IN THE CIRCUIT COURT OF THE 15TH
`JUDICIAL CIRCUIT IN AND FOR PALM
`BEACH COUNTY, FLORIDA
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`CASE NO.: 50-2021-CA-010518 XXXXMB
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`SUSAN M. FRISCIA, individually, and SUSAN M.
`FRISCIA as natural guardian and next friend of
`AALIYAH MOHAIDEEN and SOFIA MOHAIDEEN, her
`minor daughters,
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` Plaintiffs,
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`v.
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`AKUMIN, CORP., a foreign profit corporation,
`ADVANCED DIAGNOSTIC GROUP LLC, f/k/a ADG
`ACQUISITION HOLDINGS, LLC, a Florida limited
`liability company, ADVANCED DIAGNOSTIC
`RESOUCES LLC, a Florida limited laibility company,
`CLARITY RADIOLOGY LLC a Florida limited liability
`company, DAVID ROBERT PRIEST, M.D., MAMATA
`MYNENI, M.D., EAR NOSE AND THROAT
`ASSOCIATES OF SOUTH FLORIDA, P.A., a Florida for
`profit corporation, JOHN LI, M.D., P.A. a Florida for
`profit corporation, JOHN LI, M.D., JARED BRUNK, PA-
`C, JUPITER IMAGING ASSOCIATES, INC., a Florida for
`profit corporation, MICHAEL LEE CLARK, DO,
`JUPITER MEDICAL CENTER, INC. a Florida
`corporation, PALM BEACH NEUROSURGERY LLC, a
`Florida limited liability company, and RAMIN M.
`ABDOLVAHABI M.D.,
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` Defendants,
`______________________________________________________/
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`PLAINTIFF’S NOTICE OF VIDEOTAPED DEPOSITION DUCES TECUM OF
`NICHOLAS SUITE, M.D.
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`PLEASE TAKE NOTICE that the undersigned attorney will take the
`remote videotaped deposition of the following person(s), upon oral examination
`before U.S. Legal Court Reporters, notaries public, or any other notary public
`or officer authorized by law to take videotaped depositions in the State of
`Filing # 202297033 E-Filed 07/11/2024 09:30:21 AM
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 07/11/2024 09:30:21 AM ***
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`Florida, Via Zoom. The videotaped deposition will be taken until completed.
`Please note further that pursuant to F.R.C.P. 1.330, this deposition is being
`taken for the purpose of discovery, for use at trial and for such other purposes
`as are permitted under the applicable Statutes or the Rules of Court. This
`deposition shall be videotaped pursuant to Fla.R.Civ.P. 1.310(4):
`WITNESS: Nicholas Suite, M.D.
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`DATE AND TIME: August 20, 2024, at 1:00 P.M. EST
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`LOCATION: Zoom link to be provided
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`THE WITNESS IS REQUIRED TO BRING THE FOLLOWING
`DOCUMENTS TO THE DEPOSITION:
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`SEE ATTACHED SCHEDULE “A” DUCES TECUM REQUESTS
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`At the above date and time, the Plaintiffs will take the remote videotaped
`deposition by oral examination for purposes of discovery, for use at trial, and
`for the use as evidence is said cause or both.
`Said remote videotaped deposition will be taken before a Notary Public or
`any officer authorized to administer oaths by the laws of the State of Florida
`and a person who is neither a relative nor employee nor attorney nor counsel of
`any of the parties nor of such attorney or counsel and who is not financially
`interested in the action.
` Said videotaped deposition is to be taken pursuant to the Florida Rules
`of Civil Procedure in such cases as provided. The said oral examination will
`continue from hour to hour and from day to day until completed.
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`[Certificate of Service on next page]
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`CASE NO.: 50-202 l-CA-010518 XXXXMB
`CERTIFICATE OF SERVICE
`WE HEREBY CERTIFY that a true and correct copy of the foregoing was
`electronically filed with the Florida Courts E-Filing Portal on July 11, 2024, will
`serve a copy to all counsel of record with an electronic mail account listed.
`The Law Offices of Maria L. Rubio, P.A.
`Attorneys for the Plaintiffs
`9100 South Dadeland Boulevard
`One Datran Center, Suite 910
`Miami, Florida 33156
`Tel: 305-670-1164
`Fax: 305-230-4010
`For Service of pleadings & documents:
`Pleadings@marialrubio.com
`By: /s/ Maria L. Rubio_
`MARIA L. RUBIO
`Florida Bar No.: 623891
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`SCHEDULE “A” DUCES TECUM REQUESTS
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`1. A professional resume or curriculum vitae summarizing your
`professional qualifications.
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`2. Copies of all scientific and technical publications authored by you.
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`3. Copies of all scientific publications, technical publications, treaties,
`standards and/or guidelines either reviewed and/or relied upon by you
`and/or that are relevant to any issue in this case.
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`4. All-time records, diaries, and bills prepared and rendered in connection
`with your investigation and evaluation of the issues involved in the
`lawsuit.
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`5. Your complete file in connection with your investigation and evaluation of
`the issues involved in the lawsuit, including but not limited to:
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`x All documents and correspondence furnished to you by anyone;
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`x All documents and notes obtained or created by you;
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`x A list of all depositions reviewed in your evaluation of the issues
`involved in the lawsuit.
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`x All documents you reviewed, referred to, or relied upon in arriving
`at any of your opinions or conclusions concerning the issues
`involved in the lawsuit, including but not limited to summary of
`depositions or evidence, all scientific and technical articles,
`publications, codes, standards, and other literature;
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`x All models, illustrations, photographs, or other exhibits or
`documents of any kind which you intend or contemplate using to
`explain, illustrate, or support your testimony at trial.
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`6. Any and all documents evidencing the number of times you have been
`retained by the Defense firm in this case in the past five (5) years and the
`revenue generated there from.
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`7. A list of cases in which you have testified at deposition and/or trial in the
`past five (5) years in the capacity as an expert witness.
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`8. Any and all documents and/or records evidencing information that is
`permitted to be discovered under Rule 1.280(b)(4), Fla.R.Civ.P.
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`9. Any and all documents evidencing communications, including by
`electronic means, by and between you and any and all other persons or
`entities in connection with any opinions you have formed, or have been
`asked to form for this action.
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`10. Any and all reports, including drafts thereof, prepared by or for you, in
`whole or in part, in connection with this action.
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