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Filing # 122994020 E-Filed 03/12/2021 11:05:37 AM
AFFIDAVIT OF SERVICE
State of Florida County of Broward
Case Number: CACE20017273 Court Date: 3/3/2021
Plaintiff:
EVELYN ZAFRANI and ESTHER EMERGUI
vs.
Defendant:
PROGRESSIVE SELECT INSURANCE COMAPNY, a foreign corporation
For:
YASSER KADER, ESQUIRE
Law Office of Michael W. Carroll (FTL)
Fla Bar No: 682691
3230 W. Commercial Blvd., Suite 400
Ft. Lauderdale, FL 33309
Received by THE SUBPOENA, SUMMONS & AFFIDAVIT CO. to be served on DR. CLINTON BURKETT RECORD
CUSTODIAN, 1150 N. 35TH AVE., # 300, HOLLYWOOD, FL 33021.
|, LUISA MIJARES, being duly sworn, depose and say that on the 22nd day of January, 2021 at 4:44 pm, |:
AUTHORIZED: served a true copy of the SUBPOENA DUCES TECUM(Pursuant to F.R.C.P. 1.351(c), effective
1/1/2011, this Subpoena may be served by mail or by hand delivery by a commercial delivery service) and
NOTICE OF PRODUCTION FROM NON PARTY with the date and hour of service endorsed thereon by me, to:
EMPLOYEE - PHONE 954-228-6807,
Additional Information pertaining to this Service:
RE: EVELYN ZAFRANI
4/22/2021 4:44 pm 1150 N. 35TH AVE., # 300, HOLLYWOOD, FL 33021 - EMPLOYEE - PHONE 954-228-6807
THE AFFIANT, being duly sworn, states: | certify that | am over the age of 18, have no interest in the above action,
and | am authorized by law, in good standing, to serve process in the judicial circuit in which the process was served.
al
LUISA MIJARES a
Subscribed and Sworn to before me by the affiant who is Process Server 4
personally known to me.
" f; THE SUBPOENA, SUMMONS & AFFIDAVIT CO.
P. 0. Box 398457
Miami Beach, FL 33139
(305) 757-5738
Our Job Serial Number: LDC-2021000775
Ref: ZAFRANI & EMERGUI 191287479 YK
Copyright © 1992-2021 Database Services, Inc, - Process Server's Toolbox V8.1¢
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/12/2021 11:05:37 AM.****IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR BROWARD.
COUNTY, FLORIDA
EVELYN ZAFRANI and ESTHER EMERGUI
Plaintiff
v
CASE NO: CACE20017273
PROGRESSIVE SELECT INSURANCE CIVIL DIVISION
COMPANY, a foreign corporation
/
SUBPOENA DUCES TECUM
(Pursuant to F.R.CP.1.351(c), effective 1/1/2011, this
Subpoena may be served by mail or by hand delivery by a commercial delivery service)
THE STATE OF FLORIDA:
TO: Record Custodian
Dr. Clinton Burkett
1150 N 35th Ave #300
Hollywood, FL. 33021
YOU ARE COMMANDED to appear at/mail/email records to Yasser Kader, Esq., Law Offices of Michael W.
Carroll, 3230 West Commercial Blvd., Suite 400, Fort Lauderdale, FL 33309; Email:
FeLauderdaleH C@Progressive.com at the date and time noted below and to have with you at that time, regarding
the below named individual, the following:
DATE: March 3, 2021
TIME: 10:00 a.m,
RE: EVELYN ZAFRANI SSN: 000- = DOs: Ga
YOUR ENTIRE FILE(S) WITH ALL CONTENTS FOR ANY AND ALL TREATMENT, including but not
limited to:
1 Complete copies of bills (paid and unpaid) with records of payments and/or charge offs, computer
printouts, ete.
2 Reports of X rays, MRIs, Scans, etc. as well as duplicate copies of X rays, CT scan films and MRI films,
(Please call this office first to advise of the duplication cost as well as the date of film and/or fax your invoice
for duplication setting forth the details of the particular film, i.e., date, type and what was filmed, including
your Tax ID No.). If any films have been checked out or released to any individuals and/or entities, please
provide the sign out sheet describing the film no longer in your possession, including the date the film was
released and to who it was released.
