From: David Gagne
To: Katie Perez
Subject: Re: Status
Sent: September 18, 2013 @ 10:45 AM PDTHey, Katie,
Have you received copies of mom’s medical records from Florida Hospital Deland (Fish Memorial) that you requested on September 5th?
Is there any way you could ask the external counsel working on the case for an ETA? By my estimate it’s now been at least three months that he’s been involved. I’m not asking for a deadline or anything, just wondering if he (or she?) might be able to give me a ballpark idea of how long the review will take.
Also: I know that we’ve gotten copies of the EMT records (on July 25th), the records from Halifax (on August 5th), and the ones from Woodland Terrace (on May 31st). Were you ever able to obtain copies of the records from DCF that you requested on July 29th?
Thanks,
From: Katie Perez
To: David Gagne
Subject: Florida Hospital DeLand
Sent: September 19, 2013 @ 10:20 AM PDTMr. Gagne:
Please see attached the medical records received from Florida Hospital DeLand. These have been provided to outside counsel for review.
Thank you,
Attachment: Fl Hosp DeLand.pdf
From: Katie Perez
To: David Gagne
Subject: RE: Status
Sent: September 19, 2013 @ 10:27 AM PDTThe Florida Hospital DeLand medical records arrived on Monday afternoon. I provided them to you under separate cover a moment ago.
Unfortunately, I’m not really in a position to ask for a timeline from the other attorney. Until such time as he decides there is a case to pursue, he is essentially doing us a favor by lending us his expertise and reviewing the file without billing us for his time. I will, of course, follow up with him gently if I don’t hear back within a week.
The DCF records request was a long shot. They really aren’t under any obligation to provide the report to us. If a lawsuit is filed, we can send a subpoena to them that they will be forced to comply with, but at this point we have no recourse for them not providing the documentation. I can send another letter to them and hope they turn over the report, but I would not expect much.
From: David Gagne
To: Katie Perez
Subject: Re: Status
Sent: September 19, 2013 @ 11:21 AM PDTThank you for the update, Katie. I appreciate it.
My little sister is flying into LA today and we are going to take my son to Disneyland on Sunday for what would have been our mom’s 65th birthday.
From: Katie Perez
To: David Gagne
Subject: RE: Status
Sent: September 19, 2013 @ 11:48 AM PDTI’m glad you are getting some quality time with your family. What a great way to honor your mother.