On January 24, 2018 a
Party Discovery
was filed
involving a dispute between
Cabrera, Jesus,
and
Hollywood Property Investments Llc,
Larkin Community Hospital Inc,
Michel, Jack, Md,
Rehabilitation Center At Hollywood Hills Llc,
for Neg - Nursing Home Negligence
in the District Court of Broward County.
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Filing # 106359288 E-Filed 04/16/2020 06:10:27 PM
IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION: 21
CASE NO.: CACE-18-001878 (21)
JESUS CABRERA as Personal
Representative of the Estate of
RAMON CABRERA, Deceased,
Plaintiff,
vs.
JACK MICHEL, M.D., REHABILITATION
CENTER AT HOLLYWOOD HILLS, LLC.,
and LARKIN COMMUNITY HOSPITAL, INC.
d/b/a LARKIN COMMUNITY HOSPITAL,
Defendant.
/
PLAINTIFF’S RESPONSES TO DEFENDANT’S HOLLYWOOD HILLS, LLC.’S FIRST
REQUEST FOR PRODUCTION
COMES NOW, the Plaintiff, JESUS CABRERA as Personal Representative of the Estate
of RAMON CABRERA, Deceased, by and through his undersigned counsel, and pursuant to Rule
1.350, Fla.R.Civ.P., hereby files this, his Responses to Defendant, REHABILITATION CENTER
AT HOLLYWOOD HILLS, LLC., First Request for Production served on March 17, 2020.
The Plaintiff is not in possession of any documents responsive to that request.
The Plaintiff is not in possession of any documents responsive to that request.
The Plaintiff is not in possession of any documents responsive to that request.
This information is enclosed in the CD being forwarded to Defense counsel.
The Plaintiff is not in possession of any photographs responsive to that request.
The Plaintiff is not in possession of any photographs responsive to that request.
None.
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/16/2020 06:10:27 PM.**#**
This information is enclosed in the CD being forwarded to Defense counsel.
This information is enclosed in the CD being forwarded to Defense counsel.
10. This information is enclosed in the CD being forwarded to Defense counsel.
11 This information is enclosed in the CD being forwarded to Defense counsel.
12. This information is enclosed in the CD being forwarded to Defense counsel.
13 This information is enclosed in the CD being forwarded to Defense counsel.
14. This information is enclosed in the CD being forwarded to Defense counsel.
15 This information is enclosed in the CD being forwarded to Defense counsel.
16. This information is enclosed in the CD being forwarded to Defense counsel.
17 This information is enclosed in the CD being forwarded to Defense counsel.
18 This information is enclosed in the CD being forwarded to Defense counsel.
19. This information is enclosed in the CD being forwarded to Defense counsel.
20. This information is enclosed in the CD being forwarded to Defense counsel.
21 This information is enclosed in the CD being forwarded to Defense counsel.
22 This information is enclosed in the CD being forwarded to Defense counsel.
23. This information is enclosed in the CD being forwarded to Defense counsel.
24 This information is enclosed in the CD being forwarded to Defense counsel.
25 This information is enclosed in the CD being forwarded to Defense counsel.
26 This information is enclosed in the CD being forwarded to Defense counsel.
27. This information is enclosed in the CD being forwarded to Defense counsel.
28 This information is enclosed in the CD being forwarded to Defense counsel.
29 This information is enclosed in the CD being forwarded to Defense counsel.
30 This information is enclosed in the CD being forwarded to Defense counsel.
31 This information is enclosed in the CD being forwarded to Defense counsel.
32 This information is enclosed in the CD being forwarded to Defense counsel.
33 This information is enclosed in the CD being forwarded to Defense counsel.
34 This information is enclosed in the CD being forwarded to Defense counsel.
35. This information is enclosed in the CD being forwarded to Defense counsel.
36. This information is enclosed in the CD being forwarded to Defense counsel.
37. This information is enclosed in the CD being forwarded to Defense counsel.
38. This information is enclosed in the CD being forwarded to Defense counsel.
39. This information is enclosed in the CD being forwarded to Defense counsel.
40. This information is enclosed in the CD being forwarded to Defense counsel.
41 This information is enclosed in the CD being forwarded to Defense counsel.
42 The Plaintiff is not in possession of any documents responsive to that request.
43. The Plaintiff is not in possession of any documents responsive to that request.
44 This information is enclosed in the CD being forwarded to Defense counsel.
45 The Plaintiff is not in possession of any documents responsive to that request.
46 The Plaintiff is not in possession of any documents responsive to that request.
47. The Plaintiff is not in possession of any documents responsive to that request.
48 Experts to be used at the time of trial have yet to be finalized.
49 Experts to be used at the time of trial have yet to be finalized.
50. Experts to be used at the time of trial have yet to be finalized.
51 Experts to be used at the time of trial have yet to be finalized.
52. This information is enclosed in the CD being forwarded to Defense counsel.
53. None.
54 None.
55. None.
56. This information is enclosed in the CD being forwarded to Defense counsel.
57. This information is enclosed in the CD being forwarded to Defense counsel.
58. To the best of Plaintiff's knowledge, Ramon Cabrera was insured by Care Plus/Medicare
#: 205731601. All subrogation liens will be provided to Defense counsel immediately upon
receipt.
