SOPHIA LINALE ET AL VS EMC MD LLC ET AL, 2022-001591-CA-01, Doc-1144-Motion-to-Compel (Fla. 11th Cir. Ct. Jun. 20, 2024) (2024)

`

`
`
`1.
`
`On April 20, 2023, the Court ordered all Plaintiffs to produce “all social media
`
`content from the date of the alleged incident” and “all photographs and videos depicting Plaintiffs
`
`… since the date of the subject incident[.].” Ex. A. All 13 original Plaintiffs produced media in
`
`response to the order. Two additional Plaintiffs added in the Fifth Amended Complaint also
`
`produced media.2
`
`2.
`
`However, Plaintiffs newly added in the Sixth Amended Complaint objected to
`
`McKesson’s request for post-incident media, only producing “photos of scarring and a
`
`representative sample of before and after photos.”3 Each Plaintiff produced only a few photos,
`
`some producing as little as one.
`
`3.
`
`The post-incident media have been key exhibits in every Plaintiff deposition. The
`
`sudden, baseless decision not to comply with the Court’s order delays this already complex
`
`litigation.
`
`4.
`
`Attorneys and parties must respect and obey court orders until reversed or vacated.
`
`See State ex rel. Schwartz v. Lantz, 440 So.2d 446, 450-51 (Fla. 3d DCA 1983) (holding that even
`
`judges must respect court orders entered under a legitimate exercise of authority).
`
`5.
`
`Photographs and video, including those posted on social media, are “highly
`
`relevant” in cases where plaintiffs seek personal injury damages. See Nucci v. Target Corp., 162
`
`So. 3d 146, 151 (Fla. 4th DCA 2015) (denying certiorari review for order compelling plaintiff’s
`
`social media). There is “no better portrayal” of an individual’s “day in the life” before and after an
`
`injury than through photographs. Id. at 152. The requested media is crucial in defending against
`
`Plaintiffs’ damages.
`
`
`2 McKesson reserves the right to object to the sufficiency of Plaintiffs’ productions.
`3 A sample response is attached as Exhibit B.
`
`
`
`2
`
`

`

`6.
`
`Plaintiffs’ refusal to comply with the Court warrants the imposition of attorney’s
`
`fees. Fla. R. Civ. Pro. 1.380(a)(4); Giller Grp., Ltd. v. Giller, 197 So. 3d 1241, 1242 (Fla. 3d DCA
`
`2016) (approving award of award attorney’s fees for successful motion to compel).
`
`WHEREFORE, McKesson requests an order compelling Plaintiffs to produce all post-
`
`incident photos, videos, and social media content in compliance with the Court’s April 20, 2023
`
`Order, and to pay McKesson’s attorney’s fees and costs incurred in bringing this motion.
`
`CERTIFICATE OF CONFERRAL
`The undersigned certifies that they met and conferred in good faith through a telephone
`
`call with Plaintiff’s counsel on June 11, 2024, describing the issues raised in this motion.
`
`
`
`CLARKE SILVERGLATE, P.A.
`5301 Blue Lagoon Drive, Suite 900
`Miami, Florida 33126
`
`Telephone: (305) 377-0700
`Facsimile: (305) 377-3001
`
`By: /s/ Spencer H. Silverglate
`
`Spencer H. Silverglate
`
`Florida Bar No. 769223
`ssilverglate@cspalaw.com
`mpedraza@cspalaw.com
`Raul Alvarez
`Florida Bar No. 1025071
`ralvarez@cspalaw.com
`rzamora@cspalaw.com
`Adisbel Hernandez
`Florida Bar No. 1038701
`ahernandez@cspalaw.com
`vceballos@cspalaw.com
`clandgraf@cspalaw.com
`
`
`Counsel for McKesson Medical-Surgical Inc.
`
`
`3
`
`
`
`
`
`
`
`

