged incident, the ultimate disposition of the claim,
and the name of your attorney, if any.
RESPONSE: None.
14. Pursuant to the recent Florida Supreme Court ruling, Charles v. S. Baptist Hosp.
of Fla., Inc., 209 So. 3d 1199 (Fla. 2017), and Amendment 7, codified as Article
X, Section 25,of the Florida Constitution, please state any and all adverse
medical incidents during 2013, 2014 and 2015 in which you were involved. The
information requested should be redacted as to any patient identifying
information pursuant to HIPAA. Please provide a cost estimate for the
information sought in this request. The information should include any such
incident(s), state as to each such instance(s) the date of the alleged incident(s),
the ultimate disposition of the incident(s), and the name of your attorney(s), if
any. Section 25(3) defines an “adverse medical incident” to mean “medical
negligence, intentional misconduct, and any other act, neglect, or default of a
health care facility or health care provider that caused or could have caused
injury to or death of a patient, including, but not limited to, those incidents that
are required by state or federal law to bereported to any governmental agency
or body, and incidents that are reported to or reviewed by any health care facility
peer review, risk management, quality assurance, credentials, or similar
committee, or any representative of any such committees.”
RESPONSE: None known to me.
15. Describe the legal, contractual and/or business relationship of Defendant, Life
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COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no»
Changes, with Janine Beattie, ARNP, and state when the relationship was
established and whetherit was in place at the time the decedent was discharged
from Defendant's facility.
RESPONSE: At the time of my care and treatment of Michelle
Balzarano, | was a volunteer at Life Changes on an as-needed basis. | do
not recall when that relationship was established.
16. With respect to your fees for the care and treatment of Michelle Balzarano
please:
(a) State the total amount of your charges;
(b) | State the amount you were paid;
(c) Provide an itemized statement of your charges; and
(d) Identify the person or entity that paid the bill for your services.
RESPONSE: None.
17. Has the Defendant, for its care or treatment of a patient ever been the subject of
an investigation for any reason by the State of Florida Agency for Health Care
Administration, Department of Professional Regulation, Florida DCF or any other
regulatory agency? If so, please identify the name and address of the agency,
the date of the investigation, the care and treatment which was the subject of the
investigation and state the resolution of the investigation.
RESPONSE: No.
18. Do you intend to call any expert witness at the trial of this case? If so, state as
to each such witness, the name, business address and area of expertise of the
witness, the subject matter upon which the witness is expected to testify, the
facts and opinions to which the witness will testify, and a summary of the grounds
of each opinion.
RESPONSE: Unknown at this time. Any such experts will be
disclosed pursuant to this Court’s trial order.
19. Please describe with as much detail as possible all discussions or
communications between Defendant and Michelle Balzarano or any individual
assisting Michelle Balzarano, regarding her continuity of care for substance
abuse treatment, provision of her mental health medications, and linkage with a
qualified professional to maintain her mental health medication prescriptions,
Page 6
COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (05) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no»
and indicate the times the discussions occurred, the medium for conducting the
discussions (i.e. in-person, zoom, cell phone, teleconference, satellite phone
etc.), and the participants involved in any suchdiscussions.
RESPONSE: None other than those documented in the medical
record.
20. Please describe and list precisely the medications and corresponding amounts
that Michelle Balzarano was provided with upon her discharge.
RESPONSE: See medical record.
21. Please explain why arrangements were not made by Defendant to ensure that
Michelle Balzarano’s had access to sufficient amounts of her mental health
medication upondischarge.
RESPONSE: Objection, calls for an expert opinion. Without waiving
objection, | was not involved in the discharge planning of Michelle
Balzarano from Life Changes.
22. Please explain why arrangements were not made to ensure the proper
management of Michelle Balzarano’s mental health medications at the time of
her discharge.
RESPONSE: Objection, calls for an expert opinion. Without waiving
objection, | was not involved in the discharge planning of Michelle
Balzarano from Life Changes.
23. Please state the full and complete factual basis for your Fabre Affirmative
Defense, specifically naming the individual(s) you intend to include on the verdict
form, a description of how they are liable herein, and any witnesses or evidence
to support your Fabre Affirmative Defense.
RESPONSE: The affirmative defenses are self-explanatory and are
based upon the case law and statutes cited therein.
