KENNETH SHEPPARD -VS- ADVENTIST HEALTH SYSTEM SUNBELT I

2. All statutorily required conditions precedent to the maintenance of this action, have been performed, have occurred, or have been waived. All requirements of applicable Florida Statutes have timely been complied with prior to the filing of this action.

3. There has been a reasonable investigation to determine whether there are grounds for a good faith belief that there has been negligence in the care and treatment rendered by Defendants in this case, which gives rise to this action.

4. Plaintiffs did not know, nor reasonably could have known, that the injuries sustained by KENNETH SHEPPARD were the result of medical malpractice at the time the injury occurred or for some time thereafter.

5. Defendant ADVENTIST HEALTH SYSTEM/SUNBELT, INC. D/B/A ADVENT HEALTH ALTAMONTE SPRINGS (hereinafter "ADVENTHEALTH ALTAMONTE SPRINGS") is located in and conducts business in Seminole County, Florida.

6. Defendant, FLORIDA CARDIOLOGY, P.A. conducts business in Seminole County, Florida.

7. Defendant, CENTRAL FLORIDA HOSPITALIST PARTNERS, P.A., conducts business in Seminole County, Florida.

8. Defendant, PRIAMVADA SINGH, M.D., (hereinafter "Dr. SINGH") is a physician licensed to practice medicine in the state of Florida.

9. Defendant, SANDEEP BAJAJ, M.D., (hereinafter "Dr. BAJAJ") is a physician licensed to practice medicine in the state of Florida.

10. Defendant, HARISH PATIL, M.D. (hereinafter "Dr. PATIL") is a physician licensed to practice medicine in the state of Florida.

11. Ashkan Ghaneie, M.D. (hereinafter "Dr. Ghaneie") is a physician licensed to practice medicine in the state of Florida.

12. Midhir Patel, M.D. (hereinafter "Dr. Patel") is a physician licensed to practice medicine in the state of Florida.

13. At all times material hereto, FLORIDA CARDIOLOGY, P.A., CENTRAL FLORIDA HOSPITALIST PARTNERS, P.A., Dr. SINGH, Dr. BAJAJ, Dr. PATIL, Florida Hospital Medical Group, Dr. Ghaneie, and Dr. Patel were agents, actual, or apparent, and/or employees of ADVENTIST HEALTH SYSTEM/SUNBELT, INC. D/B/A ADVENT HEALTH ALTAMONTE SPRINGS.

14. At all times material hereto, Defendants, Dr. BAJAJ and Dr. PATIL were employees of FLORIDA CARDIOLOGY, P.A.

15. At all times material hereto, Defendant, Dr. SINGH was an employee of CENTRAL FLORIDA HOSPITALIST PARTNERS.

16. At all times material hereto, Dr. Ghaneie and Dr. Patel were employees of Florida Hospital Medical Group.

17. At all times material hereto, ADVENTIST HEALTH SYSTEM/SUNBELT, INC. D/B/A ADVENT HEALTH ALTAMONTE SPRINGS, FLORIDA CARDIOLOGY, P.A., CENTRAL FLORIDA HOSPITALIST PARTNERS, P.A., PRIAMVADA SINGH, M.D., SANDEEP BAJAJ, M.D., HARISH PATIL, M.D., Florida Hospital Medical Group, Ashkan Ghaneie, M.D., and Midhir Patel, M.D. had a duty to provide medical treatment and hospital care in a reasonable manner to their patients.

18. At all times material hereto, Defendants and their employees, agents, partners, and joint ventures had a duty to provide medical treatment and care in a reasonable