`

`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that on June 20, 2024, a true and correct copy of the foregoing
`
`document was electronically filed with the Clerk of Court using the Florida E-Filing Portal, which
`
`will electronically serve a copy on all counsel of record.
`
`Judd G. Rosen, Esq.
`Brett M. Rosen, Esq.
`Mustafa H. Dandashly, Esq.
`Kristopher R. Salado, Esq.
`GOLDBERG & ROSEN, P.A.
`One Biscayne Tower
`2 South Biscayne Blvd, Suite 3650
`Miami, Florida 33131
`T: (305) 374-4200
`pleadings@goldbergandrosen.com
`brett@goldbergandrosen.com
`mdandashly@goldbergandrosen.com
`salado@goldbergandrosen.com
`Counsel for Plaintiffs
`
`
`
`
`
`
`Kimberly A. Cook, Esq.
`DAVIS GOLDMAN, PLLC
`1441 Brickell Avenue, Suite 1400
`Miami, Florida 33131
`T: (305) 800-6673
`F: (305) 675-7880
`kcook@davisgoldman.com
`eservice@davisgoldman.com
`Counsel for Defendants Esther Marin-
`Casariego, M.D. and EMC MD, LLC
`
`
`By: /s/ Spencer H. Silverglate
`Spencer H. Silverglate
`
`
`
`4
`
`

`

`EXHIBIT A
`EXHIBIT A
`
`

`

`Filing # 171391596 E-Filed 04/20/2023 07:20:34 AM
`
`IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL
`CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
`
`CASE NO: 2022-001591-CA-01
`SECTION: CA21
`JUDGE: David C. Miller
`
`Sophia Linale et al
`Plaintiff(s)
`vs.
`
`EMC MD LLC et al
`Defendant(s)
`____________________________/
`ORDER ON MMS’S SECOND MOTION TO COMPEL DISCOVERY RESPONSES FROM
`PLAINTIFFS AND MOTION TO DEEM PLEADINGS CLOSED AND EXPEDITE
`EXPERT WITNESS DISCLOSURES
`
`THIS CAUSE came before the Court on April 14, 2023, on Defendant McKesson Medical-Surgical
`Inc.’s (“MMS”) (1) Second Motion to Compel Discovery Responses from Plaintiffs, served March
`29, 2023 (“Motion to Compel”) and (2) Motion to Deem Pleadings Closed and Expedite Expert
`Witness Disclosures, served April 13, 2023 (“Motion to Deem Pleadings Closed”). Having heard
`argument from the parties and being otherwise advised in the premises, it is hereby
`
` ORDERED AND ADJUDGED that
`
`The Motion to Deem Pleadings Closed is GRANTED. All pleadings shall be
`1.
`deemed closed 14 days after all Defendants are deposed. In addition, by August 1, 2023, Plaintiffs
`shall disclose their expert witnesses along with the information described in Florida Rule of Civil
`Procedure 1.280(b)(5). By September 1, 2023, Defendants shall disclose their expert witnesses
`along with the information described in Florida Rule of Civil Procedure 1.280(b)(5). All experts
`shall be available for deposition within 30 days following their disclosure.
`
`2.
`
`The Motion to Compel is GRANTED. Within 10 days of this Order, Plaintiffs shall:
`
`Case No: 2022-001591-CA-01
`
`Page 1 of 3
`
`

`

`a.
`
`Produce all written and electronically stored communications between them, including those
`made by and among the parents and guardians of minor Plaintiffs, since the date of the
`subject incident.
`
`b.
`
`Produce all social media content depicting or referring to Plaintiffs from the date of the
`alleged incident, including content by the parents and guardians of minor Plaintiffs, since the
`date of the subject incident.
`
`c.
`
`Produce all photographs and videos depicting Plaintiffs, including the parents and guardians
`of the minor Plaintiffs, since the date of the subject incident.
`
`d. Admit or deny MMS’s requests for admissions served on January 9, 2023.
`
`DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 20th day of April,
`2023.
`
`2022-001591-CA-01 04-20-2023 7:18 AM
`Hon. David C. Miller
`CIRCUIT COURT JUDGE
`Electronically Signed
`
`No Further Judicial Action Required on THIS MOTION
`
`CLERK TO RECLOSE CASE IF POST JUDGMENT
`
`Electronically Served:
`Brett Rosen, Esq, brett@goldbergandrosen.com
`Charles Gibson Short, shortc@kleinpark.com
`Charles Gibson Short, piersonj@kleinpark.com
`Charles Gibson Short, carrillom@kleinpark.com
`Judd Rosen, Esq, Judd@goldbergandrosen.com
`Khristopher Salado, Esq, salado@goldbergandrosen.com
`Kimberly A. Cook, kcook@davisgoldman.com
`Kimberly A. Cook, eservice@davisgoldman.com
`Kimberly A. Cook, nbauza@davisgoldman.com
`Mustafa Hasan Dandashly, pleadings@goldbergandrosen.com
`
`Case No: 2022-001591-CA-01
`
`Page 2 of 3
`
`

