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Filing # 113736189 E-Filed 09/22/2020 09:53:24 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
LUERETTA SMITH,
Plaintiff, CASE NO. CACE-19-021319 (13)
VS.
WINN-DIXIE STORES, INC.,
Defendant.
/
DEFENDANT’S NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE NOTIFIED that after 10 days from the date of service of this notice by email
delivery, and if no objection is received from any party, the undersigned will issue or apply to
the clerk of this court for issuance of the attached subpoenas directed to the following records
custodians, who are not parties, to produce the items listed at the time and place specified in the
subpoena:
1. Harold Rosen, M.D.
2. Unimed Health System.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd day of September, 2020, a true and correct copy
of the foregoing was filed and served via Florida Courts eFiling Portal to the following counsel
of record: Justin G. Morgan, Esq., The Law Offices of Justin G. Morgan, P.A., 2500 Weston
Road, Suite 211, Weston, FL 33331; pleadings@justinmorganlaw.com.
1025563\306644255.v1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/22/2020 09:53:23 AM.****CASE NO. CACE-19-021319 (13)
HINSHAW & CULBERTSON LLP
Si Paul J. Gamm
Paul J. Gamm
Florida Bar No. 0577146
One East Broward Boulevard
Suite 1010
Ft. Lauderdale, FL 33301
Telephone: 954-467-7900
Facsimile: 954-467-1024
Primary: pgamm@hinshawlaw.com
Secondary: kcardenas@hinshawlaw.com
Attorneys for Defendant WINN-DIXIE.
1025563\306644255.v1IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
LUERETTA SMITH,
Plaintiff, CASE NO. CACE-19-021319 (13)
VS.
WINN-DIXIE STORES, INC.,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: Records Custodian:
Harold Rosen, M.D.
1 West Sample Rd, Suite 102
Pompano Beach, FL 33064
YOU ARE HEREBY COMMANDED to appear in person or to mail to Hinshaw &
Culbertson LLP, One East Broward Boulevard, Suite 1010, Ft. Lauderdale, FL 33301, on or
before ten (10) days after service of this subpoena upon you, the following regarding:
Patient: Lueretta Smith
Date of Birth:
Soc. Sec. No.: XXX-XX-
YOUR ENTIRE FILE, FROM THE INCEPTION OF YOUR RECORDS TO THE
DATE OF SERVICE OF THIS SUBPOENA, INCLUSIVE OF, BUT NOT LIMITED TO
COPIES OF:
1. ANY AND ALL medical records, office records, doctors and nurses notes, and
all of the data pertaining to the diagnosis, treatment and care of the above-referenced patient,
including all photographs in your possession.
2. ANY AND ALL medical records, office records, doctors and nurses notes, and
all of the data pertaining to the diagnosis, treatment and care of the above-referenced patient
rendered by any other physician aside from the individual directed to the subpoena herein.
3. ANY AND ALL reports rendered by the witness to any party concerning the
treatment, diagnosis and care of the above-referenced individual.
1025563\306644059.v1CASE NO. CACE-19-021319 (13)
4. CURRENT BILL for all services rendered by the witness pertaining to the
diagnosis, treatment and care of the above-referenced patient.
5. ANY AND ALL X-ray, MRI, CT or other radiology reports of the above-
referenced patient by the witness or any other physician that are in possession of information.
6. THE ABOVE REQUESTED should be inclusive and should in no way be
limited to any one act, event or illness.
7. HOSPITAL RECORDS should include all inpatient, outpatient and emergency
room records as well as the bill for each service rendered and should not be limited to any one
event, accident or illness.
8. ANY AND ALL diagnostic tests, data and reports pertaining to the above-
referenced patient. This includes but is not limited to tests tracing data reports for diagnostic
procedures such as EMG, EEG, EKG, CT Scan, Brain Scan Invoked Response, Myelogram, etc.
9. ANY AND ALL X-rays, MRI’s, CT’s or other radiographic films taken of the
above-referenced patient.
10. | ANY AND ALL correspondence contained in the file other than correspondence
between the patient and their attorney.
