Preview
Filing # 141103402 E-Filed 12/29/2021 04:15:36 PM
Choice # 124379, 1-12
CASE NO. 50-2021-CA-010108
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CIVIL DIVISION
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff(s),
vs.
EDENS LIMITED PARTNERSHIP D/B/A
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
/
NOTICE OF PRODUCTION FROM NON-PARTY
To: Barry C. Hoffman, Esq.
Barry G. Hoffman Law Office, PA
9045 La Fontana Boulevard, Suite 1106
Boca Raton, FL 33434
Primary E-Mail: hchlawoffice@aol.com
David J. Majeak
Goldberg Segalla, LLP
222 Lakeview Avenue, Suite 800
West Palm Beach, FL 33401
Primary E-Mail: dmajcak@goldbergsegalla.com
Secondary E-Mail: kgomberg@goldbergsegalla.com
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
notice, if notice is by delivery/fax/e-mail or fifteen (15) days from the date of service, if service
is by mail, and if no objection is received from any party, the undersigned will issue the attached
subpoena(s) directed to the records custodian of:
Bethesda Memorial Hospital (Medical)
Attn: Medical Records
3800 S. Congress Ave. Ste 3
Boynton Beach, FL 33426
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/29/2021 04:15:36 PM ***Bethesda Memorial Hospital (Billing)
Attn: Billing Records Dept.
3800 S. Congress Ave. Ste 3
Boynton Beach, FL 33426
Bethesda Memorial Hospital (Films)
Attn: Radiology Department
3800 S. Congress Ave. Ste 3
Boynton Beach, FL 33426
Boynton Beach, FL 33426 New Med M.D. PA and/or Dr. Martha Rodriguez (Medical & Billing)
2015 Ocean Dr., Suite 11
Boynton Beach, FL 33426
Bethesda Hospital East (Medical)
Attn: Medical Records / HIM Department
2815 South Seacrest Boulevard
Boynton Beach, FL 33435
Bethesda Hospital East (Billing)
Attn: Billing Records Dept.
2815 South Seacrest Blvd
Boynton Beach, FL 33435
One at Home-Palm Beach (Medical & Billing)
23123 State Road 7
Boca Raton, FL 33428
Woolbright Physical Therapy (Medical & Billing)
2015 Ocean Drive, Suite 1
Boynton Beach, FL 33426-5131
National Orthopedics and Neurosurgery, P.A. (Medical & Billing)
3618 Lantana Road, Suite 100
Lake Worth, FL 33462
Humana (Insurance - Health)
P.O. Box 14601
Lexington, KY 40512-4601
JB Cruises (Employment)
Attn: Human Resources
7460 Boynton Beach Blvd.
Boynton Beach, FL 33437H. Ising's, Inc. (Employment)
Attn: Human Resources
10481 N. 150th Ct.
Jupiter, FL 33478
who are not a party to this suit, to produce the items listed by the method at the time and place
specified in the subpoena.
_x_ This notice was served via E-MAIL
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing was
furnished in accordance with the Florida Rule of Judicial Administration 2.516, to:
Barry C. Hoffman, Esq.
Barry G. Hoffman Law Office, PA
9045 La Fontana Boulevard, Suite 1106
Boca Raton, FL 33434
Primary E-Mail: hchlawoffice@aol.com
David J. Majeak
Goldberg Segalla, LLP
222 Lakeview Avenue, Suite 800
West Palm Beach, FL 33401
Primary E-Mail: dmajcak@goldbergsegalla.com
Secondary E-Mail: kgomberg@goldbergsegalla.com
on this 29th day of December 2021.
on __ Pdehatp Keter
Mitch Katler
Law Offices of James W. Kehoe, III - Ft. Lauderdale
3230 W. Commercial Blvd., Ste. 250
Fort Lauderdale, Florida 33309
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
Telephone: (954) 677-3723
Facsimile No.: 866-292-4641
Primary E-Mail: mkatler@travelers.com
Secondary E-Mail: tgruende@travelers.com
cenrich@travelers.com
Florida Bar No.454982
Attomey for the DefendantChoice Legal, Inc.
PO Box 1215
Tampa, Florida 33601
Phone: (813) 229-1444
Fax: (813) 324-5191
COPY REQUEST FORM
To: Barry C. Hoffman, Esq.
Barry G. Hoffman Law Office, PA
9045 La Fontana Boulevard, Suite 1106
Boca Raton, FL 33434
Primary E-Mail: hchlawoffice@aol.com
David J. Majcak
Goldberg Segalla, LLP
222 Lakeview Avenue, Suite 800
West Palm Beach, FL 33401
Primary E-Mail: dmajcak@goldbergsegalla.com
Secondary E-Mail: kgomberg@goldbergsegalla.com
Re: Marion J. Young Butera and Thomas Butera v. Edens Limited Partnership, et al.
Order No.: 124379
Records of: MARION J. YOUNG BUTERA
Please check the appropriate boxes and fax or mail to CHOICE LEGAL, INC. to request exact copies. Requests
cannot be accepted without a signature and date.
DO NOT SEND PAYMENT AT THIS TIME- YOU WILL RECEIVE AN INVOICE PRIOR TO
RECEIVING RECORDS. Any and all copies of films must be obtained from defense counsel.
LOCATIONS Check box for requested records
Bethesda Memorial Hospital (Medical)
Attn: Medical Records
3800 S. Congress Ave. Ste 3
Boynton Beach, FL 33426 ]
Bethesda Memorial Hospital (Billing)
Attn: Billing Records Dept.
3800 S. Congress Ave. Ste 3
Boynton Beach, FL 33426 l
Bethesda Memorial Hospital (Films)
Attn: Radiology Department
3800 S. Congress Ave. Ste 3
Boynton Beach, FL 33426 U
New Med MLD. PA and/or Dr. Martha Rodriguez (Medical & Billing)
2015 Ocean Dr., Suite 11
Boynton Beach, FL 33426 tl
Bethesda Hospital East (Medical)
Attn: Medical Records / HIM Department
2815 South Seacrest Boulevard
Boynton Beach, FL 33435 ]Bethesda Hospital East (Billing)
Attn: Billing Records Dept.
2815 South Seacrest Blvd
Boynton Beach, FL 33435
One at Home-Palm Beach (Medical & Billing)
23123 State Road 7
Boca Raton, FL 33428
Woolbright Physical Therapy (Medical & Billing)
2015 Ocean Drive, Suite 1
Boynton Beach, FL 33426-5131
National Orthopedics and Neurosurgery, P.A. (Medical & Billing)
3618 Lantana Road, Suite 100
Lake Worth, FL 33462
Humana (Insurance - Health)
P.O. Box 14601
Lexington, KY 40512-4601
JB Cruises (Employment)
Attn: Human Resources
7460 Boynton Beach Blvd.
Boynton Beach, FL 33437
H. Ising's, Inc. (Employment)
Attn: Human Resources
10481 N. 150th Ct.
Jupiter, FL 33478
Do you agree to waive the 10 day hold? YES
Requested by:
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NAME (PLEASE PRINT)
SIGNATURE
DATE
TELEPHONE NUMBER
=*~Our copy fee(s) is $0.25 a page plus a postage and handling fee of $8.00. Records are also available on CD. The fee for
these services is $50.00 flat rate up to 500 pages. At 501 pages or more, there will be a $0.10 per page fee. A $5.00
shipping fee will be charged for mailing a CD. Records are also available online for the same cost as the CD option. If
you wish to order copies of records and do not yet
have an account, please e-mail Ashleigh at
Ashleigh. Morrow@ChoiceLegal. com to receive access to your records online. (Records will be available for viewing once
payment has been received). Copies of these records can also be obtained from defense counsel directly.***Choice # 124379,001
CASE NO. 50-2021-CA-010108
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CIVIL DIVISION
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff(s),
vs.
EDENS LIMITED PARTNERSHIP D/B/A.
