UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

GREGORY A. LADELE, D.O.,

Plaintiff,

v. CASE NO. 4:20-cv-00080-MW-CAS

MHM HEALTH PROFESSIONALS, LLC,

f/k/a MHM HEALTH PROFESSIONALS,

INC., 

Defendant.

 /

PLAINTIFF’S STATEMENT

OF COMPLIANCE WITH RULE 26

Plaintiff, GREGORY A. LADELE, D.O., makes the following

disclosures in accordance with Rule 26(a)(1)(A)(i-iii) and 26(a)(1)(C),

Federal Rules of Civil Procedure:

A. Rule 26(a)(1)(A)(i),Federal Rules of Civil Procedure, requires

disclosure of the name and, if known, the address and telephone number

of each individual likely to have discoverable information relative to

the disputed facts alleged with particularity in the pleadings,

identifying the subjects of the information. Plaintiff has conducted the

reasonable inquiry required under Rule 26(g), and, to the best of the

Plaintiff’s knowledge, information and belief, the disclosure is complete

and correct as of the time that it is made. Plaintiff, however, reserves

the right to supplement this list upon discovery of additional

information which may be relevant to this action:

1. Plaintiff

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2. All persons identified by Defendant in its Rule 26 disclosures.

Plaintiff relies on the information provided by Defendant in its

rule 26 disclosures as to the knowledge of each such witness

about claims and defenses. Plaintiff will supplement this report 

if needed after depositions and additional information is gathered.

3. All persons identified by Defendant and Plaintiff in any answers

to any interrogatories. Plaintiff relies on the information

provided by Defendant about the role and relevant knowledge

held by each witness and will supplement this response if and

when additional information is obtained.

4. All persons noticed and/or deposed during discovery. Plaintiff 

lists this category of potential witnesses in an abundance of

caution. To Plaintiff’s knowledge no one has yet been noticed

for deposition. Plaintiff anticipates that witnesses on

Defendant’s Rule 26 disclosure, as well as the Plaintiff, will be

deposed. At this point, Plaintiff relies on Defendant’s Rule 26 

disclosure.

5. All records custodians of any and all records Plaintiff seeks to

introduce as evidence at trial. Plaintiff lists this category in an

abundance of caution. Plaintiff anticipates that the parties will

cooperate in authenticating documents and that records

custodians will not be necessary. However, in the event they are,

Plaintiff will call records custodians asto any and every document

produced during this case whether from the parties or third

parties, as needed to authenticate documents that are not

otherwise stipulated as authentic by the parties.

6. One or more of Plaintiff’s family members and personal friends, 

having knowledge of emotional damages occasioned to Plaintiff 

by Defendant’s activities as follows, as well as the work ethic and 

character of Plaintiff:

None

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7. The following doctors may have knowledge and opinions they 

have regarding treatment of the Plaintiff:

None

8. The following current and former employees of Defendant may 

have knowledge of Plaintiff's work performance and/or 

knowledge of Defendant's discrimination against Plaintiff:

Carol Abbott

Nurse Practitioner

c/o Defendant

(508) 410-4282

Has knowledge of Priscilla Roberts’ lack of professionalism 

including her history of yelling at employees and being 

confrontational; has knowledge of providing the mortality review 

for the patient whom Plaintiff asked to be transferred from the 

Infirmary to the Hospital which she failed to do and the patient 

died the following day; may have knowledge of other claims and 

defenses in this matter.

Errol Campbell

Regional Medical Director (Region#2)

c/o Defendant

(850) 228-5279

Has knowledge of concerns about Plaintiff’s salary being higher 

than the State Medical Director’s, Dr. Daniel Cherry; has 

knowledge of preferential treatment of others related to Plaintiff’s 

vacation coverage; has knowledge of being aware of Plaintiff’s 

concerns related to consistency amongst Regional Medical 

Directors; has knowledge of emails confirming delay of receipt of 

patient who was expected to receive treatment of Hepatitis C; may 

have knowledge of other claims and defenses in this matter.

Dr. Saint Charles

Hospitalist/Full-Time

c/o Defendant

(954) 793-5829

Has knowledge of working at the hospital and can attest to the 

conditions of the care provided there along with efforts to bring 

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that to the attention of Upper Level Management; has knowledge 

of concerns related to healthcare delivery which was not 

community standard; has knowledge that this was one of 

Plaintiff’s major concerns which he expressed to Upper Level 

Management on several occasions; may have knowledge of other 

claims and defenses in this matter.

