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Filing # 121556687 E-Filed 02/17/2021 01:39:25 PM
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).
/
NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersigned, as counsel for Defendant,
UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE
CENTER, a Florida Public Body Corporate, will take the deposition upon oral
examination of the following witness, at the date, time and place hereinafter set forth:
WITNESS: John W. Shore, M.D.
DATE: Friday, February 19, 2021
TIME: 2:00 p.m. Eastern Time / 1:00 p.m. Central Time
PLACE: Via Zoom (link to be provided)
upon oral examination before Scribe Associates, Inc., Court Reporters, or any other
Notary Public or officer authorized by law to take depositions in the State of Florida.
The oral examination will continue from day to day until testimony shall be completed.
The deposition is being taken for the purpose of discovery, for use at trial or for such
other purpose as authorized by law and the Rules of Civil Procedure.
"2020 CA 001350" 121556687 Filed at Alachua County Clerk 02/17/2021 01:39:29 PM ESTThe Witness shall have with him at the time of the deposition the items listed on
the attached Schedule “A.”
HIPAA Certificate - This certifies that this subpoena has been issued in compliance with the Health
Insurance Portability and Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR
164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.310, Fla. R. Civ. P. The
Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient
listed above by sending his/her attorney, a notice of the taking of this deposition for which this subpoena
has been issued and which included sufficient information about the litigation to permit the
Plaintiff/Patient to raise an objection to the court or administrative tribunal. The Plaintiff/Patient may
raise an objection pursuant to Rule 1.280(c), Fla. R. Civ. P. and no testimony will be taken nor will
documents be produced until said objections, if any, have been resolved.
PLEASE BE GOVERNED ACCORDINGLY.
CERTIFICATE OF SERVICE
I hereby certify that on this 17" 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
/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.ce:
Scribe Associates, Inc.
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 CorporateSCHEDULE “A”
PATIENT: Brenda Snow
DATE OF BIRTH: XX/XX/XXXX
SOCIAL SECURITY NUMBER: XXX-XX-XXXX
1, Your current Curriculum Vitae.
2. All certificates, degrees or other documentation related to your education,
experience and training in duties identified in §766.110, Fla. Stat., including those
related to comprehensive risk management.
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Filing # 121556687 E-Filed 02/17/2021 01:39:25 PM 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). / NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned, as counsel for Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate, will take the deposition upon oral examination of the following witness, at the date, time and place hereinafter set forth: WITNESS: John W. Shore, M.D. DATE: Friday, February 19, 2021 TIME: 2:00 p.m. Eastern Time / 1:00 p.m. Central Time PLACE: Via Zoom (link to be provided) upon oral examination before Scribe Associates, Inc., Court Reporters, or any other Notary Public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until testimony shall be completed. The deposition is being taken for the purpose of discovery, for use at trial or for such other purpose as authorized by law and the Rules of Civil Procedure. "2020 CA 001350" 121556687 Filed at Alachua County Clerk 02/17/2021 01:39:29 PM ESTThe Witness shall have with him at the time of the deposition the items listed on the attached Schedule “A.” HIPAA Certificate - This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.310, Fla. R. Civ. P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney, a notice of the taking of this deposition for which this subpoena has been issued and which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c), Fla. R. Civ. P. and no testimony will be taken nor will documents be produced until said objections, if any, have been resolved. PLEASE BE GOVERNED ACCORDINGLY. CERTIFICATE OF SERVICE I hereby certify that on this 17" 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 /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.ce: Scribe Associates, Inc. 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 CorporateSCHEDULE “A” PATIENT: Brenda Snow DATE OF BIRTH: XX/XX/XXXX SOCIAL SECURITY NUMBER: XXX-XX-XXXX 1, Your current Curriculum Vitae. 2. All certificates, degrees or other documentation related to your education, experience and training in duties identified in §766.110, Fla. Stat., including those related to comprehensive risk management.