PLEASE COPY AND SEND YOUR ENTIRE FILE INCLUDING ANYTHING
WRITTEN ON THE JACKET OR FOLDER CONTAINING THE FILE.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of reasonable cost of preparation.
You_may mail or deliver the copies to the attorney whose name appears on this
subpoena and thereby eliminate your appearance at the time and place specified above.
You have the right to object to the production pursuant to this subpoena at any time before the
production by giving notice to the attorney whose name appears on this subpoena.
IF YOU FAIL TO: (1) furnish the records as provided above, or (2) object to this
subpoena you may be in contempt of court.
YOU ARE SUBPOENAED by the following attorneys and unless excused from this
subpoena by these attorneys or the Court, you shall respond to this subpoena as directed.
All conditions precedent to Florida Rule of Civil Procedure 1.351 have been complied
with, including (1) service of a Notice of Production from Non Party, which constitutes notice to
1025563\306644059.v1CASE NO. CACE-19-021319 (13)
the patient's attorney and (2) waiting 10 days before service of the subpoena for records listed on
the Notice of Production from Non Party. By issuance of this subpoena, the undersigned hereby
certifies that no objection has been raised by the patient's attorney or any other party to the
issuance of the subpoena and obtaining the requested records.
FOR THE COURT
Date: HINSHAW & CULBERTSON LLP
Attomeys for Defendant Winn-Dixie Stores
One East Broward Blvd., Suite 1010
Fort Lauderdale, FL 33301
Telephone: 95.467.7900
Facsimile: 954.467-1024
Email: pgamm@hinshawlaw.com
kcardenas@hinshawlaw.com
/s/ Paul J. Gamm
By: Paul J. Gamm
Florida Bar No. 0577146
Gabriela I. Villamizar
Florida Bar No. 1019009
MAIL RECORDS TO:
Hinshaw & Culbertson LLP
One East Broward Boulevard
Suite 1010
Ft. Lauderdale, FL 33301
Phone: 954.467.7900
Fax: 954.467.1024
For Information Call:
Victor E. Pupo, Paralegal
Direct Line: 954.375.1132
Email: vpupo@hinshawlaw.com
1025563\306644059.v1CASE NO. CACE-19-021319 (13)
STATEMENT IN COMPLIANCE WITH HIPAA: The patient named in this
subpoena has been timely notified of this request for medical records (10 days prior pursuant to
Fla.R.Civ.P. 1.351) by email delivery of a Notice of Production to his/her attorney of record. It
is certified by the attorney signing this subpoena that the patient's counsel has made no objection
to production of records within the time allowed for by Fla.R.Civ.P. 1.351.
Further written warranty is hereby given that A) these records will be used for no other
purpose than the above litigation and B) these records will be destroyed at the conclusion of the
above litigation.
IN ACCORDANCE with the Americans with Disabilities Act of 1990 (ADA), disabled
persons who, because of their disabilities, need special accommodation to participate in this
proceeding should contact the ADA Coordinator at 1-800-955-8771, not later than five business
days prior to such proceeding.
1025563\306644059.v1IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
LUERETTA SMITH,
Plaintiff, CASE NO. CACE-19-021319 (13)
VS.
WINN-DIXIE STORES, INC.,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: Records Custodian:
Unimed Health System
1800 West Hillsboro Blvd
Deerfield Beach, FL 33442
YOU ARE HEREBY COMMANDED to appear in person or to mail to Hinshaw &
Culbertson LLP, One East Broward Boulevard, Suite 1010, Ft. Lauderdale, FL 33301, on or
before ten (10) days after service of this subpoena upon you, the following regarding:
Patient: Lueretta Smith
Date of Birth:
Soc. Sec. No.: XXX-XX
YOUR ENTIRE FILE, FROM THE INCEPTION OF YOUR RECORDS TO THE
DATE OF SERVICE OF THIS SUBPOENA, INCLUSIVE OF, BUT NOT LIMITED TO
COPIES OF:
1. ANY AND ALL medical records, office records, doctors and nurses notes, and
all of the data pertaining to the diagnosis, treatment and care of the above-referenced patient,
including all photographs in your possession.