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: RECORDS CUSTODIAN
Bethesda Memorial Hospital
Attn: Medical Records
3800 S. Congress Ave. Ste 3
Boynton Beach, FL 33426
YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within
receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box
1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to:
records@choicelegal.com and to have the following for copying by Choice Legal:
RECORDS OF MARION J. YOUNG BUTERA
ANY AND ALL DOCUMENTS, CORRESPONDENCE, RECORDS, INCLUDING BUT
NOT LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT-
PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSE'S NOTES, COLORED
INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE DOCUMENTS, INITIAL
PATIENT QUESTIONNAIRE, SIGN IN SHEETS, ELECTRONIC RECORDS, ANY
AND ALL PHARMACY RECORDS, ALL DESCRIPTIONS OF EXERCISES
PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE AND TIME OFPATIENT'S APPOINTMENTS PERTAINING TO THE CARE OF TREATMENT AND
EXAMINATION OF THE PATIENT REGARDLESS OF TREATMENT DATE, ANY
AND ALL REPORTS OR CORRESPONDENCE INCLUDING BUT NOT LIMITED TO
OTHER PHYSICIANS OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT
NOT LIMITED TO CD ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE,
SCANNED DOCUMENTS AND ALL OTHER DOCUMENTS STORED
ELECTRONICALLY OR DIGITALLY. INCLUDE ALL PHYSICAL THERAPY
RECORDS. INCLUDE PHYSICIAN'S CURRICULUM VITAE, AND EVERY
WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S CHART,
INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. ALL
RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED
TO ONE INCIDENT. PLEASE ALSO PROVIDE ANY AND ALL LETTERS OF
PROTECTION YOU HAVE RECEIVED AS IT PERTAINS TO THE ABOVE-NAMED
INDIVIDUAL.
These items may 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
MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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
written notice to the attorney whose name appears on the subpoena. If you do not have records
on the requested party, provide a written note stating that your facility does not have the
information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
SEND RECORDS AND INVOICE TO:
RECORDS@CHOICELEGAL.COM
Choice Legal, Inc., PO Box 1215, Tampa, FL 33601
OR
Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619
Telephone (813) 229-1444 - Fax (813) 443-5734
If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by
the attorneys or Court, you shall respond to this subpoena as directed.
IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990,
PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL
ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT
THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE
PROCEEDING: FOR COURT PROCEEDINGS —- CONTACT THE COURT A.D.A.COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED
ATTORNEY.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we
must obtain satisfactory assurance from the party issuing the below-named subpoena that notice
has been provided to the patient whose protected health information has been subpoenaed. As
the attorney issuing the above-named subpoena, I hereby certify that the following statements are
true:
1. Ihave made a good faith attempt to provide written notice to the above-named patient that
his/her protected health information has been subpoenaed
2. The notice I provided included sufficient information about the litigation or proceeding for
which the protected health information is requested to permit the patient to raise an objection
to the court; and
3. The time for the patient to raise objections to the court has elapsed; and
1. No objections were filed; or
2. All objections filed by the patient were resolved by the court and the disclosures
being sought are consistent with such resolution.
Dated on this day of
, 2021.
Mitch Katler
Law Offices of James W. Kehoe, III - Ft. Lauderdale
3230 W. Commercial Blvd., Ste. 250
Fort Lauderdale, Florida 33309
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
Telephone: (954) 677-3723
Facsimile No.: 866-292-4641
Primary E-Mail: mkatler@travelers.com
Secondary E-Mail: tgruende@travelers.com
cenrich@travelers.com
Florida Bar No.454982
Attomey for the Defendant
Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please
direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR
9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax
Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,002
CASE NO. 50-2021-CA-010108
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CIVIL DIVISION
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff(s),
vs.
EDENS LIMITED PARTNERSHIP D/B/A.
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: RECORDS CUSTODIAN
Bethesda Memorial Hospital
Attn: Billing Records
3800 S. Congress Ave. Ste 3
Boynton Beach, FL 33426
YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within
receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box
1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to:
records@choicelegal.com and to have the following for copying by Choice Legal:
RECORDS OF MARION J. YOUNG BUTERA
ANY AND ALL BILLING RECORDS FROM ALL PROVIDERS WITHIN YOUR
PRACTICE, INCLUDING, BUT NOT LIMITED TO, ITEMIZED BILLING
STATEMENTS, AND ALL BILLING LEDGERS. PLEASE INCLUDE ANY AND ALL
HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N,
AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE
CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E"CODES ASSOCIATED WITH THE PRIMARY DOCTOR. ALL RECORDS SHOULD
BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ONE INCIDENT.
These items may 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
MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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
written notice to the attorney whose name appears on the subpoena. If you do not have records
on the requested party, provide a written note stating that your facility does not have the
information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
SEND RECORDS AND INVOICE TO:
RECORDS@CHOICELEGAL.COM
Choice Legal, Inc., PO Box 1215, Tampa, FL 33601
OR
Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619
Telephone (813) 229-1444 - Fax (813) 443-5734
If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by
the attorneys or Court, you shall respond to this subpoena as directed.
IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990,
PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL
ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT
THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE
PROCEEDING: FOR COURT PROCEEDINGS - CONTACT THE COURT A.D.A.
COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED
ATTORNEY.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we
must obtain satisfactory assurance from the party issuing the below-named subpoena that notice
has been provided to the patient whose protected health information has been subpoenaed. As
the attorney issuing the above-named subpoena, I hereby certify that the following statements are
true:1. I have made a good faith attempt to provide written notice to the above-named patient that
his/her protected health information has been subpoenaed
2. The notice I provided included sufficient information about the litigation or proceeding for
which the protected health information is requested to permit the patient to raise an objection
to the court; and
3. The time for the patient to raise objections to the court has elapsed; and
1. No objections were filed; or
2. All objections filed by the patient were resolved by the court and the disclosures
being sought are consistent with such resolution.
Dated on this day of , 2021.
By: f
Mitch Katler
Law Offices of James W. Kehoe, III - Ft. Lauderdale
3230 W. Commercial Blvd., Ste. 250
Fort Lauderdale, Florida 33309
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
Telephone: (954) 677-3723
Facsimile No.: 866-292-4641
Primary E-Mail: mkatler@travelers.com
Secondary E-Mail: tgruende@travelers.com
cenrich@travelers.com
Florida Bar No.454982
Attomey for the Defendant
Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please
direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR
9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax
Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,003
CASE NO. 50-2021-CA-010108
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CIVIL DIVISION
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff(s),
vs.
EDENS LIMITED PARTNERSHIP D/B/A.
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: RECORDS CUSTODIAN
Bethesda Memorial Hospital
Attn: Radiology
3800 S. Congress Ave. Ste 3
Boynton Beach, FL 33426
YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within
receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box
1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to:
records@choicelegal.com and to have the following for copying by Choice Legal:
RECORDS OF MARION J. YOUNG BUTERA
ANY AND ALL COPIES OF ALL DIAGNOSTIC STUDIES, INCLUDING BUT NOT
LIMITED TO: FILMS, RADIOLOGICAL AND DIAGNOSTICE REPORTS, X-RAYS,
MRI FILMS, PET SCANS, CT SCANS, FLUOROSCOPY, ULTRASOUNDS, AND
COLORED INTRA-OPERATIVE PHOTOGRAPHS, PERTAINING TO THE ABOVE
PATIENT. PLEASE PROVIDE A FULL AND COMPLETE FILM BREAKDOWN
(FORM ATTACHED) OF ALL FILMS OF ANY TYPE (MRI, CT, X-RAY,
ULTRASOUND, ETC.) PRIOR TO DUPLICATION AND ORDER. ALL RECORDSAND FILMS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED
TO ANY ONE INCIDENT, AND SHOULD INCLUDE ALL WRITTEN AND
ELECTRONIC RECORDS. PLEASE CALL BEFORE SENDING FILMS.
These items may 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
MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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
written notice to the attorney whose name appears on the subpoena. If you do not have records
on the requested party, provide a written note stating that your facility does not have the
information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
SEND RECORDS AND INVOICE TO:
RECORDS@CHOICELEGAL.COM
Choice Legal, Inc., PO Box 1215, Tampa, FL 33601
OR
Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619
Telephone (813) 229-1444 - Fax (813) 443-5734
If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by
the attorneys or Court, you shall respond to this subpoena as directed.
IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990,
PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL
ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT
THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE
PROCEEDING: FOR COURT PROCEEDINGS —- CONTACT THE COURT A.D.A.
COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED
ATTORNEY.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we
must obtain satisfactory assurance from the party issuing the below-named subpoena that notice
has been provided to the patient whose protected health information has been subpoenaed. As
the attorney issuing the above-named subpoena, I hereby certify that the following statements are
true:1. I have made a good faith attempt to provide written notice to the above-named patient that
his/her protected health information has been subpoenaed
2. The notice I provided included sufficient information about the litigation or proceeding for
which the protected health information is requested to permit the patient to raise an objection
to the court; and
3. The time for the patient to raise objections to the court has elapsed; and
1. No objections were filed; or
2. All objections filed by the patient were resolved by the court and the disclosures
being sought are consistent with such resolution.
Dated on this day of , 2021.
By:
Mitch Katler
Law Offices of James W. Kehoe, III - Ft. Lauderdale
3230 W. Commercial Blvd., Ste. 250
Fort Lauderdale, Florida 33309
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
Telephone: (954) 677-3723
Facsimile No.: 866-292-4641
Primary E-Mail: mkatler@travelers.com
Secondary E-Mail: tgruende@travelers.com
cenrich@travelers.com
Florida Bar No.454982
Attomey for the Defendant
Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please
direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR
9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax
Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,004
CASE NO. 50-2021-CA-010108
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CIVIL DIVISION
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff(s),
vs.
EDENS LIMITED PARTNERSHIP D/B/A.
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: RECORDS CUSTODIAN
New Med M.D. PA and/or Dr. Martha Rodriguez
2015 Ocean Dr., Suite 11
Boynton Beach, FL 33426
YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within
receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box
1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to:
records@choicelegal.com and to have the following for copying by Choice Legal:
RECORDS OF MARION J. YOUNG BUTERA
ANY AND ALL WRITTEN AND ELECTRONIC DOCUMENTS, CORRESPONDENCE,
RECORDS AND ITEMIZED STATEMENTS OF CHARGES, INCLUDING BUT NOT
LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT-
PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSES NOTES, PAYMENT
HISTORY, COLORED INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE
DOCUMENTS, INITIAL PATIENT QUESTIONNAIRE, SIGN IN SHEETS,
ELECTRONIC RECORDS, ANY AND ALL PHARMACY RECORDS, ALL
DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICHINDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS PERTAINING TO
THE CARE OF TREATMENT AND EXAMINATION OF THE PATIENT
REGARDLESS OF TREATMENT DATE, ANY AND ALL REPORTS OR
CORRESPONDENCE INCLUDING BUT NOT LIMITED TO OTHER PHYSICIANS
OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT NOT LIMITED TO CD
ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED DOCUMENTS AND
ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR DIGITALLY.
INCLUDE ALL PHYSICAL THERAPY RECORDS. INCLUDE PHYSICIAN'S
CURRICULUM VITAE, AND EVERY WRITTEN PIECE OF PAPER INCLUDED
WITHIN THE PATIENTS CHART, INCLUDING A COPY OF ANY NOTATIONS ON
THE FILE JACKET. ALL BILLING RECORDS, INCLUDING ALL BILLING
LEDGERS. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO
WAY BE LIMITED TO ONE INCIDENT. PLEASE INCLUDE ANY AND ALL
HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N,
AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE
CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E"
CODES ASSOCIATED WITH THE PRIMARY DOCTOR. PLEASE ALSO PROVIDE
ANY AND ALL LETTERS OF PROTECTION YOU HAVE RECEIVED AS IT
PERTAINS TO THE ABOVE-NAMED INDIVIDUAL.
These items may 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
MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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
written notice to the attorney whose name appears on the subpoena. If you do not have records
on the requested party, provide a written note stating that your facility does not have the
information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
SEND RECORDS AND INVOICE TO:
RECORDS@CHOICELEGAL.COM
Choice Legal, Inc., PO Box 1215, Tampa, FL 33601
OR
Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619
Telephone (813) 229-1444 - Fax (813) 443-5734
If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by
the attorneys or Court, you shall respond to this subpoena as directed.IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990,
PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL
ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT
THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE
PROCEEDING: FOR COURT PROCEEDINGS — CONTACT THE COURT A.D.A.
COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED
ATTORNEY.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we
must obtain satisfactory assurance from the party issuing the below-named subpoena that notice
has been provided to the patient whose protected health information has been subpoenaed. As
the attorney issuing the above-named subpoena, I hereby certify that the following statements are
true:
1. I have made a good faith attempt to provide written notice to the above-named patient that
his/her protected health information has been subpoenaed
2. The notice I provided included sufficient information about the litigation or proceeding for
which the protected health information is requested to permit the patient to raise an objection
to the court; and
3. The time for the patient to raise objections to the court has elapsed; and
1. No objections were filed; or
2. All objections filed by the patient were resolved by the court and the disclosures
being sought are consistent with such resolution.
Dated on this day of , 2021.
By: |
Mitch Katler
Law Offices of James W. Kehoe, III - Ft. Lauderdale
3230 W. Commercial Blvd., Ste. 250
Fort Lauderdale, Florida 33309
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
Telephone: (954) 677-3723
Facsimile No.: 866-292-4641
Primary E-Mail: mkatler@travelers.com
Secondary E-Mail: tgruende@travelers.com
cenrich@travelers.com
Florida Bar No.454982
Attomey for the DefendantPlease do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please
direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR
9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax
Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,005
CASE NO. 50-2021-CA-010108
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CIVIL DIVISION
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff(s),
vs.
EDENS LIMITED PARTNERSHIP D/B/A.
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: RECORDS CUSTODIAN
Bethesda Hospital East
Attn: Medical Records / HIM Department
2815 South Seacrest Boulevard
Boynton Beach, FL 33435
YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within
receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box
1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to:
records@choicelegal.com and to have the following for copying by Choice Legal:
RECORDS OF MARION J. YOUNG BUTERA
ANY AND ALL DOCUMENTS, CORRESPONDENCE, RECORDS, INCLUDING BUT
NOT LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT-
PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSE'S NOTES, COLORED
INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE DOCUMENTS, INITIAL
PATIENT QUESTIONNAIRE, SIGN IN SHEETS, ELECTRONIC RECORDS, ANY
AND ALL PHARMACY RECORDS, ALL DESCRIPTIONS OF EXERCISES
PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE AND TIME OFPATIENT'S APPOINTMENTS PERTAINING TO THE CARE OF TREATMENT AND
EXAMINATION OF THE PATIENT REGARDLESS OF TREATMENT DATE, ANY
AND ALL REPORTS OR CORRESPONDENCE INCLUDING BUT NOT LIMITED TO
OTHER PHYSICIANS OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT
NOT LIMITED TO CD ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE,
SCANNED DOCUMENTS AND ALL OTHER DOCUMENTS STORED
ELECTRONICALLY OR DIGITALLY. INCLUDE ALL PHYSICAL THERAPY
RECORDS. INCLUDE PHYSICIAN'S CURRICULUM VITAE, AND EVERY
WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S CHART,
INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. ALL
RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED
TO ONE INCIDENT. PLEASE ALSO PROVIDE ANY AND ALL LETTERS OF
PROTECTION YOU HAVE RECEIVED AS IT PERTAINS TO THE ABOVE-NAMED
INDIVIDUAL.
These items may 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
MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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
written notice to the attorney whose name appears on the subpoena. If you do not have records
on the requested party, provide a written note stating that your facility does not have the
information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
SEND RECORDS AND INVOICE TO:
RECORDS@CHOICELEGAL.COM
Choice Legal, Inc., PO Box 1215, Tampa, FL 33601
OR
Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619
Telephone (813) 229-1444 - Fax (813) 443-5734
If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by
the attorneys or Court, you shall respond to this subpoena as directed.
IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990,
PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL
ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT
THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE
PROCEEDING: FOR COURT PROCEEDINGS —- CONTACT THE COURT A.D.A.COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED
ATTORNEY.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we
must obtain satisfactory assurance from the party issuing the below-named subpoena that notice
has been provided to the patient whose protected health information has been subpoenaed. As
the attorney issuing the above-named subpoena, I hereby certify that the following statements are
true:
1. Ihave made a good faith attempt to provide written notice to the above-named patient that
his/her protected health information has been subpoenaed
2. The notice I provided included sufficient information about the litigation or proceeding for
which the protected health information is requested to permit the patient to raise an objection
to the court; and
3. The time for the patient to raise objections to the court has elapsed; and
1. No objections were filed; or
2. All objections filed by the patient were resolved by the court and the disclosures
being sought are consistent with such resolution.
Dated on this day of , 2021.