24. Please describe the complete facts and circumstances surrounding why and
how Life Changes facility ceased operations and shut down, including the
reason(s) for closing, thedate that the decision to close was made or known by
Life Changes, the dates that the lastpatients were discharged, the dates that
staff stopped reporting to the premises, the last date that Dr. Emilio Duboy was
present on the premises, and all processes or support put in place for discharged
patients to ensure continuity of care post-discharge and _ continued
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COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no»
communications with staff and physicians.
RESPONSE: Unknown to me.
25. Please list every job, source of employment, medical facility, or location
that JanineBeattie, ARNP worked or was employed by during March, April,
May, and June of 2017.
RESPONSE: See attached CV.
26. Please list every job, source of employment, medical facility, or location
that JanineBeattie worked or was employed by during March, April, May, and
June of 2017.
RESPONSE: See attached CV.
Page 8
COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAX
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Filing # 138726012 E-Filed 11/17/2021 02:46:23 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 50-2018-CA-15763-XXXX- MB ELIZABETH L. BALZARANO, Individually, and as Personal Representative of the ESTATE OF MICHELLE L. BALZARANO, Plaintiffs, v. LIFELINE RECOVERY, LLC d/b/a LIFELINE RECOVERY SUPPORT SERVICES, a Foreign Corporation; JOHN BROGAN; LIFE CHANGES ADDICTION TREATMENT CENTER OF THE PALM BEACHES; WARBIRD PROPERTIES, LLC, d/b/a CAMERON VILLA, LLC, a Florida Corporation; EMILIO DUBOY, M.D.; and JANINE BEATTIE, ARNP, Defendants. / DEFENDANT, JANINE BEATTIE, ARNP’S RESPONSE TO PLAINTIFF’S FIRST SET OF INTERROGATORIES COMES NOW, Defendant, Janine Beattie, ARNP, by and through its undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.340 and responds to Plaintiff's First Set of Interrogatories and states the following in support thereof. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 17th day of November, 2021, a true and correct copy of the foregoing was filed with the Clerk of Palm Beach County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Warbird Properties LLC dba CAMERON VILLA, LLC, Thomas D. Graham, Esq., Leesfield Scolaro, P.A., Page 1 «FIRM_NAME_LINE_1» COLE, SCOTT & KISSANE BUILDING - 9190 SOUTH DADELAND BOULEVARD ~SUITE 1490 - P.O. BOX 569015 - MIAMI FLORIDA 39256 - (305) 50-5900 - (905) 373-2294 FAX *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/17/2021 02:46:23 PM ***CASE NO.: «Court_court_case_no» graham@leesfiled.com;leon@leesfield.com, 2350 S. Dixie Highway, Miami, FL 33133, (305) 854-4900/(305) 854-8266 (F), Attorney for Plaintiff, Elizabeth L. Balzarano, Nicole Sauvola LaMay, Esq., Nicole Sauvola PA, Colelaw36@gmail.com, 10152 Indiantown Road, Box 138, Jupiter, FL 33478, (561) 506-5606/(561) 229-0169 (F), Attorney for Defendant, Warbird Properties LLC dba CAMERON VILLA, LLC, Thomas Scolaro, Esq., Leesfield Scolaro, P.A., scolaro@leesfield.com; Shapiro@leesfield.com; diaz@leesfield.com, 2350 South Dixie Highway, Miami, FL 33133, (305) 854-4900/(305) 854-8266 (F), Attorney for Plaintiff, Elizabeth L. Balzarano and Noelle Sheehan, Esq., Wilson Elser Moskowitz Edelman & Dicker, LLP, Noelle.Sheehan@wilsonelser.com;Annette.Corchado@wilsonelser.com;Alejandra.Bosc an@wilsonelser.com, 111 N. Orange Ave., Suite 1200, Orlando, FL 32801, (407) 203- 7599/(407) 648-1376 (F), Attorney for Defendant, Emilio Duboy. COLE, SCOTT & KISSANE, P.A. Counsel! for Defendant Life Changes Addition Treatment Center of The Palm Beaches and Jeanine Beattie, ARNP; Cole, Scott & Kissane Building 9150 South Dadeland Boulevard, Suite 1400 P.O. Box 569015 Miami, Florida 33256 Telephone (305) 350-5354 Facsimile (305) 373-2294 Primary e-mail: jonathan.midwall@csklegal.com Secondary e-mail: omaira.rodriguez@csklegal.com By: _s/ Jonathan M. Midwall JONATHAN M. MIDWALL Florida Bar No.: 182011 ALYSSA M. TORNBERG Florida Bar No.: 127409 1943.0485-00 Page 2 COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no» RESPONSES AND/OR OBJECTIONS TO INTERROGATORIES DIRECTED TO JANINE BEATTIE, ARNP 1. What is the name and address of the person answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom theinterrogatories are directed? RESPONSE: Janine Bettie, ARNP with the assistance of counsel. 2. Describe any and all policies of insurance, including excess or umbrella insurance, whichyou contend cover or may cover you for the allegations set forth in Plaintiffs’ complaint, detailing as to such policies the name of the insurer, the number of the policy, the effective dates of the policy, the available limits of liability; the name and address of the custodian of the policy and whether there is a coverage defense. Please describe the coverage defense if applicable. RESPONSE: See attached. 3. Describe in detail how the incident described in the complaint happened, including all actions taken by you to prevent the incident. RESPONSE: Unknown at this time as discovery has just commenced. 