Preview
Filing # 131858332 E-Filed 08/02/2021 03:18:46 PM
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
NOTICE OF PRODUCTION FROM NON-PARTIES
TO: Derek Lewis, Esquire
YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice by Electronic Filing and if
no objection is received from any party, pursuant to Rule 1.351 of the Florida Rules of Civil Procedure, the undersigned
will either directly issue or alternativelyapply to the Clerk of Court for issuance of Subpoenas directed to the following
listed entities:
All Pro Orthopedic & Sports Medicine,P.A. Medical Records Department
Med, Bills, Films
17779 SW 2nd Street, Pembroke Pines, FL 33029
Beaches MRI Medical Records Department
Med, Bills, Films
7186 North University Drive, Tamarac, FL 33321
Broward Health Medical Center Billing Dept
Billing
1600 South Andrews Avenue, Ft. Lauderdale, FL 33316
Broward Health Medical Center Medical Records Department
Medical Records
1600 South Andrews Avenue, Ft. Lauderdale, FL 33316
Broward Health Medical Center Radiology File Room
Radiology
1600 South Andrews Avenue, Ft. Lauderdale, FL 33316
Douglas ChiropracticMedical Records Department
Med, Bills, Films
8910 Miramar Parkway,#115, Miramar, FL 33025
North Broward RadiologistsBilling Department
Billing
1801 S Perimeter Road, Suite 180, Fort Lauderdale, FL 33309
North Broward RadiologistsRecordsDepartment
Medical & Films
1801 S Perimeter Road, Suite 180, Fort Lauderdale, FL 33309
Radiology Consultants of HollywoodRadiology File Room
Med, Bills, Films
210 South Federal Highway, Hollywood,FL 33020
Surgery Services of South FloridaMedicalRecords Department
Med, Bills, Films
18459 Pines Boulevard,#315, Pembroke Pines, FL 33029
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/02/2021 03:18:46 PM.****
YOU ARE FURTHER NOTIFIED that the records will be directed to and processedby Center City Legal
Reproductions, Inc., who is an agent for HINSHAW & CULBERTSON LLR Pursuantto Florida Rule of Civil Procedure
1.351, which incorporates by referenceRule 1.350(a),undersignedcounsel is authorized to utilize Center City Legal
Reproductions, Inc., as an entity "acting in the requestingparty's behalf" to receive and copy the requested documents.
Center City Legal Reproductions, Inc. routinely obtains protectedhealthinfonnation on behalf of HINSHAW &
CULBERTSONLLP. The Center City Legal Reproductions, Inc. HIPAA Compliance officer ensures all infonnation
obtained is transmitted, stored, and destroyed in accordancewith HIPAA rules.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 2nd day of August 2021, I electronicallyfiled the foregoing document
with the Clerk of Court using FloridaCourts eFiling Portal. I also certify that the foregoing document is being
served this day on all counsel of record or pro se parties identified as follows, eithervia transmissionsofNotices
of Electronic Filing generated by FloridaCourts eFiling Portal or in some other authorizedmanner for those
counsel or partieswho are not authorized to receive electronicnotices of Electronic Filing:
Derek Lewis, Esquire
The Injury Firm
1608 E. CommercialBoulevard
Fort Lauderdale,FL 33334
com
ss:// Anthony Torrente
ANTHONY TORRENTE, ESQUIRE
Florida Bar No.093644
HINSHAW & CULBERTSON LLP
Counsel for Defendant
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
Center City Legal Reproductions, Inc.
CCLR
1315 Walnut Street, Suite 601, Philadelphia, PA 19107
....
(215)732-1177 fax (215)732-5637
Online Services
www.cclrinc.com
MARILYN CONEY
CCLR File No: 21-14587JF
Case No: 2021-010690
VS.
MZ COMMUNICATIONS, INC.