59. This information is enclosed in the CD being forwarded to Defense counsel.
60. This information is enclosed in the CD being forwarded to Defense counsel.
61 None.
62 See response to Number 58.
63. The Plaintiff is not in possession of any documents responsive to that request.
64, The Plaintiff is not in possession of any documents responsive to that request.
65 This information is enclosed in the CD being forwarded to Defense counsel.
66 The Plaintiff is not in possession of any documents responsive to that request.
67. A lost wage claim is not anticipated at this time.
68 This information is enclosed in the CD being forwarded to Defense counsel.
69 The Plaintiff is not in possession of any documents responsive to that request.
70. The Plaintiff is not in possession of any documents responsive to that request.
71 The Plaintiff is not in possession of any documents responsive to that request.
72. The Plaintiff is not in possession of any documents responsive to that request.
73 See response to Number 58.
TA. None.
75 Objection. Attorney client privilege.
76. This information is enclosed in the CD being forwarded to Defense counsel.
77 This information is enclosed in the CD being forwarded to Defense counsel.
78. This information is enclosed in the CD being forwarded to Defense counsel.
79. This information is enclosed in the CD being forwarded to Defense counsel.
80. None.
81 None.
82 None.
83. This information is enclosed in the CD being forwarded to Defense counsel.
84 Experts to be used at the time of trial have yet to be finalized.
85. Experts to be used at the time of trial have yet to be finalized.
86. Experts to be used at the time of trial have yet to be finalized.
87. The Plaintiff is not in possession of any documents responsive to that request.
88. This information is enclosed in the CD being forwarded to Defense counsel.
89. See response to Number 58.
90. This information is enclosed in the CD being forwarded to Defense counsel.
91 This information is enclosed in the CD being forwarded to Defense counsel.
92 This information is enclosed in the CD being forwarded to Defense counsel.
93. This information is enclosed in the CD being forwarded to Defense counsel.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the
Florida Courts E-filing Portal: Julie W. Allison, Esq. and Kirsten K .Ullman; julie@allisonlaw.net;
kullman@ublawoffices.com; this 16" day of April, 2020.
FORD, DEAN & ROTUNDO, P.A.
Attorneys for Plaintiff
3323 NE 163” Street, Suite 605
North Miami Beach, FL 33160
Tel: (305) 670-2000
Fax: (305) 670-1353
Bill@forddean.com
Brandy@forddean.com
Service@forddean.com
By:
WI . DEAN, B.C.S.
Florida jo.: 118354
Document Filed Date
April 16, 2020
Case Filing Date
January 24, 2018
Category
Neg - Nursing Home Negligence
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Filing # 106359288 E-Filed 04/16/2020 06:10:27 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION: 21 CASE NO.: CACE-18-001878 (21) JESUS CABRERA as Personal Representative of the Estate of RAMON CABRERA, Deceased, Plaintiff, vs. JACK MICHEL, M.D., REHABILITATION CENTER AT HOLLYWOOD HILLS, LLC., and LARKIN COMMUNITY HOSPITAL, INC. d/b/a LARKIN COMMUNITY HOSPITAL, Defendant. / PLAINTIFF’S RESPONSES TO DEFENDANT’S HOLLYWOOD HILLS, LLC.’S FIRST REQUEST FOR PRODUCTION COMES NOW, the Plaintiff, JESUS CABRERA as Personal Representative of the Estate of RAMON CABRERA, Deceased, by and through his undersigned counsel, and pursuant to Rule 1.350, Fla.R.Civ.P., hereby files this, his Responses to Defendant, REHABILITATION CENTER AT HOLLYWOOD HILLS, LLC., First Request for Production served on March 17, 2020. The Plaintiff is not in possession of any documents responsive to that request. The Plaintiff is not in possession of any documents responsive to that request. The Plaintiff is not in possession of any documents responsive to that request. This information is enclosed in the CD being forwarded to Defense counsel. The Plaintiff is not in possession of any photographs responsive to that request. The Plaintiff is not in possession of any photographs responsive to that request. None. #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/16/2020 06:10:27 PM.**#** This information is enclosed in the CD being forwarded to Defense counsel. This information is enclosed in the CD being forwarded to Defense counsel. 10. This information is enclosed in the CD being forwarded to Defense counsel. 11 This information is enclosed in the CD being forwarded to Defense counsel. 12. This information is enclosed in the CD being forwarded to Defense counsel. 13 This information is enclosed in the CD being forwarded to Defense counsel. 14. This information is enclosed in the CD being forwarded to Defense counsel. 15 This information is enclosed in the CD being forwarded to Defense counsel. 16. This information is enclosed in the CD being forwarded to Defense counsel. 17 This information is enclosed in the CD being forwarded to Defense counsel. 18 This information is enclosed in the CD being forwarded to Defense counsel. 19. This information is enclosed in the CD being forwarded to Defense counsel. 20. This information is enclosed in the CD being forwarded to Defense counsel. 21 This information is enclosed in the CD being forwarded to Defense counsel. 22 This information is enclosed in the CD being forwarded to Defense counsel. 