4. Describe in detail each act or omission on the part of any health care provider, individual or other entity that you contend constituted negligence that was a contributing legal causeof the incident described in the Complaint. Please state the full name and address of eachsuch person or entity, the legal basis for your contention, the facts or evidence uponwhich your contention is based, and whether or not you have notified each such person orentity of your contention. RESPONSE: Unknown at this time as discovery has just commenced. 5. List the names and addresses of all persons who are believed or known by you, your agents or your attorneys, to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. RESPONSE: None known to me other than the parties to this lawsuit and the Plaintiff's treating providers. 6. Have you heard or do you know about any statement or remark made by or on Page 3 COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (05) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no» behalf of any party to this lawsuit, other than yourself, concerning any issue in this lawsuit? If so, state the name and address of each person who made the statement or statements, the name and address of each person who heard it, and the date, time, place, and substance ofeach statement. RESPONSE: None known to me. 7. Have you made an agreement with anyone that would limit that partys liability to anyone for any of the damages sued upon in this case? If so, state the terms of the agreement andthe parties to it. RESPONSE: None. 8. Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other than the present matter, and, if so, state whether you were plaintiff or defendant, the nature of the action, and the date and court in which such suit was filed. RESPONSE: No. 9. Please give us your entire professional background up to the present time, including datesof employment or association, the names of all physicians with whom you have practiced, the form of employment or business relationship such as whether by partnership, corporation, or sole proprietorship, and the dates of the relationships, including hospital staff privileges and positions, and teaching experience. RESPONSE: See attached CV. 10. With respect to your office library or usual place of work, give us the name, author, nameof publisher, and the date of publication for every medical book or article, journal, or medical text to which you had access, which deals with the overall subject matterdescribed in the complaint. (In lieu of answering this interrogatory you may allow plaintiffs’ counsel to inspect your library at a reasonable time). RESPONSE: I do not maintain a library. 11. If you believe there was any risk to the treatment you rendered to the plaintiff, state the nature of all risks, including whether the risks were communicated to the plaintiff; when, where, and in what manner they were communicated; and whether any of the risks in fact occurred. Page 4 COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no» RESPONSE: Objection, vague and overbroad as to the term “risk.” Without waiving objection, there is risk involved in all medical care and treatment. 12. Tell us your experience in giving the kind of treatment or examination that you rendered to the plaintiff before it was given to the plaintiff, giving us such information as the approximate number of times you have given similar treatment or examinations, where the prior treatment or examinations took place, and the successful or unsuccessful nature of the outcome of the treatment or those examinations. RESPONSE: See attached CV. 13. Please state whether any claim for medical malpractice has ever been made against you alleging facts relating to the same or similar subject matter as this lawsuit, and, if so, stateas to each such claim the names of the parties, the claim number, the date of the alleged incident, the ultimate disposition of the claim, and the name of your attorney, if any. RESPONSE: None. 14. Pursuant to the recent Florida Supreme Court ruling, Charles v. S. Baptist Hosp. of Fla., Inc., 209 So. 3d 1199 (Fla. 2017), and Amendment 7, codified as Article X, Section 25,of the Florida Constitution, please state any and all adverse medical incidents during 2013, 2014 and 2015 in which you were involved. The information requested should be redacted as to any patient identifying information pursuant to HIPAA. Please provide a cost estimate for the information sought in this request. The information should include any such incident(s), state as to each such instance(s) the date of the alleged incident(s), the ultimate disposition of the incident(s), and the name of your attorney(s), if any. Section 25(3) defines an “adverse medical incident” to mean “medical negligence, intentional misconduct, and any other act, neglect, or default of a health care facility or health care provider that caused or could have caused injury to or death of a patient, including, but not limited to, those incidents that are required by state or federal law to bereported to any governmental agency or body, and incidents that are reported to or reviewed by any health care facility peer review, risk management, quality assurance, credentials, or similar committee, or any representative of any such committees.” RESPONSE: None known to me. 15. Describe the legal, contractual and/or business relationship of Defendant, Life Page 5 COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no» Changes, with Janine Beattie, ARNP, and state when the relationship was established and whetherit was in place at the time the decedent was discharged from Defendant's facility. RESPONSE: At the time of my care and treatment of Michelle Balzarano, | was a volunteer at Life Changes on an as-needed basis. | do not recall when that relationship was established. 