2. ANY AND ALL medical records, office records, doctors and nurses notes, and
all of the data pertaining to the diagnosis, treatment and care of the above-referenced patient
rendered by any other physician aside from the individual directed to the subpoena herein.
3. ANY AND ALL reports rendered by the witness to any party concerning the
treatment, diagnosis and care of the above-referenced individual.
1025563\306644031.v1CASE NO. CACE-19-021319 (13)
4. CURRENT BILL for all services rendered by the witness pertaining to the
diagnosis, treatment and care of the above-referenced patient.
5. ANY AND ALL X-ray, MRI, CT or other radiology reports of the above-
referenced patient by the witness or any other physician that are in possession of information.
6. THE ABOVE REQUESTED should be inclusive and should in no way be
limited to any one act, event or illness.
7. HOSPITAL RECORDS should include all inpatient, outpatient and emergency
room records as well as the bill for each service rendered and should not be limited to any one
event, accident or illness.
8. ANY AND ALL diagnostic tests, data and reports pertaining to the above-
referenced patient. This includes but is not limited to tests tracing data reports for diagnostic
procedures such as EMG, EEG, EKG, CT Scan, Brain Scan Invoked Response, Myelogram, etc.
9. ANY AND ALL X-rays, MRI’s, CT’s or other radiographic films taken of the
above-referenced patient.
10. | ANY AND ALL correspondence contained in the file other than correspondence
between the patient and their attorney.
PLEASE COPY AND SEND YOUR ENTIRE FILE INCLUDING ANYTHING
WRITTEN ON THE JACKET OR FOLDER CONTAINING THE FILE.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of reasonable cost of preparation.
You_may mail or deliver the copies to the attorney whose name appears on this
subpoena and thereby eliminate your appearance at the time and place specified above.
You have the right to object to the production pursuant to this subpoena at any time before the
production by giving notice to the attorney whose name appears on this subpoena.
IF YOU FAIL TO: (1) furnish the records as provided above, or (2) object to this
subpoena you may be in contempt of court.
YOU ARE SUBPOENAED by the following attorneys and unless excused from this
subpoena by these attorneys or the Court, you shall respond to this subpoena as directed.
All conditions precedent to Florida Rule of Civil Procedure 1.351 have been complied
with, including (1) service of a Notice of Production from Non Party, which constitutes notice to
1025563\306644031.v1CASE NO. CACE-19-021319 (13)
the patient's attorney and (2) waiting 10 days before service of the subpoena for records listed on
the Notice of Production from Non Party. By issuance of this subpoena, the undersigned hereby
certifies that no objection has been raised by the patient's attorney or any other party to the
issuance of the subpoena and obtaining the requested records.
FOR THE COURT
Date: HINSHAW & CULBERTSON LLP
Attomeys for Defendant Winn-Dixie Stores
One East Broward Blvd., Suite 1010
Fort Lauderdale, FL 33301
Telephone: 95.467.7900
Facsimile: 954.467-1024
Email: pgamm@hinshawlaw.com
kcardenas@hinshawlaw.com
/s/ Paul J. Gamm
By: Paul J. Gamm
Florida Bar No. 0577146
Gabriela I. Villamizar
Florida Bar No. 1019009
MAIL RECORDS TO:
Hinshaw & Culbertson LLP
One East Broward Boulevard
Suite 1010
Ft. Lauderdale, FL 33301
Phone: 954.467.7900
Fax: 954.467.1024
For Information Call:
Victor E. Pupo, Paralegal
Direct Line: 954.375.1132
Email: vpupo@hinshawlaw.com
1025563\306644031.v1CASE NO. CACE-19-021319 (13)
STATEMENT IN COMPLIANCE WITH HIPAA: The patient named in this
subpoena has been timely notified of this request for medical records (10 days prior pursuant to
Fla.R.Civ.P. 1.351) by email delivery of a Notice of Production to his/her attorney of record. It
is certified by the attorney signing this subpoena that the patient's counsel has made no objection
to production of records within the time allowed for by Fla.R.Civ.P. 1.351.