23. This information is enclosed in the CD being forwarded to Defense counsel. 24 This information is enclosed in the CD being forwarded to Defense counsel. 25 This information is enclosed in the CD being forwarded to Defense counsel. 26 This information is enclosed in the CD being forwarded to Defense counsel. 27. This information is enclosed in the CD being forwarded to Defense counsel. 28 This information is enclosed in the CD being forwarded to Defense counsel. 29 This information is enclosed in the CD being forwarded to Defense counsel. 30 This information is enclosed in the CD being forwarded to Defense counsel. 31 This information is enclosed in the CD being forwarded to Defense counsel. 32 This information is enclosed in the CD being forwarded to Defense counsel. 33 This information is enclosed in the CD being forwarded to Defense counsel. 34 This information is enclosed in the CD being forwarded to Defense counsel. 35. This information is enclosed in the CD being forwarded to Defense counsel. 36. This information is enclosed in the CD being forwarded to Defense counsel. 37. This information is enclosed in the CD being forwarded to Defense counsel. 38. This information is enclosed in the CD being forwarded to Defense counsel. 39. This information is enclosed in the CD being forwarded to Defense counsel. 40. This information is enclosed in the CD being forwarded to Defense counsel. 41 This information is enclosed in the CD being forwarded to Defense counsel. 42 The Plaintiff is not in possession of any documents responsive to that request. 43. The Plaintiff is not in possession of any documents responsive to that request. 44 This information is enclosed in the CD being forwarded to Defense counsel. 45 The Plaintiff is not in possession of any documents responsive to that request. 46 The Plaintiff is not in possession of any documents responsive to that request. 47. The Plaintiff is not in possession of any documents responsive to that request. 48 Experts to be used at the time of trial have yet to be finalized. 49 Experts to be used at the time of trial have yet to be finalized. 50. Experts to be used at the time of trial have yet to be finalized. 51 Experts to be used at the time of trial have yet to be finalized. 52. This information is enclosed in the CD being forwarded to Defense counsel. 53. None. 54 None. 55. None. 56. This information is enclosed in the CD being forwarded to Defense counsel. 57. This information is enclosed in the CD being forwarded to Defense counsel. 58. To the best of Plaintiff's knowledge, Ramon Cabrera was insured by Care Plus/Medicare #: 205731601. All subrogation liens will be provided to Defense counsel immediately upon receipt. 59. This information is enclosed in the CD being forwarded to Defense counsel. 60. This information is enclosed in the CD being forwarded to Defense counsel. 61 None. 62 See response to Number 58. 63. The Plaintiff is not in possession of any documents responsive to that request. 64, The Plaintiff is not in possession of any documents responsive to that request. 65 This information is enclosed in the CD being forwarded to Defense counsel. 66 The Plaintiff is not in possession of any documents responsive to that request. 67. A lost wage claim is not anticipated at this time. 68 This information is enclosed in the CD being forwarded to Defense counsel. 69 The Plaintiff is not in possession of any documents responsive to that request. 70. The Plaintiff is not in possession of any documents responsive to that request. 71 The Plaintiff is not in possession of any documents responsive to that request. 72. The Plaintiff is not in possession of any documents responsive to that request. 73 See response to Number 58. TA. None. 75 Objection. Attorney client privilege. 76. This information is enclosed in the CD being forwarded to Defense counsel. 77 This information is enclosed in the CD being forwarded to Defense counsel. 78. This information is enclosed in the CD being forwarded to Defense counsel. 79. This information is enclosed in the CD being forwarded to Defense counsel. 80. None. 81 None. 82 None. 83. This information is enclosed in the CD being forwarded to Defense counsel. 84 Experts to be used at the time of trial have yet to be finalized. 85. Experts to be used at the time of trial have yet to be finalized. 86. Experts to be used at the time of trial have yet to be finalized. 87. The Plaintiff is not in possession of any documents responsive to that request. 88. This information is enclosed in the CD being forwarded to Defense counsel. 89. See response to Number 58. 90. This information is enclosed in the CD being forwarded to Defense counsel. 91 This information is enclosed in the CD being forwarded to Defense counsel. 92 This information is enclosed in the CD being forwarded to Defense counsel. 93. This information is enclosed in the CD being forwarded to Defense counsel. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the Florida Courts E-filing Portal: Julie W. Allison, Esq. and Kirsten K .Ullman; julie@allisonlaw.net; kullman@ublawoffices.com; this 16" day of April, 2020. FORD, DEAN & ROTUNDO, P.A. Attorneys for Plaintiff 3323 NE 163” Street, Suite 605 North Miami Beach, FL 33160 Tel: (305) 670-2000 Fax: (305) 670-1353 Bill@forddean.com Brandy@forddean.com Service@forddean.com By: WI . DEAN, B.C.S. Florida jo.: 118354