`

`Mustafa Hasan Dandashly, mdandashly@goldbergandrosen.com
`Mustafa Hasan Dandashly, evelyn@goldbergandrosen.com
`Raul Alvarez, ralvarez@cspalaw.com
`Raul Alvarez, jsantana@cspalaw.com
`Robert M Klein, kleinr@kleinpark.com
`Robert M Klein, piersonj@kleinpark.com
`Robert M Klein, carrillom@kleinpark.com
`Samantha Gonzalez, sgonzalez@cspalaw.com
`Spencer Hal Silverglate, ssilverglate@cspalaw.com
`Spencer Hal Silverglate, mpedraza@cspalaw.com
`Spencer Hal Silverglate, rzamora@cspalaw.com
`
`Physically Served:
`
`Case No: 2022-001591-CA-01
`
`Page 3 of 3
`
`

`

`EXHIBIT B
`EXHIBIT B
`
`

`

`Filing # 193970058 E-Filed 03/13/2024 05:11:43 PM
`
`IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI DADE
`COUNTY, FLORIDA
`
`COMPLEX LITIGATION DIVISION
`
`CASE NO.: 2022-001591-CA-01
`SOPHIA LINALE, an individual,
`DANIEL HERNANDEZ and SAMANTHA NUCHE
`as parents and legal guardians of A.H. and R.H., their
`minor children, DANIELLE MENA, an individual,
`and AILYN CUERVO and ARNOLD CUERVO, as
`parents and legal guardians of A.C., their minor child,
`ANA ISABEL FELICIANO and ARMANDO ALVAREZ,
`as parents and legal guardians of A.A., her minor child, and
`GRISEL D’ELENA and JOSEPH BRU, as parents and
`LEGAL GUARDIANS OF J.B., GIUSEPPE GALASSO,
`JULIE JEFFRIES and MARCEL ROTKER
`as parents OF I.R., MEGAN RODRIGUEZ,
`and JASON and MARIA DOWNING as parents of V.D.
`MARIA ANNARINO as parent of L.C., and DIANA
`BETANCOURT as parent of N.B., JOSE HERNANDEZ
`and ROSALY HERNANDEZ as parents and legal guardians of J.H.,
` their minor child, NICOLE ADSIDE-SYLVAIN as parent of C.S.,
`her minor child, JOICE GONZALEZ and HUMBURTO GONZALEZ
`as parents and legal guardians of J.G., their minor child,
` JESSICA PRADA, as parent and legal guardian of A.P.,
`YAIMARA ACOSTA and ALEX DURAN, as legal
`guardians of A.D. and G.G., NICHOLAS and JESSICA
`WOHL, as parents of E.W., PATRICIA CRESPO as parent
`of D.C., her minor child, MARCIA ADELSTEIN as parent
`of A.A., her minor child, LISANDRA SANTANA, as
`parent of J.S., her minor child, GABRIELLE PEREZ,
`as legal guardian of A.E., a minor, JENNIFER DE ARMAS
`as parent and legal guardian of A.B., her minor child,
`MAISBERT SOSA, as parent of M.S. her minor child,
`and ELIZABETH CAMPOS, as parent of L.C. her minor
`child,
`
`vs.
`MCKESSON MEDICAL-SURGICAL, INC., a Foreign Profit Corporation,
`ESTHER MARIN-CASARIEGO, M.D., and
`EMC MD, LLC.
`Defendants.
`_______________________________________________
`
`Plaintiffs,
`
`

`

`PLAINTIFF’S, YAIMARA ACOSTA AND ALEX DURAN AS PARENTS OF G.G.,
`REPONSE TO DEFENDANT, MCKESSON MEDICAL-SURGICAL INC’S FIRST
`REQUEST FOR PRODUCTION
`COME NOW, the Plaintiffs, YAIMARA ACOSTA and ALEX DURAN as parents of
`
`G.G., by and through the undersigned attorney, and hereby file this Response to Defendant,
`
`McKesson Medical Surgical Inc.’s First Request for Production as follows:
`
`1. Request: Complete and sign the form titled “HIPPA Compliant Authorization for the
`
`Release of Patient Information Pursuant to 45 CF 164.507,” attached hereto as Exhibit A.
`
`Response: See attached.
`
`2. Request: All notes, memoranda, correspondence (including e-mails and text messages),
`
`or any other Documents relating to all communications between the Plaintiff, or anyone
`
`on their behalf, and Dr. Esther Marin-Casariego, or anyone acting on their behalf.
`
`Response: None.
`
`3. Request: All photos and videos of the Plaintiff’s injuries allegedly caused by the
`
`Incident.
`
`Response: See photos in Plaintiff's possession.
`
`4. Request: All photos and videos depicting the treatment of the injury allegedly caused by
`
`this Incident.
`
`Response: See photos in Plaintiff's possession.
`
`5. Request: All photos and videos taken of the Plaintiff since the alleged injury through the
`
`date of receipt of this Request for Production.
`
`Response: Objection; overbroad, overburdensome, not tailored to the needs of this case,
`
`and not limited in time and scope. Plaintiff has produced photos of scarring and a
`
`representative sample of before and after photos.
`
`

