Professional liability: hospital's liability for 'bare' physicians in Florida increasingly unclear. Plantation General Hospital Limited Partnership v. Horowitz, _____ So. 2d _____, No. 4D03-3873 (Ct. App. 4th Dist. Fla. February 9, 2005); North Miami Medical Center, Ltd. v. Miller, _____ So. 2d _____, Nos. 3D03-3183, 3D03-3233