Dr. Daniel Cherry III

State Medical Director

c/o Defendant

Has knowledge of Plaintiff reporting on clinical matters directly 

to him; has knowledge of forcing Plaintiff to be on-call by 

telephone during his vacations and was frequently required to 

manage clinical problems during the day; has knowledge of 

Plaintiff being denied compensation for working during this time; 

has knowledge of the Defendant’s chronic short staffing problems 

at RMC; may have knowledge of other claims and defenses in this 

matter.

Dr. Jean Dure

PRN Provider

c/o Defendant

(401) 749-6019

Has knowledge of concerns related to healthcare delivery 

conditions which were not addressed by Upper Level 

Management; may have knowledge of other claims and defenses 

in this matter.

Dr. Josephine Eady

Hospital Administrator

c/o Defendant

Has knowledge of unprofessional behaviors involving treatment 

and lack of professional behavior during Plaintiff’s time as 

Regional Medical Director; has knowledge of preferential 

treatment shown to Priscilla Roberts which made it difficult for 

many employees to perform their job duties with people of color 

having the most arduous time with her; has knowledge of Roberts’ 

unprofessional comments in the workplace; has knowledge of 

Roberts being reprimanded by her supervisor for those comments; 

may have knowledge of other claims and defenses in this matter.

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James Hankerson

Director of Nursing

c/o Defendant

(352) 672-1096

Has knowledge of writing a letter regarding concerns about not 

meeting current nursing standards; has knowledge of Plaintiff’s 

concerns about being short-staffed; may have knowledge of other 

claims and defenses in this matter.

Latoya Jenkins

Medical Records 

c/o Defendant

Has knowledge of witnessing Priscilla Roberts hiding medical 

records in which Plaintiff had made a direct order to have a patient 

placed in the hospital for concerns related to psychiatric problems; 

has knowledge of Plaintiff’s orders not being followed and the 

patient dying the following day from hemorrhaging; may have 

knowledge of other claims and defenses in this matter.

Krissy Kirkland

RN/Urgent Care

c/o Defendant

(386) 266-9686

Has knowledge of telling Plaintiff she felt uncomfortable writing 

a letter that alluded to her being asked to do something against her 

will by Plaintiff; has knowledge of unprofessional behavior by 

Priscilla Roberts in the workplace; may have knowledge of other 

claims and defenses in this matter.

Victoria Love

Vice President of Operations

c/o Defendant

Has knowledge of Plaintiff’s email to her, Dr. Cherry and Dr. Jeff 

Keller on or about January 31, 2017 regarding his grave concerns 

of short-staffing at the RMC; has knowledge of participating in 

the decision to terminate Plaintiff; may have knowledge of other 

claims and defenses in this matter.

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Lisa Lynch

Human Resources Representative

c/o Defendant

Has knowledge of being present when Plaintiff was terminated by 

the Defendant; may have knowledge of other claims and defenses 

in this matter.

Dr. (fnu) Pouparinas

Staff Provider

c/o Defendant

(251) 359-8101

Has knowledge of issues with the conditions of the facility and the 

lack of response from Upper Level Management to address those 

issues; may have knowledge of other claims and defenses in this 

matter.

Priscilla Roberts

Health Services Administrator-Outpatient

c/o Defendant

Has knowledge of the failed audits of the Outpatient Clinic under 

her supervision due to her mismanagement; has knowledge of 

using racial slurs against RMC employees; may have knowledge 

of other claims and defenses in this matter.

Dr. (fnu) Simeon, M.D.

PRN Provider

c/o Defendant

(954) 367-7554

Has knowledge of concerns related to healthcare delivery which 

were not community standard; has knowledge that this was one of 

Plaintiff’s major concerns which he expressed to Upper Level 

Management; may have knowledge of other claims and defenses 

in this matter.

(fnu) Smith

Warden, RMC Facility

c/o Defendant

Has knowledge of being involved in the conversation and meeting 

to approve patient being transferred from the Infirmary to the 

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Hospital, a discussion that included Priscilla Roberts; may have 

knowledge of other claims and defenses in this matter.

Tamara Taylor

Regional Director of Operations

c/o Defendant

Has knowledge of terminating Plaintiff on September 5, 2017 and 

refusing to provide a reason for it; has knowledge of Plaintiff’s 

concerns about the Outpatient Unit’s failed audits due to 

mismanagement; has knowledge of Plaintiff’s requests to work a 

four day/ten hour shift which was denied but granted to Dr. Chris 

Hadadd, an older Caucasian physician who was hired after 

Plaintiff; may have knowledge of other claims and defenses in this 

matter.

Dr. Jacqueline Williams, M.D.