`

`6. Request: All medical, hospital, physician, pharmaceutical, drug, nursing, transportation,
`
`ambulance, psychological, counseling, and other related bills evidencing expenses
`
`claimed to have been paid or incurred by Plaintiff as a result of the injuries alleged in this
`
`Action.
`
`Response: See billing records & liens, if any, in Plaintiff’s possession. Discovery is
`
`ongoing.
`
`7. Request: All medical, hospital, physician, pharmaceutical, drug, nursing, transportation,
`
`ambulance, psychological, counseling, and other related bills evidencing expenses
`
`claimed to have been paid or incurred by Plaintiff in the past ten years.
`
`Response: See billing records & liens, if any, in Plaintiff’s possession. Discovery is
`
`ongoing.
`
`8. Request: All medical, hospital, physician, pharmaceutical, drug, nursing, transportation,
`
`ambulance, psychological, counseling, and other records regarding the injuries alleged in
`
`this Action.
`
`Response: See medical records, if any, in Plaintiff’s possession. Discovery is ongoing.
`
`9. Request: All medical, hospital, physician, pharmaceutical, drug, nursing, transportation,
`
`ambulance, psychological, counseling, and other records regarding treatment Plaintiff has
`
`received in the past ten years.
`
`Response: See medical records, if any, in Plaintiff’s possession. Discovery is ongoing.
`
`10. Request: All correspondence, including e-mails and text messages, prescriptions,
`
`pharmacological records, notes, medical reports, or other written documentation received
`
`by Plaintiff, Plaintiff’s attorneys, investigators, agents, servants, or employees, from
`
`doctors, physicians, or anyone else who has rendered care and/or treatment to Plaintiff for
`
`

`

`injuries incurred as a result of the injury that is the subject of this Action.
`
`Response: None.
`
`11. Request: All correspondence, including e-mails, text messages, notes, letters, or other
`
`communications between yourself and Co-Plaintiffs.
`
`Response: Objection; overbroad, not limited in time or scope. Implicates attorney-client
`
`privilege.
`
`12. Request: All correspondence, including e-mails, text messages, notes, letters, or other
`
`communications between the Plaintiff and Co-Plaintiffs.
`
`Response: Objection; overbroad, not limited in time or scope. Implicates attorney-client
`
`privilege.
`
`13. Request: All documentary evidence of benefits or payments to Plaintiff via Medicare,
`
`Medicaid, private medical insurance, social security benefits, or any other sources as
`
`reimbursem*nt for medical expenses relating to Plaintiff’s treatment for injuries that you
`
`allege are the subject of this Action.
`
`Response: See health insurance liens in Plaintiff's possession, if any. Discovery is
`
`ongoing.
`
`14. Request: All notices and notifications of Plaintiff’s intent to claim damages from the
`
`alleged tortfeasors which have been sent to all collateral source providers.
`
`Response: See health insurance liens in Plaintiff's possession, if any. Discovery is
`
`ongoing.
`
`15. Request: All claims of lien, statements, correspondence (including e-mails and text
`
`messages), or documentation received from all providers of collateral sources asserting or
`
`waiving any claim of subrogation or reimbursem*nt.
`
`