16. With respect to your fees for the care and treatment of Michelle Balzarano please: (a) State the total amount of your charges; (b) | State the amount you were paid; (c) Provide an itemized statement of your charges; and (d) Identify the person or entity that paid the bill for your services. RESPONSE: None. 17. Has the Defendant, for its care or treatment of a patient ever been the subject of an investigation for any reason by the State of Florida Agency for Health Care Administration, Department of Professional Regulation, Florida DCF or any other regulatory agency? If so, please identify the name and address of the agency, the date of the investigation, the care and treatment which was the subject of the investigation and state the resolution of the investigation. RESPONSE: No. 18. Do you intend to call any expert witness at the trial of this case? If so, state as to each such witness, the name, business address and area of expertise of the witness, the subject matter upon which the witness is expected to testify, the facts and opinions to which the witness will testify, and a summary of the grounds of each opinion. RESPONSE: Unknown at this time. Any such experts will be disclosed pursuant to this Court’s trial order. 19. Please describe with as much detail as possible all discussions or communications between Defendant and Michelle Balzarano or any individual assisting Michelle Balzarano, regarding her continuity of care for substance abuse treatment, provision of her mental health medications, and linkage with a qualified professional to maintain her mental health medication prescriptions, Page 6 COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (05) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no» and indicate the times the discussions occurred, the medium for conducting the discussions (i.e. in-person, zoom, cell phone, teleconference, satellite phone etc.), and the participants involved in any suchdiscussions. RESPONSE: None other than those documented in the medical record. 20. Please describe and list precisely the medications and corresponding amounts that Michelle Balzarano was provided with upon her discharge. RESPONSE: See medical record. 21. Please explain why arrangements were not made by Defendant to ensure that Michelle Balzarano’s had access to sufficient amounts of her mental health medication upondischarge. RESPONSE: Objection, calls for an expert opinion. Without waiving objection, | was not involved in the discharge planning of Michelle Balzarano from Life Changes. 22. Please explain why arrangements were not made to ensure the proper management of Michelle Balzarano’s mental health medications at the time of her discharge. RESPONSE: Objection, calls for an expert opinion. Without waiving objection, | was not involved in the discharge planning of Michelle Balzarano from Life Changes. 23. Please state the full and complete factual basis for your Fabre Affirmative Defense, specifically naming the individual(s) you intend to include on the verdict form, a description of how they are liable herein, and any witnesses or evidence to support your Fabre Affirmative Defense. RESPONSE: The affirmative defenses are self-explanatory and are based upon the case law and statutes cited therein. 24. Please describe the complete facts and circumstances surrounding why and how Life Changes facility ceased operations and shut down, including the reason(s) for closing, thedate that the decision to close was made or known by Life Changes, the dates that the lastpatients were discharged, the dates that staff stopped reporting to the premises, the last date that Dr. Emilio Duboy was present on the premises, and all processes or support put in place for discharged patients to ensure continuity of care post-discharge and _ continued Page 7 COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAXCASE NO.: «Court_court_case_no» communications with staff and physicians. RESPONSE: Unknown to me. 25. Please list every job, source of employment, medical facility, or location that JanineBeattie, ARNP worked or was employed by during March, April, May, and June of 2017. RESPONSE: See attached CV. 26. Please list every job, source of employment, medical facility, or location that JanineBeattie worked or was employed by during March, April, May, and June of 2017. RESPONSE: See attached CV. Page 8 COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (805) 373-2204 FAX