Preview
Filing # 79897499 E-Filed 10/25/2018 05:52:08 PM
IN THE CIRCUIT COURT OF THE
9TH JUDICIAL CIRCUIT IN AND
FOR ORANGE COUNTY, FLORIDA
CHRISTINE DEMELLO, Case No.: 2017-CA-007822-O
Plaintiff,
vs.
RICHARD A. O'NEAL, JR. AND
LESLEY O'NEAL,
Defendant.
_____________________________/
NOTICE OF TAKING DEPOSITION DUCES TECUM OF RONALD
LANDAU, M.D.
(Uniset with Aimee at OC)
YOU are hereby notified that the Defendant, RICHARD A. O'NEAL, JR.
AND LESLEY O'NEAL, in the above styled cause will take the deposition by oral
examination for purposes of discovery and for use as evidence in said cause, or both,
of:
WITNESS: Ronald Landau, M.D.
DATE: November 30, 2018
TIME: 4:00 p.m.
LOCATION: Premiere Medical Imaging
8903 Glades Road
Boca Raton, FL
Said deposition will be taken before Orange Legal of Florida, and said oral
examination will continue from hour to hour and from day to day until completed.
The deposition is being taken for the purpose of discovery (for use at trial) or both
of the foregoing, or for such other purposes as are permitted under the applicable
and governing rules, pursuant to Florida Rules of Civil Procedure.
*The deponent is hereby directed to bring at said time and place the following:
ANY AND ALL DOCUMENTS, RECORDS, NOTES LOGS OR OTHER
WRITTEN MATERIAL, INCLUDING THAT WHICH IS
ELECTRONICALLY STORED, PERTAINING TO Christine DeMello
[PLEASE CONTACT THE UNDERSIGNED FOR DOB OR SSN] and all
records to present; INCLUDING, BUT NOT LIMITED TO THE
FOLLOWING:
1. All medical records, office notes, doctors’ and nurses’ notes, and all
other data pertaining to the diagnosis, treatment, and care of the above
patient, rendered by the above physician and/or facility;
2. All medical records, office records, doctors’ and nurses’ notes, and all
other data pertaining to the diagnosis treatment and care of the above
patient, rendered by any other health care providers that are in the
possession of the above physician and/or facility;
3 Any and all notes, logs, records or memorandum regarding any
communications between any employees or personnel from the above
physician and/or facility and Christine DeMello or his or her attorneys
/ or employees or personnel from his or her attorneys office.
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Case No. 2017-CA-007822-O
4. All reports rendered by the witness to any party concerning the
diagnosis, care and treatment of the above patient;
5. All reports or correspondence prepared for attorneys by the above
physician and/or facility, and all correspondence received by the
above physician and/or facility;
6. All patient information forms or questionnaires, or any other
information provided by the above patient;
7. Any bills for services rendered by the above physician and/or facility
pertaining to the diagnosis, treatment, and care of the above patient;
8. Any statements indicating the total amount of the bill that has been
paid and by whom;
9. Any and all x-rays, MRI’s, Ct Scans or other radiographic films taken
of the above patient by the above physician and/or facility or by any
other health care providers that are in the possession of the above
physician and/or facility;
10. Every written piece of paper included within the above patients’ chart,
including a copy of any notations of the file jacket;
11. Any MRI reports and/or studies performed;
12. A copy of the curriculum vitae of the above physician;
13. A copy of any and all contracts (including addendums) between you and/or
your office and any entity providing health insurance benefits to the above
patient (including but not limited to any health insurance company, health
maintenance organization, medicare, etc.) together with any fee or contract
rate schedules applicable at the time of the services being rendered to the
above patient.
14. A copy of any and all letters of protection, medical liens, or any other
similar agreement.
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Case No. 2017-CA-007822-O
15. All records requested should be all inclusive and should in no way be
limited to one incident.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by E-Mail this 25th day of October 2018 to: W. Doug Martin, Esq.,
Morgan & Morgan, P.A., 20 N. Orange Ave., Ste. 1600, PO Box 4979, Orlando,
FL 32801-4624 at dmartin@forthepeople.com and apratt@forthepeople.com.
ROIG LAWYERS
7380 Sand Lake Road, Suite 600
Orlando, FL 32819
(954) 462-0330 / (954) 462-7798 Fax
LitigationPleadings@RoigLawyers.com
swolfe@roiglawyers.com
BY: /s/ Scharome R. Wolfe, Esq.
SCHAROME R. WOLFE, ESQ.