Further written warranty is hereby given that A) these records will be used for no other
purpose than the above litigation and B) these records will be destroyed at the conclusion of the
above litigation.
IN ACCORDANCE with the Americans with Disabilities Act of 1990 (ADA), disabled
persons who, because of their disabilities, need special accommodation to participate in this
proceeding should contact the ADA Coordinator at 1-800-955-8771, not later than five business
days prior to such proceeding.
1025563\306644031.v1
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Filing # 113736189 E-Filed 09/22/2020 09:53:24 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION LUERETTA SMITH, Plaintiff, CASE NO. CACE-19-021319 (13) VS. WINN-DIXIE STORES, INC., Defendant. / DEFENDANT’S NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE NOTIFIED that after 10 days from the date of service of this notice by email delivery, and if no objection is received from any party, the undersigned will issue or apply to the clerk of this court for issuance of the attached subpoenas directed to the following records custodians, who are not parties, to produce the items listed at the time and place specified in the subpoena: 1. Harold Rosen, M.D. 2. Unimed Health System. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 22nd day of September, 2020, a true and correct copy of the foregoing was filed and served via Florida Courts eFiling Portal to the following counsel of record: Justin G. Morgan, Esq., The Law Offices of Justin G. Morgan, P.A., 2500 Weston Road, Suite 211, Weston, FL 33331; pleadings@justinmorganlaw.com. 1025563\306644255.v1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/22/2020 09:53:23 AM.****CASE NO. CACE-19-021319 (13) HINSHAW & CULBERTSON LLP Si Paul J. Gamm Paul J. Gamm Florida Bar No. 0577146 One East Broward Boulevard Suite 1010 Ft. Lauderdale, FL 33301 Telephone: 954-467-7900 Facsimile: 954-467-1024 Primary: pgamm@hinshawlaw.com Secondary: kcardenas@hinshawlaw.com Attorneys for Defendant WINN-DIXIE. 1025563\306644255.v1IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION LUERETTA SMITH, Plaintiff, CASE NO. CACE-19-021319 (13) VS. WINN-DIXIE STORES, INC., Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: Records Custodian: Harold Rosen, M.D. 1 West Sample Rd, Suite 102 Pompano Beach, FL 33064 YOU ARE HEREBY COMMANDED to appear in person or to mail to Hinshaw & Culbertson LLP, One East Broward Boulevard, Suite 1010, Ft. Lauderdale, FL 33301, on or before ten (10) days after service of this subpoena upon you, the following regarding: Patient: Lueretta Smith Date of Birth: Soc. Sec. No.: XXX-XX- YOUR ENTIRE FILE, FROM THE INCEPTION OF YOUR RECORDS TO THE DATE OF SERVICE OF THIS SUBPOENA, INCLUSIVE OF, BUT NOT LIMITED TO COPIES OF: 1. ANY AND ALL medical records, office records, doctors and nurses notes, and all of the data pertaining to the diagnosis, treatment and care of the above-referenced patient, including all photographs in your possession. 2. ANY AND ALL medical records, office records, doctors and nurses notes, and all of the data pertaining to the diagnosis, treatment and care of the above-referenced patient rendered by any other physician aside from the individual directed to the subpoena herein. 3. ANY AND ALL reports rendered by the witness to any party concerning the treatment, diagnosis and care of the above-referenced individual. 1025563\306644059.v1CASE NO. CACE-19-021319 (13) 4. CURRENT BILL for all services rendered by the witness pertaining to the diagnosis, treatment and care of the above-referenced patient. 5. ANY AND ALL X-ray, MRI, CT or other radiology reports of the above- referenced patient by the witness or any other physician that are in possession of information. 6. THE ABOVE REQUESTED should be inclusive and should in no way be limited to any one act, event or illness. 7. HOSPITAL RECORDS should include all inpatient, outpatient and emergency room records as well as the bill for each service rendered and should not be limited to any one event, accident or illness. 