3. Any and all sign in sheets, telephone messages, prescriptions, computer printouts, hand written notes,
and insurance information.
4, Any and all records (this includes outside records from other providers or entities in your possession), log
in/sign in sheets, patient questionnaires, computerized records and records on microfilm/microfiche) pertaining to
Emergency Room treatment, in-patient treatment, out-patient treatment, including any and all medical and
chiropractic records, admission reports, consultation reports, initial evaluations, interim evaluations, final evaluations,
discharge summaries, clinical charts, clinical records, medical histories, chiropractic histories, patient questionnaire
forms, reports of physical examination, narrative reports, and reports, notes on attendance, charts, all correspondence,
letters, telephone messages, notes, claim forms, lien letters, letters of protection, diagnostic test results and studies, AND.
ANY AND ALL RECORDS WHATSOEVER YOU MAY HAVE regarding the above named individual.These items will be inspected and may be copied at that time, You will not be required to surrender the original items.
You may comply with this Subpoena by providing legible copies of the items to be produced to the attorney whose
name appears on this Subpoena on or before the scheduled date of production (if copies are expected to exceed $50.00,
please contact our office for authorization). You may condition the preparation of the copies upon the payment in
advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears
‘on this Subpoena, and thereby, eliminate your appearance at the time and place specified above. You have the right
to object to the production pursuant to this Subpoena at any time before production by giving written notice to the
attorney whose ame appears on this Subpoena.
THIS WIL.
NO TESTIMONY WILL BE TAKEN.
OT BE A DEPOS)
IF YOU FAIL TO: () 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 attorney whose name appears on this Subpoena, and
unless excused from this Subpoena by these attorneys or the Court, you shall respond to this Subpoena as directed.
DATED this 19th day of January, 2021
YASSER KADER, ESQUIRE
Attorneys for Defendant
Law Offices o@Mickgel W. Carroll 4 &
3230 West Commercial Blvd., Suite 400
Fort Lauderdale, FL 33309
(954) 233-9179 (Asst.)
Fax: (866) 841-8921
SERVICE DESIGNATIONS:
Primary: FtLauderdaleHC@Progressive.com
Secondary: YKader1@Progressive.com
Florida Bar No. 682691
“Salaried! limployees of Progressive Casnaity hnsurance Company”
RONNIE WALLACE/Claim No: 191287479
Preview
Filing # 122994020 E-Filed 03/12/2021 11:05:37 AM AFFIDAVIT OF SERVICE State of Florida County of Broward Case Number: CACE20017273 Court Date: 3/3/2021 Plaintiff: EVELYN ZAFRANI and ESTHER EMERGUI vs. Defendant: PROGRESSIVE SELECT INSURANCE COMAPNY, a foreign corporation For: YASSER KADER, ESQUIRE Law Office of Michael W. Carroll (FTL) Fla Bar No: 682691 3230 W. Commercial Blvd., Suite 400 Ft. Lauderdale, FL 33309 Received by THE SUBPOENA, SUMMONS & AFFIDAVIT CO. to be served on DR. CLINTON BURKETT RECORD CUSTODIAN, 1150 N. 35TH AVE., # 300, HOLLYWOOD, FL 33021. |, LUISA MIJARES, being duly sworn, depose and say that on the 22nd day of January, 2021 at 4:44 pm, |: AUTHORIZED: served a true copy of the SUBPOENA DUCES TECUM(Pursuant to F.R.C.P. 1.351(c), effective 1/1/2011, this Subpoena may be served by mail or by hand delivery by a commercial delivery service) and NOTICE OF PRODUCTION FROM NON PARTY with the date and hour of service endorsed thereon by me, to: EMPLOYEE - PHONE 954-228-6807, Additional Information pertaining to this Service: RE: EVELYN ZAFRANI 4/22/2021 4:44 pm 1150 N. 35TH AVE., # 300, HOLLYWOOD, FL 33021 - EMPLOYEE - PHONE 954-228-6807 THE AFFIANT, being duly sworn, states: | certify that | am over the age of 18, have no interest in the above action, and | am authorized by law, in good standing, to serve process in the judicial circuit in which the process was served. al LUISA MIJARES a Subscribed and Sworn to before me by the affiant who is Process Server 4 personally known to me. " f; THE SUBPOENA, SUMMONS & AFFIDAVIT CO. P. 0. Box 398457 Miami Beach, FL 33139 (305) 757-5738 Our Job Serial Number: LDC-2021000775 Ref: ZAFRANI & EMERGUI 191287479 YK Copyright © 1992-2021 Database Services, Inc, - Process Server's Toolbox V8.1¢ *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/12/2021 11:05:37 AM.****IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD. COUNTY, FLORIDA EVELYN ZAFRANI and ESTHER EMERGUI Plaintiff v CASE NO: CACE20017273 PROGRESSIVE SELECT INSURANCE CIVIL DIVISION COMPANY, a foreign corporation / SUBPOENA DUCES TECUM (Pursuant to F.R.CP.1.351(c), effective 1/1/2011, this Subpoena may be served by mail or by hand delivery by a commercial delivery service) THE STATE OF FLORIDA: TO: Record Custodian Dr. Clinton Burkett 1150 N 35th Ave #300 Hollywood, FL. 33021 YOU ARE COMMANDED to appear at/mail/email records to Yasser Kader, Esq., Law Offices of Michael W. Carroll, 3230 West Commercial Blvd., Suite 400, Fort Lauderdale, FL 33309; Email: FeLauderdaleH C@Progressive.com at the date and time noted below and to have with you at that time, regarding the below named individual, the following: DATE: March 3, 2021 TIME: 10:00 a.m, RE: EVELYN ZAFRANI SSN: 000- = DOs: Ga YOUR ENTIRE FILE(S) WITH ALL CONTENTS FOR ANY AND ALL TREATMENT, including but not limited to: 1 Complete copies of bills (paid and unpaid) with records of payments and/or charge offs, computer printouts, ete. 2 Reports of X rays, MRIs, Scans, etc. as well as duplicate copies of X rays, CT scan films and MRI films, (Please call this office first to advise of the duplication cost as well as the date of film and/or fax your invoice for duplication setting forth the details of the particular film, i.e., date, type and what was filmed, including your Tax ID No.). If any films have been checked out or released to any individuals and/or entities, please provide the sign out sheet describing the film no longer in your possession, including the date the film was released and to who it was released. 3. Any and all sign in sheets, telephone messages, prescriptions, computer printouts, hand written notes, and insurance information. 4, Any and all records (this includes outside records from other providers or entities in your possession), log in/sign in sheets, patient questionnaires, computerized records and records on microfilm/microfiche) pertaining to Emergency Room treatment, in-patient treatment, out-patient treatment, including any and all medical and chiropractic records, admission reports, consultation reports, initial evaluations, interim evaluations, final evaluations, discharge summaries, clinical charts, clinical records, medical histories, chiropractic histories, patient questionnaire forms, reports of physical examination, narrative reports, and reports, notes on attendance, charts, all correspondence, letters, telephone messages, notes, claim forms, lien letters, letters of protection, diagnostic test results and studies, AND. ANY AND ALL RECORDS WHATSOEVER YOU MAY HAVE regarding the above named individual.These items will be inspected and may be copied at that time, You will not be required to surrender the original items. You may comply with this Subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this Subpoena on or before the scheduled date of production (if copies are expected to exceed $50.00, please contact our office for authorization). You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears ‘on this Subpoena, and thereby, eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this Subpoena at any time before production by giving written notice to the attorney whose ame appears on this Subpoena. THIS WIL. NO TESTIMONY WILL BE TAKEN. OT BE A DEPOS) IF YOU FAIL TO: () 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 attorney whose name appears on this Subpoena, and unless excused from this Subpoena by these attorneys or the Court, you shall respond to this Subpoena as directed. DATED this 19th day of January, 2021 YASSER KADER, ESQUIRE Attorneys for Defendant Law Offices o@Mickgel W. Carroll 4 & 3230 West Commercial Blvd., Suite 400 Fort Lauderdale, FL 33309 (954) 233-9179 (Asst.) Fax: (866) 841-8921 SERVICE DESIGNATIONS: Primary: FtLauderdaleHC@Progressive.com Secondary: YKader1@Progressive.com Florida Bar No. 682691 “Salaried! limployees of Progressive Casnaity hnsurance Company” RONNIE WALLACE/Claim No: 191287479