`

`Response: See health insurance liens in Plaintiff's possession, if any. Discovery is
`
`ongoing.
`
`16. Request: All subrogation or reimbursem*nt notices, policy provisions, and claims of lien
`
`for all providers of collateral sources for medical treatment received by Plaintiff as a
`
`result of the injury that is the subject of this Action.
`
`Response: See health insurance liens in Plaintiff's possession, if any. Discovery is
`
`ongoing.
`
`17. Request: All documentation establishing the amount of money and benefits paid by all
`
`collateral sources for treatment received by the Plaintiff as a result of the injury that is the
`
`subject of this Action.
`
`Response: See health insurance liens in Plaintiff's possession, if any. Discovery is
`
`ongoing.
`
`18. Request: All Complaints and Statements of Claim filed by any medical provider against
`
`Plaintiff for any medical care which is alleged to have been rendered as a result of the
`
`injury that is the subject of this Action.
`
`Response: None.
`
`19. Request: All drafts, checks, money orders, and receipts showing payment by the Plaintiff
`
`of any hospital lien charges which are alleged to have been incurred as a result of the
`
`injury that is the subject of this Action.
`
`Response: See health insurance liens and bills, if any, in Plaintiff's possession. Discovery
`
`is ongoing.
`
`20. Request: All correspondence, including e-mails and text messages, between the Plaintiff
`
`and any Healthcare Provider, including hospitals, relating to collection of accounts,
`
`

`

`payments of bills and liens, and reimbursem*nt/subrogation rights.
`
`Response: None.
`
`21. Request: All Workers Compensation, TRICARE/Champus, Medicare, HRS Medicaid,
`
`Hospital Liens, HMO notices, PPO notices, ERIS plan, health insurance, medical
`
`payment (Med Pay), or other subrogation and reimbursem*nt rights relating to any health
`
`care rendered to Plaintiff as an alleged result of the injury that is the subject of this
`
`Action.
`
`Response: See health insurance liens in Plaintiff's possession, if any. Discovery is
`
`ongoing.
`
`22. Request: All drafts and checks showing payment by a Workers’ Compensation carrier,
`
`TRICARE/Champus, Medicare, HRS Medicaid, health insurance, HMO, PPO, ERISA
`
`plan, Med Pay plan, or any other program providing medical expenses to Plaintiff and
`
`any Healthcare Provider for the benefit of the Plaintiff relating to care for the injury that
`
`is the subject of this Action.
`
`Response: See health insurance liens in Plaintiff's possession, if any. Discovery is
`
`ongoing.
`
`23. Request: All checks, drafts, documentation, and correspondence (including e-mails and
`
`text messages) sent by the Social Security Administration or any federal, state, or local
`
`income disability provider, any public program providing disability payments, and
`
`income disability insurer to the Plaintiff for any wage loss, disability, and loss of earning
`
`capacity payments made as an alleged result of the injury that is the subject of this
`
`Action.
`
`Response: None.
`
`

`

`24. Request: Any contract or agreement by any group, organization, partnership, or
`
`corporation to provide, pay for, or reimburse the costs of hospital, medical, or their health
`
`care services for the Plaintiff over the past 10 years.
`
`Response: None.
`
`25. Request: Any complaints in any lawsuit or arbitration concerning a dispute between any
`
`collateral source providers and Plaintiff.
`
`Response: None.
`
`26. Request: All Medical Summary Notices (MSN), or any other notices, reports,
`
`statements, or other Documents from any source that describe, total, or reference any
`
`Medicare benefits that Plaintiff has received from the date of the injury that is the subject
`
`of this Action until the present.
`
`Response: None.
`
`27. Request: Documents displaying all benefits paid by Medicare for all services or supplies
`
`that your providers and suppliers billed through Medicare and are contained on your
`
`personal account history at www.mymedicare.com.
`
`Response: None.
`
`28. Request: All correspondence (including e-mails and text messages) from CMS or any
`
`other source that describes, totals, or references any liens on the claims raised in this case.
`
`Response: None.
`
`29. Request: All releases, checks, contracts, Mary Carter agreements, hold-harmless
`
`agreements, or other documentation evidencing the settlement of any claim or potential
`
`claim arising out of the same transaction or occurrence as this cause of Action.
`
`Response: None.
`
`

`

`30. Request: All documents, agreements, stipulations, or other items evidencing any
`
`agreement entered into by Plaintiff with any Healthcare Provider who has rendered care
`
`and treatment to Plaintiff at any time, which may act to limit that Healthcare Provider’s
`
`exposure in the cause of Action, preclude a cause of action being filed against that
`
`Healthcare Provider, or provide an agreement whereby that Healthcare Provider would
`
`provide certain evidence and/or testimony in connection with this cause of Action.
`
`Response: None.
`
`31. Request: All medical records, x-rays, radiological studies, physical therapy records,
`
`home nursing services records, laboratory studies, hospital records, and/or psychological
`
`records which are a result of the injury that is the subject of this litigation.
`
`Response: See medical records, if any, in Plaintiff’s possession. Discovery is ongoing.
`
`32. Request: All psychiatric, neuropsychological, or psychological records relating to
`
`treatment of Plaintiff.
`
`Response: None.
`
`33. Request: All school records, educational records, vocational records, or technical school
`
`records pertaining to Plaintiff.
`
`Response: None.
`
`34. Request: A copy of Plaintiff’s birth certificate.
`
`Response: See attached.
`
`35. Request: A copy of Plaintiff’s driver’s license.
`
`Response: See attached.
`
`36. Request: A copy of Plaintiff’s social security card.
`
`Response: See attached.
`
`