8. ANY AND ALL diagnostic tests, data and reports pertaining to the above- referenced patient. This includes but is not limited to tests tracing data reports for diagnostic procedures such as EMG, EEG, EKG, CT Scan, Brain Scan Invoked Response, Myelogram, etc. 9. ANY AND ALL X-rays, MRI’s, CT’s or other radiographic films taken of the above-referenced patient. 10. | ANY AND ALL correspondence contained in the file other than correspondence between the patient and their attorney. PLEASE COPY AND SEND YOUR ENTIRE FILE INCLUDING ANYTHING WRITTEN ON THE JACKET OR FOLDER CONTAINING THE FILE. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of reasonable cost of preparation. You_may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before the production by giving notice to the attorney whose name appears on this subpoena. IF YOU FAIL TO: (1) furnish the records as provided above, or (2) object to this subpoena you may be in contempt of court. YOU ARE SUBPOENAED by the following attorneys and unless excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed. All conditions precedent to Florida Rule of Civil Procedure 1.351 have been complied with, including (1) service of a Notice of Production from Non Party, which constitutes notice to 1025563\306644059.v1CASE NO. CACE-19-021319 (13) the patient's attorney and (2) waiting 10 days before service of the subpoena for records listed on the Notice of Production from Non Party. By issuance of this subpoena, the undersigned hereby certifies that no objection has been raised by the patient's attorney or any other party to the issuance of the subpoena and obtaining the requested records. FOR THE COURT Date: HINSHAW & CULBERTSON LLP Attomeys for Defendant Winn-Dixie Stores One East Broward Blvd., Suite 1010 Fort Lauderdale, FL 33301 Telephone: 95.467.7900 Facsimile: 954.467-1024 Email: pgamm@hinshawlaw.com kcardenas@hinshawlaw.com /s/ Paul J. Gamm By: Paul J. Gamm Florida Bar No. 0577146 Gabriela I. Villamizar Florida Bar No. 1019009 MAIL RECORDS TO: Hinshaw & Culbertson LLP One East Broward Boulevard Suite 1010 Ft. Lauderdale, FL 33301 Phone: 954.467.7900 Fax: 954.467.1024 For Information Call: Victor E. Pupo, Paralegal Direct Line: 954.375.1132 Email: vpupo@hinshawlaw.com 1025563\306644059.v1CASE NO. CACE-19-021319 (13) STATEMENT IN COMPLIANCE WITH HIPAA: The patient named in this subpoena has been timely notified of this request for medical records (10 days prior pursuant to Fla.R.Civ.P. 1.351) by email delivery of a Notice of Production to his/her attorney of record. It is certified by the attorney signing this subpoena that the patient's counsel has made no objection to production of records within the time allowed for by Fla.R.Civ.P. 1.351. Further written warranty is hereby given that A) these records will be used for no other purpose than the above litigation and B) these records will be destroyed at the conclusion of the above litigation. IN ACCORDANCE with the Americans with Disabilities Act of 1990 (ADA), disabled persons who, because of their disabilities, need special accommodation to participate in this proceeding should contact the ADA Coordinator at 1-800-955-8771, not later than five business days prior to such proceeding. 1025563\306644059.v1IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION LUERETTA SMITH, Plaintiff, CASE NO. CACE-19-021319 (13) VS. WINN-DIXIE STORES, INC., Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: Records Custodian: Unimed Health System 1800 West Hillsboro Blvd Deerfield Beach, FL 33442 YOU ARE HEREBY COMMANDED to appear in person or to mail to Hinshaw & Culbertson LLP, One East Broward Boulevard, Suite 1010, Ft. Lauderdale, FL 33301, on or before ten (10) days after service of this subpoena upon you, the following regarding: Patient: Lueretta Smith Date of Birth: Soc. Sec. No.: XXX-XX YOUR ENTIRE FILE, FROM THE INCEPTION OF YOUR RECORDS TO THE DATE OF SERVICE OF THIS SUBPOENA, INCLUSIVE OF, BUT NOT LIMITED TO COPIES OF: 1. ANY AND ALL medical records, office records, doctors and nurses notes, and all of the data pertaining to the diagnosis, treatment and care of the above-referenced patient, including all photographs in your possession. 