Mitch Katler
Law Offices of James W. Kehoe, III - Ft. Lauderdale
3230 W. Commercial Blvd., Ste. 250
Fort Lauderdale, Florida 33309
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
Telephone: (954) 677-3723
Facsimile No.: 866-292-4641
Primary E-Mail: mkatler@travelers.com
Secondary E-Mail: tgruende@travelers.com
cenrich@travelers.com
Florida Bar No.454982
Attomey for the Defendant
Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please
direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR
9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax
Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,006
CASE NO. 50-2021-CA-010108
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CIVIL DIVISION
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff(s),
vs.
EDENS LIMITED PARTNERSHIP D/B/A.
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: RECORDS CUSTODIAN
Bethesda Hospital East
Attn: Billing Records Dept.
2815 South Seacrest Blvd
Boynton Beach, FL 33435
YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within
receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box
1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to:
records@choicelegal.com and to have the following for copying by Choice Legal:
RECORDS OF MARION J. YOUNG BUTERA
ANY AND ALL BILLING RECORDS FROM ALL PROVIDERS WITHIN YOUR
PRACTICE, INCLUDING, BUT NOT LIMITED TO, ITEMIZED BILLING
STATEMENTS, AND ALL BILLING LEDGERS. PLEASE INCLUDE ANY AND ALL
HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N,
AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE
CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E"CODES ASSOCIATED WITH THE PRIMARY DOCTOR. ALL RECORDS SHOULD
BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ONE INCIDENT.
These items may 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
MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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
written notice to the attorney whose name appears on the subpoena. If you do not have records
on the requested party, provide a written note stating that your facility does not have the
information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
SEND RECORDS AND INVOICE TO:
RECORDS@CHOICELEGAL.COM
Choice Legal, Inc., PO Box 1215, Tampa, FL 33601
OR
Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619
Telephone (813) 229-1444 - Fax (813) 443-5734
If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by
the attorneys or Court, you shall respond to this subpoena as directed.
IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990,
PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL
ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT
THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE
PROCEEDING: FOR COURT PROCEEDINGS - CONTACT THE COURT A.D.A.
COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED
ATTORNEY.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we
must obtain satisfactory assurance from the party issuing the below-named subpoena that notice
has been provided to the patient whose protected health information has been subpoenaed. As
the attorney issuing the above-named subpoena, I hereby certify that the following statements are
true:1. Ihave made a good faith attempt to provide written notice to the above-named patient that
his/her protected health information has been subpoenaed
2. The notice I provided included sufficient information about the litigation or proceeding for
which the protected health information is requested to permit the patient to raise an objection
to the court; and
3. The time for the patient to raise objections to the court has elapsed; and
1. No objections were filed; or
2. All objections filed by the patient were resolved by the court and the disclosures
being sought are consistent with such resolution.
Dated on this day of , 2021.
Lan Kee
Mitch Katler
Law Offices of James W. Kehoe, III - Ft. Lauderdale
3230 W. Commercial Blvd., Ste. 250
Fort Lauderdale, Florida 33309
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
Telephone: (954) 677-3723
Facsimile No.: 866-292-4641
Primary E-Mail: mkatler@travelers.com
Secondary E-Mail: tgruende@travelers.com
cenrich@travelers.com
Florida Bar No.454982
Attomey for the Defendant
By:
Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please
direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR
9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax
Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,007
CASE NO. 50-2021-CA-010108
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CIVIL DIVISION
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff(s),
vs.
EDENS LIMITED PARTNERSHIP D/B/A.
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: RECORDS CUSTODIAN
One at Home-Palm Beach
23123 State Road 7
Boca Raton, FL 33428
YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within
receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box
1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to:
records@choicelegal.com and to have the following for copying by Choice Legal:
RECORDS OF MARION J. YOUNG BUTERA
ANY AND ALL WRITTEN AND ELECTRONIC DOCUMENTS, CORRESPONDENCE,
RECORDS AND ITEMIZED STATEMENTS OF CHARGES, INCLUDING BUT NOT
LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT-
PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSES NOTES, PAYMENT
HISTORY, COLORED INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE
DOCUMENTS, INITIAL PATIENT QUESTIONNAIRE, SIGN IN SHEETS,
ELECTRONIC RECORDS, ANY AND ALL PHARMACY RECORDS, ALL
DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICHINDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS PERTAINING TO
THE CARE OF TREATMENT AND EXAMINATION OF THE PATIENT
REGARDLESS OF TREATMENT DATE, ANY AND ALL REPORTS OR
CORRESPONDENCE INCLUDING BUT NOT LIMITED TO OTHER PHYSICIANS
OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT NOT LIMITED TO CD
ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED DOCUMENTS AND
ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR DIGITALLY.
INCLUDE ALL PHYSICAL THERAPY RECORDS. INCLUDE PHYSICIAN'S
CURRICULUM VITAE, AND EVERY WRITTEN PIECE OF PAPER INCLUDED
WITHIN THE PATIENTS CHART, INCLUDING A COPY OF ANY NOTATIONS ON
THE FILE JACKET. ALL BILLING RECORDS, INCLUDING ALL BILLING
LEDGERS. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO
WAY BE LIMITED TO ONE INCIDENT. PLEASE INCLUDE ANY AND ALL
HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N,
AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE
CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E"
CODES ASSOCIATED WITH THE PRIMARY DOCTOR. PLEASE ALSO PROVIDE
ANY AND ALL LETTERS OF PROTECTION YOU HAVE RECEIVED AS IT
PERTAINS TO THE ABOVE-NAMED INDIVIDUAL.
These items may 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
MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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
written notice to the attorney whose name appears on the subpoena. If you do not have records
on the requested party, provide a written note stating that your facility does not have the
information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
SEND RECORDS AND INVOICE TO:
RECORDS@CHOICELEGAL.COM
Choice Legal, Inc., PO Box 1215, Tampa, FL 33601
OR
Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619
Telephone (813) 229-1444 - Fax (813) 443-5734
If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by
the attorneys or Court, you shall respond to this subpoena as directed.IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990,
PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL
ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT
THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE
PROCEEDING: FOR COURT PROCEEDINGS — CONTACT THE COURT A.D.A.
COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED
ATTORNEY.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we
must obtain satisfactory assurance from the party issuing the below-named subpoena that notice
has been provided to the patient whose protected health information has been subpoenaed. As
the attorney issuing the above-named subpoena, I hereby certify that the following statements are
true:
1. Ihave made a good faith attempt to provide written notice to the above-named patient that
his/her protected health information has been subpoenaed
2. The notice I provided included sufficient information about the litigation or proceeding for
which the protected health information is requested to permit the patient to raise an objection
to the court; and
3. The time for the patient to raise objections to the court has elapsed; and
1. No objections were filed; or
2. All objections filed by the patient were resolved by the court and the disclosures
being sought are consistent with such resolution.
Dated on this day of , 2021.
Mitch Katler
Law Offices of James W. Kehoe, III - Ft. Lauderdale
3230 W. Commercial Blvd., Ste. 250
Fort Lauderdale, Florida 33309
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
Telephone: (954) 677-3723
Facsimile No.: 866-292-4641
Primary E-Mail: mkatler@travelers.com
Secondary E-Mail: tgruende@travelers.com
cenrich@travelers.com
Florida Bar No.454982
Attorney for the DefendantPlease do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please
direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR
9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax
Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,008
CASE NO. 50-2021-CA-010108
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CIVIL DIVISION
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff(s),
vs.
EDENS LIMITED PARTNERSHIP D/B/A.
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
To: RECORDS CUSTODIAN
Woolbright Physical Therapy
2015 Ocean Drive, Suite 1
Boynton Beach, FL 33426-5131
YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within
receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box
1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to:
records@choicelegal.com and to have the following for copying by Choice Legal:
RECORDS OF MARION J. YOUNG BUTERA
ANY AND ALL WRITTEN AND ELECTRONIC DOCUMENTS, CORRESPONDENCE,
RECORDS AND ITEMIZED STATEMENTS OF CHARGES, INCLUDING BUT NOT
LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT-
PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSES NOTES, PAYMENT
HISTORY, COLORED INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE
DOCUMENTS, INITIAL PATIENT QUESTIONNAIRE, SIGN IN SHEETS,
ELECTRONIC RECORDS, ANY AND ALL PHARMACY RECORDS, ALL
DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICHINDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS PERTAINING TO
THE CARE OF TREATMENT AND EXAMINATION OF THE PATIENT
REGARDLESS OF TREATMENT DATE, ANY AND ALL REPORTS OR
CORRESPONDENCE INCLUDING BUT NOT LIMITED TO OTHER PHYSICIANS
OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT NOT LIMITED TO CD
ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED DOCUMENTS AND
ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR DIGITALLY.