Florida Bar No. 672947
SRW/abh
Cc: Orange Legal
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Case No. 2017-CA-007822-O
Preview
Filing # 79897499 E-Filed 10/25/2018 05:52:08 PM IN THE CIRCUIT COURT OF THE 9TH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CHRISTINE DEMELLO, Case No.: 2017-CA-007822-O Plaintiff, vs. RICHARD A. O'NEAL, JR. AND LESLEY O'NEAL, Defendant. _____________________________/ NOTICE OF TAKING DEPOSITION DUCES TECUM OF RONALD LANDAU, M.D. (Uniset with Aimee at OC) YOU are hereby notified that the Defendant, RICHARD A. O'NEAL, JR. AND LESLEY O'NEAL, in the above styled cause will take the deposition by oral examination for purposes of discovery and for use as evidence in said cause, or both, of: WITNESS: Ronald Landau, M.D. DATE: November 30, 2018 TIME: 4:00 p.m. LOCATION: Premiere Medical Imaging 8903 Glades Road Boca Raton, FL Said deposition will be taken before Orange Legal of Florida, and said oral examination will continue from hour to hour and from day to day until completed. The deposition is being taken for the purpose of discovery (for use at trial) or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules, pursuant to Florida Rules of Civil Procedure. *The deponent is hereby directed to bring at said time and place the following: ANY AND ALL DOCUMENTS, RECORDS, NOTES LOGS OR OTHER WRITTEN MATERIAL, INCLUDING THAT WHICH IS ELECTRONICALLY STORED, PERTAINING TO Christine DeMello [PLEASE CONTACT THE UNDERSIGNED FOR DOB OR SSN] and all records to present; INCLUDING, BUT NOT LIMITED TO THE FOLLOWING: 1. All medical records, office notes, doctors’ and nurses’ notes, and all other data pertaining to the diagnosis, treatment, and care of the above patient, rendered by the above physician and/or facility; 2. All medical records, office records, doctors’ and nurses’ notes, and all other data pertaining to the diagnosis treatment and care of the above patient, rendered by any other health care providers that are in the possession of the above physician and/or facility; 3 Any and all notes, logs, records or memorandum regarding any communications between any employees or personnel from the above physician and/or facility and Christine DeMello or his or her attorneys / or employees or personnel from his or her attorneys office. Page 2 of 4 Case No. 2017-CA-007822-O 4. All reports rendered by the witness to any party concerning the diagnosis, care and treatment of the above patient; 5. All reports or correspondence prepared for attorneys by the above physician and/or facility, and all correspondence received by the above physician and/or facility; 6. All patient information forms or questionnaires, or any other information provided by the above patient; 7. Any bills for services rendered by the above physician and/or facility pertaining to the diagnosis, treatment, and care of the above patient; 8. Any statements indicating the total amount of the bill that has been paid and by whom; 9. Any and all x-rays, MRI’s, Ct Scans or other radiographic films taken of the above patient by the above physician and/or facility or by any other health care providers that are in the possession of the above physician and/or facility; 10. Every written piece of paper included within the above patients’ chart, including a copy of any notations of the file jacket; 11. Any MRI reports and/or studies performed; 12. A copy of the curriculum vitae of the above physician; 13. A copy of any and all contracts (including addendums) between you and/or your office and any entity providing health insurance benefits to the above patient (including but not limited to any health insurance company, health maintenance organization, medicare, etc.) together with any fee or contract rate schedules applicable at the time of the services being rendered to the above patient. 14. A copy of any and all letters of protection, medical liens, or any other similar agreement. Page 3 of 4 Case No. 2017-CA-007822-O 15. All records requested should be all inclusive and should in no way be limited to one incident. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E-Mail this 25th day of October 2018 to: W. Doug Martin, Esq., Morgan & Morgan, P.A., 20 N. Orange Ave., Ste. 1600, PO Box 4979, Orlando, FL 32801-4624 at dmartin@forthepeople.com and apratt@forthepeople.com. ROIG LAWYERS 7380 Sand Lake Road, Suite 600 Orlando, FL 32819 (954) 462-0330 / (954) 462-7798 Fax LitigationPleadings@RoigLawyers.com swolfe@roiglawyers.com BY: /s/ Scharome R. Wolfe, Esq. SCHAROME R. WOLFE, ESQ. Florida Bar No. 672947 SRW/abh Cc: Orange Legal Page 4 of 4 Case No. 2017-CA-007822-O