2. ANY AND ALL medical records, office records, doctors and nurses notes, and all of the data pertaining to the diagnosis, treatment and care of the above-referenced patient rendered by any other physician aside from the individual directed to the subpoena herein. 3. ANY AND ALL reports rendered by the witness to any party concerning the treatment, diagnosis and care of the above-referenced individual. 1025563\306644031.v1CASE NO. CACE-19-021319 (13) 4. CURRENT BILL for all services rendered by the witness pertaining to the diagnosis, treatment and care of the above-referenced patient. 5. ANY AND ALL X-ray, MRI, CT or other radiology reports of the above- referenced patient by the witness or any other physician that are in possession of information. 6. THE ABOVE REQUESTED should be inclusive and should in no way be limited to any one act, event or illness. 7. HOSPITAL RECORDS should include all inpatient, outpatient and emergency room records as well as the bill for each service rendered and should not be limited to any one event, accident or illness. 8. ANY AND ALL diagnostic tests, data and reports pertaining to the above- referenced patient. This includes but is not limited to tests tracing data reports for diagnostic procedures such as EMG, EEG, EKG, CT Scan, Brain Scan Invoked Response, Myelogram, etc. 9. ANY AND ALL X-rays, MRI’s, CT’s or other radiographic films taken of the above-referenced patient. 10. | ANY AND ALL correspondence contained in the file other than correspondence between the patient and their attorney. PLEASE COPY AND SEND YOUR ENTIRE FILE INCLUDING ANYTHING WRITTEN ON THE JACKET OR FOLDER CONTAINING THE FILE. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of reasonable cost of preparation. You_may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before the production by giving notice to the attorney whose name appears on this subpoena. IF YOU FAIL TO: (1) furnish the records as provided above, or (2) object to this subpoena you may be in contempt of court. YOU ARE SUBPOENAED by the following attorneys and unless excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed. All conditions precedent to Florida Rule of Civil Procedure 1.351 have been complied with, including (1) service of a Notice of Production from Non Party, which constitutes notice to 1025563\306644031.v1CASE NO. CACE-19-021319 (13) the patient's attorney and (2) waiting 10 days before service of the subpoena for records listed on the Notice of Production from Non Party. By issuance of this subpoena, the undersigned hereby certifies that no objection has been raised by the patient's attorney or any other party to the issuance of the subpoena and obtaining the requested records. FOR THE COURT Date: HINSHAW & CULBERTSON LLP Attomeys for Defendant Winn-Dixie Stores One East Broward Blvd., Suite 1010 Fort Lauderdale, FL 33301 Telephone: 95.467.7900 Facsimile: 954.467-1024 Email: pgamm@hinshawlaw.com kcardenas@hinshawlaw.com /s/ Paul J. Gamm By: Paul J. Gamm Florida Bar No. 0577146 Gabriela I. Villamizar Florida Bar No. 1019009 MAIL RECORDS TO: Hinshaw & Culbertson LLP One East Broward Boulevard Suite 1010 Ft. Lauderdale, FL 33301 Phone: 954.467.7900 Fax: 954.467.1024 For Information Call: Victor E. Pupo, Paralegal Direct Line: 954.375.1132 Email: vpupo@hinshawlaw.com 1025563\306644031.v1CASE NO. CACE-19-021319 (13) STATEMENT IN COMPLIANCE WITH HIPAA: The patient named in this subpoena has been timely notified of this request for medical records (10 days prior pursuant to Fla.R.Civ.P. 1.351) by email delivery of a Notice of Production to his/her attorney of record. It is certified by the attorney signing this subpoena that the patient's counsel has made no objection to production of records within the time allowed for by Fla.R.Civ.P. 1.351. Further written warranty is hereby given that A) these records will be used for no other purpose than the above litigation and B) these records will be destroyed at the conclusion of the above litigation. IN ACCORDANCE with the Americans with Disabilities Act of 1990 (ADA), disabled persons who, because of their disabilities, need special accommodation to participate in this proceeding should contact the ADA Coordinator at 1-800-955-8771, not later than five business days prior to such proceeding. 1025563\306644031.v1