INCLUDE ALL PHYSICAL THERAPY RECORDS. INCLUDE PHYSICIAN'S
CURRICULUM VITAE, AND EVERY WRITTEN PIECE OF PAPER INCLUDED
WITHIN THE PATIENTS CHART, INCLUDING A COPY OF ANY NOTATIONS ON
THE FILE JACKET. ALL BILLING RECORDS, INCLUDING ALL BILLING
LEDGERS. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO
WAY BE LIMITED TO ONE INCIDENT. PLEASE INCLUDE ANY AND ALL
HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N,
AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE
CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E"
CODES ASSOCIATED WITH THE PRIMARY DOCTOR. PLEASE ALSO PROVIDE
ANY AND ALL LETTERS OF PROTECTION YOU HAVE RECEIVED AS IT
PERTAINS TO THE ABOVE-NAMED INDIVIDUAL.
These items may 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
MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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
written notice to the attorney whose name appears on the subpoena. If you do not have records
on the requested party, provide a written note stating that your facility does not have the
information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
SEND RECORDS AND INVOICE TO:
RECORDS@CHOICELEGAL.COM
Choice Legal, Inc., PO Box 1215, Tampa, FL 33601
OR
Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619
Telephone (813) 229-1444 - Fax (813) 443-5734
If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by
the attorneys or Court, you shall respond to this subpoena as directed.IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990,
PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL
ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT
THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE
PROCEEDING: FOR COURT PROCEEDINGS — CONTACT THE COURT A.D.A.
COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED
ATTORNEY.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we
must obtain satisfactory assurance from the party issuing the below-named subpoena that notice
has been provided to the patient whose protected health information has been subpoenaed. As
the attorney issuing the above-named subpoena, I h
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Filing # 141103402 E-Filed 12/29/2021 04:15:36 PM Choice # 124379, 1-12 CASE NO. 50-2021-CA-010108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff(s), vs. EDENS LIMITED PARTNERSHIP D/B/A SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). / NOTICE OF PRODUCTION FROM NON-PARTY To: Barry C. Hoffman, Esq. Barry G. Hoffman Law Office, PA 9045 La Fontana Boulevard, Suite 1106 Boca Raton, FL 33434 Primary E-Mail: hchlawoffice@aol.com David J. Majeak Goldberg Segalla, LLP 222 Lakeview Avenue, Suite 800 West Palm Beach, FL 33401 Primary E-Mail: dmajcak@goldbergsegalla.com Secondary E-Mail: kgomberg@goldbergsegalla.com YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this notice, if notice is by delivery/fax/e-mail or fifteen (15) days from the date of service, if service is by mail, and if no objection is received from any party, the undersigned will issue the attached subpoena(s) directed to the records custodian of: Bethesda Memorial Hospital (Medical) Attn: Medical Records 3800 S. Congress Ave. Ste 3 Boynton Beach, FL 33426 *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/29/2021 04:15:36 PM ***Bethesda Memorial Hospital (Billing) Attn: Billing Records Dept. 3800 S. Congress Ave. Ste 3 Boynton Beach, FL 33426 Bethesda Memorial Hospital (Films) Attn: Radiology Department 3800 S. Congress Ave. Ste 3 Boynton Beach, FL 33426 Boynton Beach, FL 33426 New Med M.D. PA and/or Dr. Martha Rodriguez (Medical & Billing) 2015 Ocean Dr., Suite 11 Boynton Beach, FL 33426 Bethesda Hospital East (Medical) Attn: Medical Records / HIM Department 2815 South Seacrest Boulevard Boynton Beach, FL 33435 Bethesda Hospital East (Billing) Attn: Billing Records Dept. 2815 South Seacrest Blvd Boynton Beach, FL 33435 One at Home-Palm Beach (Medical & Billing) 23123 State Road 7 Boca Raton, FL 33428 Woolbright Physical Therapy (Medical & Billing) 2015 Ocean Drive, Suite 1 Boynton Beach, FL 33426-5131 National Orthopedics and Neurosurgery, P.A. (Medical & Billing) 3618 Lantana Road, Suite 100 Lake Worth, FL 33462 Humana (Insurance - Health) P.O. Box 14601 Lexington, KY 40512-4601 JB Cruises (Employment) Attn: Human Resources 7460 Boynton Beach Blvd. Boynton Beach, FL 33437H. Ising's, Inc. (Employment) Attn: Human Resources 10481 N. 150th Ct. Jupiter, FL 33478 who are not a party to this suit, to produce the items listed by the method at the time and place specified in the subpoena. _x_ This notice was served via E-MAIL CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing was furnished in accordance with the Florida Rule of Judicial Administration 2.516, to: Barry C. Hoffman, Esq. Barry G. Hoffman Law Office, PA 9045 La Fontana Boulevard, Suite 1106 Boca Raton, FL 33434 Primary E-Mail: hchlawoffice@aol.com David J. Majeak Goldberg Segalla, LLP 222 Lakeview Avenue, Suite 800 West Palm Beach, FL 33401 Primary E-Mail: dmajcak@goldbergsegalla.com Secondary E-Mail: kgomberg@goldbergsegalla.com on this 29th day of December 2021. on __ Pdehatp Keter Mitch Katler Law Offices of James W. Kehoe, III - Ft. Lauderdale 3230 W. Commercial Blvd., Ste. 250 Fort Lauderdale, Florida 33309 Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 Telephone: (954) 677-3723 Facsimile No.: 866-292-4641 Primary E-Mail: mkatler@travelers.com Secondary E-Mail: tgruende@travelers.com cenrich@travelers.com Florida Bar No.454982 Attomey for the DefendantChoice Legal, Inc. PO Box 1215 Tampa, Florida 33601 Phone: (813) 229-1444 Fax: (813) 324-5191 COPY REQUEST FORM To: Barry C. Hoffman, Esq. Barry G. Hoffman Law Office, PA 9045 La Fontana Boulevard, Suite 1106 Boca Raton, FL 33434 Primary E-Mail: hchlawoffice@aol.com David J. Majcak Goldberg Segalla, LLP 222 Lakeview Avenue, Suite 800 West Palm Beach, FL 33401 Primary E-Mail: dmajcak@goldbergsegalla.com Secondary E-Mail: kgomberg@goldbergsegalla.com Re: Marion J. Young Butera and Thomas Butera v. Edens Limited Partnership, et al. Order No.: 124379 Records of: MARION J. YOUNG BUTERA Please check the appropriate boxes and fax or mail to CHOICE LEGAL, INC. to request exact copies. Requests cannot be accepted without a signature and date. DO NOT SEND PAYMENT AT THIS TIME- YOU WILL RECEIVE AN INVOICE PRIOR TO RECEIVING RECORDS. Any and all copies of films must be obtained from defense counsel. LOCATIONS Check box for requested records Bethesda Memorial Hospital (Medical) Attn: Medical Records 3800 S. Congress Ave. Ste 3 Boynton Beach, FL 33426 ] Bethesda Memorial Hospital (Billing) Attn: Billing Records Dept. 3800 S. Congress Ave. Ste 3 Boynton Beach, FL 33426 l Bethesda Memorial Hospital (Films) Attn: Radiology Department 3800 S. Congress Ave. Ste 3 Boynton Beach, FL 33426 U New Med MLD. PA and/or Dr. Martha Rodriguez (Medical & Billing) 2015 Ocean Dr., Suite 11 Boynton Beach, FL 33426 tl Bethesda Hospital East (Medical) Attn: Medical Records / HIM Department 2815 South Seacrest Boulevard Boynton Beach, FL 33435 ]Bethesda Hospital East (Billing) Attn: Billing Records Dept. 2815 South Seacrest Blvd Boynton Beach, FL 33435 One at Home-Palm Beach (Medical & Billing) 23123 State Road 7 Boca Raton, FL 33428 Woolbright Physical Therapy (Medical & Billing) 2015 Ocean Drive, Suite 1 Boynton Beach, FL 33426-5131 National Orthopedics and Neurosurgery, P.A. (Medical & Billing) 3618 Lantana Road, Suite 100 Lake Worth, FL 33462 Humana (Insurance - Health) P.O. Box 14601 Lexington, KY 40512-4601 JB Cruises (Employment) Attn: Human Resources 7460 Boynton Beach Blvd. Boynton Beach, FL 33437 H. Ising's, Inc. (Employment) Attn: Human Resources 10481 N. 150th Ct. Jupiter, FL 33478 Do you agree to waive the 10 day hold? YES Requested by: Ul Ul U] Ul U Ul {1 NO NAME (PLEASE PRINT) SIGNATURE DATE TELEPHONE NUMBER =*~Our copy fee(s) is $0.25 a page plus a postage and handling fee of $8.00. Records are also available on CD. The fee for these services is $50.00 flat rate up to 500 pages. At 501 pages or more, there will be a $0.10 per page fee. A $5.00 shipping fee will be charged for mailing a CD. Records are also available online for the same cost as the CD option. If you wish to order copies of records and do not yet have an account, please e-mail Ashleigh at Ashleigh. Morrow@ChoiceLegal. com to receive access to your records online. (Records will be available for viewing once payment has been received). Copies of these records can also be obtained from defense counsel directly.