PRN Provider

c/o Defendant

(352) 538-5228

Has knowledge of her concerns related to healthcare delivery 

which was not community standard; has knowledge of this being 

one of Plaintiff’s major issues which he conveyed to Upper Level 

Management; may have knowledge of other claims and defenses 

in this matter.

B. Rule 26(a)(1)(A)(ii), Federal Rules of Civil Procedure,

requires disclosure of a copy or a description by category and location of, 

all documents, data, compilations, and tangible things in the possession,

custody or control of the party that are relevant to the disputed facts

alleged with particularity in the pleadings. Plaintiff reserves the right to

supplement this list as additional information becomes available. Plaintiff

has performed a good faith examination of the pleadings and of all 

documents in Plaintiff’s possession and makes the following disclosure of

documents that may be relevant:

1. Plaintiff’s documents to and from EEOC and FCHR.

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C. Rule 26(a)(1)(A)(iii),Federal Rules of Civil Procedure,

requires a computation of any category of damages claimed by the

disclosing party, making available for inspection and copying under 

Rule 34 the documents or other evidentiary material not privileged or

protected from disclosure on which such computation is based, including

materials bearing on the nature and extent of injuries suffered. Plaintiff,

to the extent that these documents are available, identifies the following:

1. Plaintiff claims lost wages and other tangible damages. The 

following are estimates of Plaintiff’s damages based upon the 

information he is aware of and can recall at this time:

Plaintiff was earning weekly wages of approximately $5,014.00 

when he worked for the Defendant. After being terminated on 

September 5, 2017, Plaintiff did not find new employment until 

December 4, 2017, a period of approximately 13 weeks. 

$5,014.00 for 13 weeks is approximately $65,182.00 Plaintiff 

suffered in lost wages during this time period. 

On December 4, 2017, Plaintiff began working for Corizon 

Healthcare, Inc. earning weekly wages of approximately 

$6,384.62. He continues to work at Corizon and has been 

promoted twice now earning approximately $6,453.85 per week.

As of this date, April 14, 2020, Plaintiff estimates his damages at 

approximately $65,182.00 for lost wages. 

2. Plaintiff is also entitled to damages relating to mental anguish,

emotional distress, depression, anger, escalated levels of stress,

feelings of helplessness, embarrassment, humiliation, loss of

capacity for the enjoyment of life, and illness. It is not Plaintiff’s

counsel’s practice to ask the jury for a set financial award for 

intangible damages. Instead, it is Plaintiff’s counsel’s practice to 

ask the jury to award an amount of money for emotional pain and

suffering that will fairly compensate the Plaintiff for the mental

pain and suffering endured as a result of the unlawful acts of

Defendant.

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Plaintiff submits that the decision how much to award for these

damages belongs to the jury and to the jury alone. Plaintiff 

further submits that on a practical level, a forced statement of 

emotional pain and suffering damages, as here, is pernicious. 

Appearing as it must in a court paper, it is subject to Rule 11 and, 

therefore, in light of the above authorities and common sense, the 

number given is necessarily not based on any specific calculation 

or formula.

Plaintiff also claims entitlement to attorneys' fees and costs in 

this matter. 

3. Lost pay increases and bonuses, as may be applicable. 

4. Punitive damages, amount sought will be the maximum allowed 

by law.

5. Injunctive relief and other equitable relief as allowed by law. 

6. Reinstatement of Plaintiff’s position, pay, fringe benefits, and 

tenure. 

7. Plaintiff also seeks to recover front pay and back pay, as may be 

applicable. 

8. Other damages may be made known to Plaintiff during the course 

of this action.

D. Rule 26(a)(1)(A)(iv), Federal Rules of Civil Procedure,

requires disclosure of any insurance agreement under which any

person carrying on an insurance business may be liable to satisfy part

or all of any judgment which may be entered in the action or to

indemnify or reimburse for payments made to satisfy the judgment.

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Plaintiff has no such insurance policy but reasonably believes that a

policy of insurance covers Defendant's actions in this case.

Respectfully submitted,

/s/ Farnita Saunders Hill_______

Farnita Saunders Hill [FBN 1012158]

Marie A. Mattox, Esquire

Marie A. Mattox [FBN0739685]

MARIE A. MATTOX, P. A.

203 N. Gadsden Street

Tallahassee, FL 32301

Telephone: (850) 383-4800

Facsimile: (850) 383-4801

farnita@mattoxlaw.com

jervonie@mattoxlaw.com

marie@mattoxlaw.com

susan@mattoxlaw.com

ATTORNEYS FOR PLAINTIFF

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