`

`37. Request: A copy of Plaintiff’s medical health insurance claim number card
`
`Response: See attached.
`
`38. Request: Any analysis of the future medical expenses that might be incurred by Plaintiff,
`
`and which would be covered by medical benefits provided by Medicare, including, but
`
`not limited to, a Medicare Set Aside allocation (MSA).
`
`Response: None in Plaintiff’s possession.
`
`39. Request: All social media posts, including on Facebook, Twitter, LinkedIn, Snap Chat,
`
`Instagram, Tik Tok and others pertaining to the allegations of the Complaint.
`
`Response: Objection; overbroad, overburdensome, not tailored to the needs of this case,
`
`and not limited in time and scope. Plaintiff has produced photos of scarring and a
`
`representative sample of before and after photos.
`
`40. Request: All social media posts, including on Facebook, Twitter, LinkedIn, Snap Chat,
`
`Instagram, Tik Tok, and other sites, that you posted since Plaintiff incurred the injury
`
`alleged in the Complaint.
`
`Response: Objection; overbroad, overburdensome, not tailored to the needs of this case,
`
`and not limited in time and scope. Plaintiff has produced photos of scarring and a
`
`representative sample of before and after photos.
`
`41. Request: All social media posts, including on Facebook, Twitter, LinkedIn, Snap
`
`Chat, Instagram, Tik Tok, and other sites, that Plaintiff posted since May 2021.
`
`Response: Objection; overbroad, overburdensome, not tailored to the needs of this case,
`
`and not limited in time and scope. Plaintiff has produced photos of scarring and a
`
`representative sample of before and after photos.
`
`

`

`42. Request: All Documents, photographs, films, movies, or videotapes of Plaintiff since
`
`May 2021.
`
`Response: Objection; overbroad, overburdensome, not tailored to the needs of this case,
`
`and not limited in time and scope. Plaintiff has produced photos of scarring and a
`
`representative sample of before and after photos.
`
`43. Request: All diaries, journals, logs, or other written materials you have kept that relate to
`
`the Incident.
`
`Response: None.
`
`44. Request: All sales literature, advertising, promotional material, technical literature,
`
`warnings, material safety data sheets, labels, product records, shipping records, invoices
`
`purchase orders, marketing records, sales, records, or other Documents which relate to
`
`any use of needles, syringes, or equipment for intravenous administration.
`
`Response: None.
`
`45. Request: A copy of your retention agreements with all attorneys representing you in this
`
`Action.
`
`Response: Objection; work product.
`
`46. Request: A signed insurance records authorization in the form attached.
`
`Response: See response to #1.
`
`Request: A signed education records authorization in the form attached.
`
`Response: See response to #1.
`
`47. Request: A signed mental health records authorization in the form attached.
`
`Response: See response to #1.
`
`
`
`

`

`48. Request: All Documents relied upon to answer Defendant’s Interrogatories to you served
`
`contemporaneously with this Request for Production.
`
`Response: See attached Dropbox link.
`
`
`
`CERTIFICATE OF SERVICE
`
`
`WE HEREBY CERTIFY that a true and correct copy of the foregoing was served by
`Electronic Service via the Florida Courts E-filing E-portal pursuant to the Supreme Court
`Administrative Order AOSC13-49 on this 13 day of March 2024.
`
`
`GOLDBERG & ROSEN, P.A.
`Counsel for Plaintiff
`One Biscayne Tower
`2 South Biscayne Blvd, Suite 3650
`Miami, Florida 33131
`Tel:(305) 374-4200 / Fax:(305) 374-8024
`/s Mustafa H. Dandashly
` BY: ____________________________________
`Judd G. Rosen, Esq., Fla. Bar No. 0458953
`Mustafa H. Dandashly, Esq., Fla. Bar No. 118159
`Primary E-mail: pleadings@goldbergandrosen.com
`Secondary E-mails: mdandashly@goldbergandrosen.com
`
`