***Choice # 124379,001 CASE NO. 50-2021-CA-010108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff(s), vs. EDENS LIMITED PARTNERSHIP D/B/A. SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: RECORDS CUSTODIAN Bethesda Memorial Hospital Attn: Medical Records 3800 S. Congress Ave. Ste 3 Boynton Beach, FL 33426 YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to: records@choicelegal.com and to have the following for copying by Choice Legal: RECORDS OF MARION J. YOUNG BUTERA ANY AND ALL DOCUMENTS, CORRESPONDENCE, RECORDS, INCLUDING BUT NOT LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT- PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSE'S NOTES, COLORED INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE DOCUMENTS, INITIAL PATIENT QUESTIONNAIRE, SIGN IN SHEETS, ELECTRONIC RECORDS, ANY AND ALL PHARMACY RECORDS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE AND TIME OFPATIENT'S APPOINTMENTS PERTAINING TO THE CARE OF TREATMENT AND EXAMINATION OF THE PATIENT REGARDLESS OF TREATMENT DATE, ANY AND ALL REPORTS OR CORRESPONDENCE INCLUDING BUT NOT LIMITED TO OTHER PHYSICIANS OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT NOT LIMITED TO CD ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED DOCUMENTS AND ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR DIGITALLY. INCLUDE ALL PHYSICAL THERAPY RECORDS. INCLUDE PHYSICIAN'S CURRICULUM VITAE, AND EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ONE INCIDENT. PLEASE ALSO PROVIDE ANY AND ALL LETTERS OF PROTECTION YOU HAVE RECEIVED AS IT PERTAINS TO THE ABOVE-NAMED INDIVIDUAL. These items may 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 MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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 written notice to the attorney whose name appears on the subpoena. If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. SEND RECORDS AND INVOICE TO: RECORDS@CHOICELEGAL.COM Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619 Telephone (813) 229-1444 - Fax (813) 443-5734 If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or Court, you shall respond to this subpoena as directed. IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990, PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE PROCEEDING: FOR COURT PROCEEDINGS —- CONTACT THE COURT A.D.A.COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED ATTORNEY. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. As the attorney issuing the above-named subpoena, I hereby certify that the following statements are true: 1. Ihave made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed 2. The notice I provided included sufficient information about the litigation or proceeding for which the protected health information is requested to permit the patient to raise an objection to the court; and 3. The time for the patient to raise objections to the court has elapsed; and 1. No objections were filed; or 2. All objections filed by the patient were resolved by the court and the disclosures being sought are consistent with such resolution. Dated on this day of , 2021. Mitch Katler Law Offices of James W. Kehoe, III - Ft. Lauderdale 3230 W. Commercial Blvd., Ste. 250 Fort Lauderdale, Florida 33309 Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 Telephone: (954) 677-3723 Facsimile No.: 866-292-4641 Primary E-Mail: mkatler@travelers.com Secondary E-Mail: tgruende@travelers.com cenrich@travelers.com Florida Bar No.454982 Attomey for the Defendant Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,002 CASE NO. 50-2021-CA-010108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff(s), vs. EDENS LIMITED PARTNERSHIP D/B/A. SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: RECORDS CUSTODIAN Bethesda Memorial Hospital Attn: Billing Records 3800 S. Congress Ave. Ste 3 Boynton Beach, FL 33426 YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to: records@choicelegal.com and to have the following for copying by Choice Legal: RECORDS OF MARION J. YOUNG BUTERA ANY AND ALL BILLING RECORDS FROM ALL PROVIDERS WITHIN YOUR PRACTICE, INCLUDING, BUT NOT LIMITED TO, ITEMIZED BILLING STATEMENTS, AND ALL BILLING LEDGERS. PLEASE INCLUDE ANY AND ALL HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N, AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E"CODES ASSOCIATED WITH THE PRIMARY DOCTOR. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ONE INCIDENT. These items may 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 MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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 written notice to the attorney whose name appears on the subpoena. If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. SEND RECORDS AND INVOICE TO: RECORDS@CHOICELEGAL.COM Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619 Telephone (813) 229-1444 - Fax (813) 443-5734 If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or Court, you shall respond to this subpoena as directed. IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990, PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE PROCEEDING: FOR COURT PROCEEDINGS - CONTACT THE COURT A.D.A. COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED ATTORNEY. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. As the attorney issuing the above-named subpoena, I hereby certify that the following statements are true:1. I have made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed 2. The notice I provided included sufficient information about the litigation or proceeding for which the protected health information is requested to permit the patient to raise an objection to the court; and 3. The time for the patient to raise objections to the court has elapsed; and 1. No objections were filed; or 2. All objections filed by the patient were resolved by the court and the disclosures being sought are consistent with such resolution. Dated on this day of , 2021. By: f Mitch Katler Law Offices of James W. Kehoe, III - Ft. Lauderdale 3230 W. Commercial Blvd., Ste. 250 Fort Lauderdale, Florida 33309 Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 Telephone: (954) 677-3723 Facsimile No.: 866-292-4641 Primary E-Mail: mkatler@travelers.com Secondary E-Mail: tgruende@travelers.com cenrich@travelers.com Florida Bar No.454982 Attomey for the Defendant Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,003 CASE NO. 50-2021-CA-010108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff(s), vs. EDENS LIMITED PARTNERSHIP D/B/A. SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: RECORDS CUSTODIAN Bethesda Memorial Hospital Attn: Radiology 3800 S. Congress Ave. Ste 3 Boynton Beach, FL 33426 YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to: records@choicelegal.com and to have the following for copying by Choice Legal: RECORDS OF MARION J. YOUNG BUTERA ANY AND ALL COPIES OF ALL DIAGNOSTIC STUDIES, INCLUDING BUT NOT LIMITED TO: FILMS, RADIOLOGICAL AND DIAGNOSTICE REPORTS, X-RAYS, MRI FILMS, PET SCANS, CT SCANS, FLUOROSCOPY, ULTRASOUNDS, AND COLORED INTRA-OPERATIVE PHOTOGRAPHS, PERTAINING TO THE ABOVE PATIENT. PLEASE PROVIDE A FULL AND COMPLETE FILM BREAKDOWN (FORM ATTACHED) OF ALL FILMS OF ANY TYPE (MRI, CT, X-RAY, ULTRASOUND, ETC.) PRIOR TO DUPLICATION AND ORDER. ALL RECORDSAND FILMS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ANY ONE INCIDENT, AND SHOULD INCLUDE ALL WRITTEN AND ELECTRONIC RECORDS. PLEASE CALL BEFORE SENDING FILMS. These items may 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 MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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 written notice to the attorney whose name appears on the subpoena. If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. SEND RECORDS AND INVOICE TO: RECORDS@CHOICELEGAL.COM Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619 Telephone (813) 229-1444 - Fax (813) 443-5734 If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or Court, you shall respond to this subpoena as directed. IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990, PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE PROCEEDING: FOR COURT PROCEEDINGS —- CONTACT THE COURT A.D.A. COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED ATTORNEY. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. As the attorney issuing the above-named subpoena, I hereby certify that the following statements are true:1. I have made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed 2. The notice I provided included sufficient information about the litigation or proceeding for which the protected health information is requested to permit the patient to raise an objection to the court; and 3. The time for the patient to raise objections to the court has elapsed; and 1. No objections were filed; or 2. All objections filed by the patient were resolved by the court and the disclosures being sought are consistent with such resolution. Dated on this day of , 2021. By: Mitch Katler Law Offices of James W. Kehoe, III - Ft. Lauderdale 3230 W. Commercial Blvd., Ste. 250 Fort Lauderdale, Florida 33309 Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 Telephone: (954) 677-3723 Facsimile No.: 866-292-4641 Primary E-Mail: mkatler@travelers.com Secondary E-Mail: tgruende@travelers.com cenrich@travelers.com Florida Bar No.454982 Attomey for the Defendant Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,004 CASE NO. 50-2021-CA-010108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff(s), vs. EDENS LIMITED PARTNERSHIP D/B/A. SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: RECORDS CUSTODIAN New Med M.D. PA and/or Dr. Martha Rodriguez 2015 Ocean Dr., Suite 11 Boynton Beach, FL 33426 YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to: records@choicelegal.com and to have the following for copying by Choice Legal: RECORDS OF MARION J. YOUNG BUTERA ANY AND ALL WRITTEN AND ELECTRONIC DOCUMENTS, CORRESPONDENCE, RECORDS AND ITEMIZED STATEMENTS OF CHARGES, INCLUDING BUT NOT LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT- PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSES NOTES, PAYMENT HISTORY, COLORED INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE DOCUMENTS, INITIAL PATIENT QUESTIONNAIRE, SIGN IN SHEETS, ELECTRONIC RECORDS, ANY AND ALL PHARMACY RECORDS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICHINDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS PERTAINING TO THE CARE OF TREATMENT AND EXAMINATION OF THE PATIENT REGARDLESS OF TREATMENT DATE, ANY AND ALL REPORTS OR CORRESPONDENCE INCLUDING BUT NOT LIMITED TO OTHER PHYSICIANS OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT NOT LIMITED TO CD ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED DOCUMENTS AND ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR DIGITALLY. INCLUDE ALL PHYSICAL THERAPY RECORDS. INCLUDE PHYSICIAN'S CURRICULUM VITAE, AND EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENTS CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. ALL BILLING RECORDS, INCLUDING ALL BILLING LEDGERS. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ONE INCIDENT. PLEASE INCLUDE ANY AND ALL HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N, AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E" CODES ASSOCIATED WITH THE PRIMARY DOCTOR. PLEASE ALSO PROVIDE ANY AND ALL LETTERS OF PROTECTION YOU HAVE RECEIVED AS IT PERTAINS TO THE ABOVE-NAMED INDIVIDUAL. These items may 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 MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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 written notice to the attorney whose name appears on the subpoena. If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. SEND RECORDS AND INVOICE TO: RECORDS@CHOICELEGAL.COM Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619 Telephone (813) 229-1444 - Fax (813) 443-5734 If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or Court, you shall respond to this subpoena as directed.IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990, PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE PROCEEDING: FOR COURT PROCEEDINGS — CONTACT THE COURT A.D.A. COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED ATTORNEY. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. As the attorney issuing the above-named subpoena, I hereby certify that the following statements are true: 1. I have made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed 2. The notice I provided included sufficient information about the litigation or proceeding for which the protected health information is requested to permit the patient to raise an objection to the court; and 3. The time for the patient to raise objections to the court has elapsed; and 1. No objections were filed; or 2. All objections filed by the patient were resolved by the court and the disclosures being sought are consistent with such resolution. Dated on this day of , 2021. By: | Mitch Katler Law Offices of James W. Kehoe, III - Ft. Lauderdale 3230 W. Commercial Blvd., Ste. 250 Fort Lauderdale, Florida 33309 Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 Telephone: (954) 677-3723 Facsimile No.: 866-292-4641 Primary E-Mail: mkatler@travelers.com Secondary E-Mail: tgruende@travelers.com cenrich@travelers.com Florida Bar No.454982 Attomey for the DefendantPlease do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,005 CASE NO. 50-2021-CA-010108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff(s), vs. EDENS LIMITED PARTNERSHIP D/B/A. SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: RECORDS CUSTODIAN Bethesda Hospital East Attn: Medical Records / HIM Department 2815 South Seacrest Boulevard Boynton Beach, FL 33435 YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to: records@choicelegal.com and to have the following for copying by Choice Legal: RECORDS OF MARION J. YOUNG BUTERA ANY AND ALL DOCUMENTS, CORRESPONDENCE, RECORDS, INCLUDING BUT NOT LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT- PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSE'S NOTES, COLORED INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE DOCUMENTS, INITIAL PATIENT QUESTIONNAIRE, SIGN IN SHEETS, ELECTRONIC RECORDS, ANY AND ALL PHARMACY RECORDS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE AND TIME OFPATIENT'S APPOINTMENTS PERTAINING TO THE CARE OF TREATMENT AND EXAMINATION OF THE PATIENT REGARDLESS OF TREATMENT DATE, ANY AND ALL REPORTS OR CORRESPONDENCE INCLUDING BUT NOT LIMITED TO OTHER PHYSICIANS OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT NOT LIMITED TO CD ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED DOCUMENTS AND ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR DIGITALLY. INCLUDE ALL PHYSICAL THERAPY RECORDS. INCLUDE PHYSICIAN'S CURRICULUM VITAE, AND EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ONE INCIDENT. PLEASE ALSO PROVIDE ANY AND ALL LETTERS OF PROTECTION YOU HAVE RECEIVED AS IT PERTAINS TO THE ABOVE-NAMED INDIVIDUAL. These items may 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 MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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 written notice to the attorney whose name appears on the subpoena. If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. SEND RECORDS AND INVOICE TO: RECORDS@CHOICELEGAL.COM Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619 Telephone (813) 229-1444 - Fax (813) 443-5734 If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or Court, you shall respond to this subpoena as directed. IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990, PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE PROCEEDING: FOR COURT PROCEEDINGS —- CONTACT THE COURT A.D.A.COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED ATTORNEY. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. As the attorney issuing the above-named subpoena, I hereby certify that the following statements are true: 1. Ihave made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed 2. The notice I provided included sufficient information about the litigation or proceeding for which the protected health information is requested to permit the patient to raise an objection to the court; and 3. The time for the patient to raise objections to the court has elapsed; and 1. No objections were filed; or 2. All objections filed by the patient were resolved by the court and the disclosures being sought are consistent with such resolution. Dated on this day of , 2021. Mitch Katler Law Offices of James W. Kehoe, III - Ft. Lauderdale 3230 W. Commercial Blvd., Ste. 250 Fort Lauderdale, Florida 33309 Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 Telephone: (954) 677-3723 Facsimile No.: 866-292-4641 Primary E-Mail: mkatler@travelers.com Secondary E-Mail: tgruende@travelers.com cenrich@travelers.com Florida Bar No.454982 Attomey for the Defendant Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,006 CASE NO. 50-2021-CA-010108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff(s), vs. EDENS LIMITED PARTNERSHIP D/B/A. SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: RECORDS CUSTODIAN Bethesda Hospital East Attn: Billing Records Dept. 2815 South Seacrest Blvd Boynton Beach, FL 33435 YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to: records@choicelegal.com and to have the following for copying by Choice Legal: RECORDS OF MARION J. YOUNG BUTERA ANY AND ALL BILLING RECORDS FROM ALL PROVIDERS WITHIN YOUR PRACTICE, INCLUDING, BUT NOT LIMITED TO, ITEMIZED BILLING STATEMENTS, AND ALL BILLING LEDGERS. PLEASE INCLUDE ANY AND ALL HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N, AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E"CODES ASSOCIATED WITH THE PRIMARY DOCTOR. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ONE INCIDENT. These items may 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 MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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 written notice to the attorney whose name appears on the subpoena. If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. SEND RECORDS AND INVOICE TO: RECORDS@CHOICELEGAL.COM Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619 Telephone (813) 229-1444 - Fax (813) 443-5734 If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or Court, you shall respond to this subpoena as directed. IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990, PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE PROCEEDING: FOR COURT PROCEEDINGS - CONTACT THE COURT A.D.A. COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED ATTORNEY. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. As the attorney issuing the above-named subpoena, I hereby certify that the following statements are true:1. Ihave made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed 2. The notice I provided included sufficient information about the litigation or proceeding for which the protected health information is requested to permit the patient to raise an objection to the court; and 3. The time for the patient to raise objections to the court has elapsed; and 1. No objections were filed; or 2. All objections filed by the patient were resolved by the court and the disclosures being sought are consistent with such resolution. Dated on this day of , 2021. Lan Kee Mitch Katler Law Offices of James W. Kehoe, III - Ft. Lauderdale 3230 W. Commercial Blvd., Ste. 250 Fort Lauderdale, Florida 33309 Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 Telephone: (954) 677-3723 Facsimile No.: 866-292-4641 Primary E-Mail: mkatler@travelers.com Secondary E-Mail: tgruende@travelers.com cenrich@travelers.com Florida Bar No.454982 Attomey for the Defendant By: Please do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,007 CASE NO. 50-2021-CA-010108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff(s), vs. EDENS LIMITED PARTNERSHIP D/B/A. SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: RECORDS CUSTODIAN One at Home-Palm Beach 23123 State Road 7 Boca Raton, FL 33428 YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to: records@choicelegal.com and to have the following for copying by Choice Legal: RECORDS OF MARION J. YOUNG BUTERA ANY AND ALL WRITTEN AND ELECTRONIC DOCUMENTS, CORRESPONDENCE, RECORDS AND ITEMIZED STATEMENTS OF CHARGES, INCLUDING BUT NOT LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT- PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSES NOTES, PAYMENT HISTORY, COLORED INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE DOCUMENTS, INITIAL PATIENT QUESTIONNAIRE, SIGN IN SHEETS, ELECTRONIC RECORDS, ANY AND ALL PHARMACY RECORDS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICHINDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS PERTAINING TO THE CARE OF TREATMENT AND EXAMINATION OF THE PATIENT REGARDLESS OF TREATMENT DATE, ANY AND ALL REPORTS OR CORRESPONDENCE INCLUDING BUT NOT LIMITED TO OTHER PHYSICIANS OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT NOT LIMITED TO CD ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED DOCUMENTS AND ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR DIGITALLY. INCLUDE ALL PHYSICAL THERAPY RECORDS. INCLUDE PHYSICIAN'S CURRICULUM VITAE, AND EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENTS CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. ALL BILLING RECORDS, INCLUDING ALL BILLING LEDGERS. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ONE INCIDENT. PLEASE INCLUDE ANY AND ALL HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N, AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E" CODES ASSOCIATED WITH THE PRIMARY DOCTOR. PLEASE ALSO PROVIDE ANY AND ALL LETTERS OF PROTECTION YOU HAVE RECEIVED AS IT PERTAINS TO THE ABOVE-NAMED INDIVIDUAL. These items may 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 MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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 written notice to the attorney whose name appears on the subpoena. If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. SEND RECORDS AND INVOICE TO: RECORDS@CHOICELEGAL.COM Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619 Telephone (813) 229-1444 - Fax (813) 443-5734 If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or Court, you shall respond to this subpoena as directed.IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990, PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE PROCEEDING: FOR COURT PROCEEDINGS — CONTACT THE COURT A.D.A. COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED ATTORNEY. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. As the attorney issuing the above-named subpoena, I hereby certify that the following statements are true: 1. Ihave made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed 2. The notice I provided included sufficient information about the litigation or proceeding for which the protected health information is requested to permit the patient to raise an objection to the court; and 3. The time for the patient to raise objections to the court has elapsed; and 1. No objections were filed; or 2. All objections filed by the patient were resolved by the court and the disclosures being sought are consistent with such resolution. Dated on this day of , 2021. Mitch Katler Law Offices of James W. Kehoe, III - Ft. Lauderdale 3230 W. Commercial Blvd., Ste. 250 Fort Lauderdale, Florida 33309 Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 Telephone: (954) 677-3723 Facsimile No.: 866-292-4641 Primary E-Mail: mkatler@travelers.com Secondary E-Mail: tgruende@travelers.com cenrich@travelers.com Florida Bar No.454982 Attorney for the DefendantPlease do not respond to Law Offices of James W. Kehoe, III - Ft. Lauderdale. Please direct any questions or response to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Dr., Tampa FL 33619. Telephone Number (813) 229-1444 and Fax Number (813) 443-5734, E-Mail: records@choicelegal.com. Thank you.Choice # 124379,008 CASE NO. 50-2021-CA-010108 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff(s), vs. EDENS LIMITED PARTNERSHIP D/B/A. SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION To: RECORDS CUSTODIAN Woolbright Physical Therapy 2015 Ocean Drive, Suite 1 Boynton Beach, FL 33426-5131 YOU ARE HEREBY COMMANDED to furnish no later than twenty (20) days within receipt of this Subpoena Duces Tecum Without Deposition, to Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR 9204 King Palm Drive, Tampa FL 33619, or via e-mail to: records@choicelegal.com and to have the following for copying by Choice Legal: RECORDS OF MARION J. YOUNG BUTERA ANY AND ALL WRITTEN AND ELECTRONIC DOCUMENTS, CORRESPONDENCE, RECORDS AND ITEMIZED STATEMENTS OF CHARGES, INCLUDING BUT NOT LIMITED TO: ALL OFFICE, EMERGENCY ROOM, IN-PATIENT AND OUT- PATIENT CHARTS AND RECORDS, DOCTOR'S AND NURSES NOTES, PAYMENT HISTORY, COLORED INTRA-OPERATIVE PHOTOGRAPHS, INSURANCE DOCUMENTS, INITIAL PATIENT QUESTIONNAIRE, SIGN IN SHEETS, ELECTRONIC RECORDS, ANY AND ALL PHARMACY RECORDS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICHINDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS PERTAINING TO THE CARE OF TREATMENT AND EXAMINATION OF THE PATIENT REGARDLESS OF TREATMENT DATE, ANY AND ALL REPORTS OR CORRESPONDENCE INCLUDING BUT NOT LIMITED TO OTHER PHYSICIANS OR OTHER HOSPITALS IN YOUR FILE, INCLUDING BUT NOT LIMITED TO CD ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED DOCUMENTS AND ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR DIGITALLY. INCLUDE ALL PHYSICAL THERAPY RECORDS. INCLUDE PHYSICIAN'S CURRICULUM VITAE, AND EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENTS CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. ALL BILLING RECORDS, INCLUDING ALL BILLING LEDGERS. ALL RECORDS SHOULD BE ALL INCLUSIVE AND SHOULD IN NO WAY BE LIMITED TO ONE INCIDENT. PLEASE INCLUDE ANY AND ALL HCFA/CMS-1500 BILLING FORMS AND/OR UB-92/UB-04 FORMS, BILLING R&N, AND BILLING HB 4 FORMS. PLEASE ALSO INCLUDE ALL CPT OR PROCEDURE CODES, HCPCS CODES, ICD-9 CODES, ICD-10 CODES AND ANY AND ALL "E" CODES ASSOCIATED WITH THE PRIMARY DOCTOR. PLEASE ALSO PROVIDE ANY AND ALL LETTERS OF PROTECTION YOU HAVE RECEIVED AS IT PERTAINS TO THE ABOVE-NAMED INDIVIDUAL. These items may 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 MAILING COPIES TO CHOICE LEGAL, THE AGENT FOR 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 written notice to the attorney whose name appears on the subpoena. If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. SEND RECORDS AND INVOICE TO: RECORDS@CHOICELEGAL.COM Choice Legal, Inc., PO Box 1215, Tampa, FL 33601 OR Choice Legal, Inc., 9204 King Palm Drive, Tampa FL 33619 Telephone (813) 229-1444 - Fax (813) 443-5734 If copy costs exceed $300.00 please contact Choice Legal, Inc. for approval If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena; you may be in contempt of court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or Court, you shall respond to this subpoena as directed.IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990, PERSONS, INCLUDING THE HEARING IMPAIRED, NEEDING A_ SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING NEEDS TO CONTACT THE FOLLOWING PERSON NO LATER THAT SEVEN (7) DAYS PRIOR TO THE PROCEEDING: FOR COURT PROCEEDINGS — CONTACT THE COURT A.D.A. COORDINATOR; AND FOR DEPOSITIONS — CONTACT THE UNDERSIGNED ATTORNEY. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act — HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. As the attorney issuing the above-named subpoena, I h