COUNSEL RETURN PAGE
I have received the Notice of Records Reproduction Request dated / /2021 regarding
records in the custody of (see attached subpoena(s)) and respond as follow:
(Ordering records through CCLR is more cost effective than getting them from a provider or another servicecarrier - see rates below)
(1)
COPIES
yes / no
I would like a copy of the records in question sent to me, and agree to
pay the price noted in the Notice of Records Reproduction Request.
(2)
I would like copies of X-Rays on CD sent to me.
yes / no
(3)
OBJECTION
In accordanceto rules governing civil procedure a copy of date/timestamped
filing needs to be sent to Center City Legal Reproductionsprior to / /2021.
Failure to do so shall serve as an agreement that the records reproduction
serviceshould proceed with the records collection process.
2021 Copy Fees/PerLocation
AdministrativeFee:
$10.00 Attorney for plaintiff(s) / defendant(s)
Date
Pages 1-20:
$1.00 DEREK LEWIS, ESQUIRE
Pages 21-60:
$0.75 THE INJURY FIRM
Pages 61 & above:
$0.50 1608 E. COMMERCIAL BOULEVARD
X-Rays on CD (per CD):
$25.00
FORT LAUDERDALE, FL 33334
If Billing is NOT to Firm (but to an insurance company, etc.), enter the bill-to information below:
Bill-to Company:
Adjuster Name:
Claim Number::
Address:
CCLR ID #: 966144/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIAN OF RECORDS
ALL PRO ORTHOPEDIC & SPORTS MEDICINE,PA.
17779 SW 2ND STREET
PEMBROKE PINES, FL 33029
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA-
OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR
UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI
REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS
AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL
DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING
PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES,
BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT,
ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ]
REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS,
OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE
SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF
DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED
PRIOR TO COPIES BEING MADE.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired andno objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 093644
HINSHAW & CULBERTSON LLP
Counsel for DEFENDANT
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any
accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance.
Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL
GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are
hearing or voice impaired, call 1-800-955-8771.
CCLR ID #: 966150/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIANOF RECORDS
BEACHES MRI
7186 NORTH UNIVERSITY DRIVE
TAMARAC, FL 33321
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA-
OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR
UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI
REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS
AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL
DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING
PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES,
BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT,
ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ]
REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS,
OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE
SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF
DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED
PRIOR TO COPIES BEING MADE.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 093644
HINSHAW & CULBERTSON LLP
Counsel for DEFENDANT
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any
accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance.
Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL
GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are
hearing or voice impaired, call 1-800-955-8771.
CCLR ID #: 966149/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIANOF RECORDS
BROWARD HEALTH MEDICAL CENTER
1600 SOUTH ANDREWS AVENUE
FT. LAUDERDALE,FL 33316
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY AND ALL BILLINGRECORDS, LEDGERS, SERVICES RENDERED, CLAIM FORMS, BILLS (PAID OR
UNPAID), LEDGER CARDS, STATEMENTS OR CHARGES INCURRED, INVOICES OR RECEIPTS
PERTAINING TO THE EXAMINATION AND/OR TREATMENT OF MARILYN CONEY.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 093644
HINSHAW & CULBERTSON LLP
Counsel for DEFENDANT
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any
accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance.
Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL
GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are
hearing or voice impaired, call 1-800-955-8771.
CCLR ID #: 966146/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIANOF RECORDS
BROWARD HEALTH MEDICAL CENTER
1600 SOUTH ANDREWS AVENUE
FT. LAUDERDALE,FL 33316
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA-
OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, TESTS, REPORTS, MEMORANDA,
CORRESPONDENCE,CONSULTATIONS,OPERATIONS, INSURANCERECORDS AND/OR CLAIMS,
RECORDS AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT
LIMITED TO ANY AND ALL DOCUMENTSWHICH MAY BE CONTAINED IN PATIENT FILE FROM OTHER
CARE PROVIDERS,INCLUDING PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTEN
NOTES, TELEPHONE MESSAGES,BUT NOT LIMITED TO ANY AND ALL RECORDS, PERTAINING TO
PSYCHOLOGICAL TREATMENT, ALCOHOL/DRUGABUSE TREATMENT, AND ANY ADDITIONAL
RECORDS GENERATED THEREAFTER, IF REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,
DISEASES, INJURIES, ACCIDENTS, OPERATIONS AND CHECKUPS OF MARILYN CONEY.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 093644
HINSHAW & CULBERTSON LLP
Counsel for DEFENDANT
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any
accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance.
Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL
GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are
hearing or voice impaired, call 1-800-955-8771.
CCLR ID #: 966147/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIANOF RECORDS
BROWARD HEALTH MEDICAL CENTER
1600 SOUTH ANDREWS AVENUE
FT. LAUDERDALE,FL 33316
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY AND ALL FILMS ** PLEASE PROVIDE A LIST FIRST **, MRIS, CAT SCANS, X-RAYS, INCLUDING
RADIOLOGYREPORTS,ETC., PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE
SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF
DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED
PRIOR TO COPIES BEING MADE.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and thereby. eliminate your appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 093644
HINSHAW & CULBERTSON LLP
Counsel for DEFENDANT
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any
accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance.
Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL
GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are
hearing or voice impaired, call 1-800-955-8771.
CCLR ID #: 966165/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIANOF RECORDS
DOUGLAS CHIROPRACTIC
8910 MIRAMAR PARKWAY
#115
MIRAMAR, FL 33025
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA-
OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR
UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI
REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS
AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL
DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING
PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES,
BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT,
ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ]
REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS,
OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE
SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF
DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED
PRIOR TO COPIES BEING MADE.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 093644
HINSHAW & CULBERTSON LLP
Counsel for DEFENDANT
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any
accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance.
Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL
GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are
hearing or voice impaired, call 1-800-955-8771.
CCLR ID #: 966162/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIANOF RECORDS
NORTH BROWARD RADIOLOGISTS
1801 S PERIMETER ROAD
SUITE 180
FORT LAUDERDALE,FL 33309
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY AND ALL BILLINGRECORDS, LEDGERS, SERVICES RENDERED, CLAIM FORMS, BILLS (PAID OR
UNPAID), LEDGER CARDS, STATEMENTS OR CHARGES INCURRED, INVOICES OR RECEIPTS
PERTAINING TO THE EXAMINATION AND/OR TREATMENT OF MARILYN CONEY.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 093644
HINSHAW & CULBERTSON LLP
Counsel for DEFENDANT
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any
accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance.
Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL
GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are
hearing or voice impaired, call 1-800-955-8771.
CCLR ID #: 966161/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIANOF RECORDS
NORTH BROWARD RADIOLOGISTS
1801 S PERIMETER ROAD
SUITE 180
FORT LAUDERDALE,FL 33309
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA-
OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, TESTS, REPORTS, MEMORANDA,
CORRESPONDENCE,CONSULTATIONS,OPERATIONS, INSURANCERECORDS AND/OR CLAIMS,
RECORDS AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT
LIMITED TO ANY AND ALL DOCUMENTSWHICH MAY BE CONTAINED IN PATIENT FILE FROM OTHER
CARE PROVIDERS,INCLUDING PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTEN
NOTES, TELEPHONE MESSAGES,BUT NOT LIMITED TO ANY AND ALL RECORDS, PERTAINING TO
PSYCHOLOGICAL TREATMENT, ALCOHOL/DRUGABUSE TREATMENT, AND ANY ADDITIONAL
RECORDS GENERATED THEREAFTER, IF REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,
DISEASES, INJURIES, ACCIDENTS, OPERATIONS AND NY AND ALL FILMS, MRIS, CAT SCANS, X-RAYS
INCLUDING RADIOLOGYREPORTS,ETC., PERTAININGTO KIM RIST. **CERTIFICATION PAGE MUST B]
SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF
DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED
PRIOR TO COPIES BEING MADE.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 093644
HINSHAW & CULBERTSON LLP
Counsel for DEFENDANT
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any
accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance.
Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL
GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are
hearing or voice impaired, call 1-800-955-8771.
CCLR ID #: 966166/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIANOF RECORDS
RADIOLOGY CONSULTANTS OF HOLLYWOOD
210 SOUTH FEDERAL HIGHWAY
HOLLYWOOD,FL 33020
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA-
OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR
UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI
REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS
AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL
DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING
PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES,
BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT,
ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ]
REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS,
OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE
SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF
DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED
PRIOR TO COPIES BEING MADE.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 093644
HINSHAW & CULBERTSON LLP
Counsel for DEFENDANT
2525 PONCE DE LEON BLVD.
4TH FLOOR
CORAL GABLES, FL 33134
Telephone No.: (305)358-7747
Facsimile No.: (305)577-1063
com
In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any
accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance.
Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL
GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are
hearing or voice impaired, call 1-800-955-8771.
CCLR ID #: 966168/21-14587JF
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA.
CASE NO: 2021-010690
MARILYN CONEY
Plaintiff,
VS
MZ COMMUNICATIONS,INC.
Defendant.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: CUSTODIANOF RECORDS
SURGERY SERVICES OF SOUTH FLORIDA
18459 PINES BOULEVARD
#315
PEMBROKE PINES, FL 33029
YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum
Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street,
Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following:
ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA-
OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR
UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI
REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS
AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL
DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING
PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES,
BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT,
ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ]
REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS,
OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE
SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF
DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED
PRIOR TO COPIES BEING MADE.
These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems.
You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or
before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof
the copies upon the paymentin advance of the reasonable cost of preparation. 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
name appears on this Subpoena.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00
in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please
contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval
is not received prior to copies being made.
Ifyou fail to:
(1) appear as specified;or
(2) furnish the records instead of appearingas provided above; or
(3) object to this Subpoena
you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this
Subpoena by this attorney or the court, you shall respond to this Subpoena as directed.
HIPAA CERTIFICATE
This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand
Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been
issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith
attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the
issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto
raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl
to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed.
***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal
Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290
(Fax)
DATED:
ANTHONY TORRENTE, ESQUIRE
FBN: 09364
Preview
Filing # 131858332 E-Filed 08/02/2021 03:18:46 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i NOTICE OF PRODUCTION FROM NON-PARTIES TO: Derek Lewis, Esquire YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice by Electronic Filing and if no objection is received from any party, pursuant to Rule 1.351 of the Florida Rules of Civil Procedure, the undersigned will either directly issue or alternativelyapply to the Clerk of Court for issuance of Subpoenas directed to the following listed entities: All Pro Orthopedic & Sports Medicine,P.A. Medical Records Department Med, Bills, Films 17779 SW 2nd Street, Pembroke Pines, FL 33029 Beaches MRI Medical Records Department Med, Bills, Films 7186 North University Drive, Tamarac, FL 33321 Broward Health Medical Center Billing Dept Billing 1600 South Andrews Avenue, Ft. Lauderdale, FL 33316 Broward Health Medical Center Medical Records Department Medical Records 1600 South Andrews Avenue, Ft. Lauderdale, FL 33316 Broward Health Medical Center Radiology File Room Radiology 1600 South Andrews Avenue, Ft. Lauderdale, FL 33316 Douglas ChiropracticMedical Records Department Med, Bills, Films 8910 Miramar Parkway,#115, Miramar, FL 33025 North Broward RadiologistsBilling Department Billing 1801 S Perimeter Road, Suite 180, Fort Lauderdale, FL 33309 North Broward RadiologistsRecordsDepartment Medical & Films 1801 S Perimeter Road, Suite 180, Fort Lauderdale, FL 33309 Radiology Consultants of HollywoodRadiology File Room Med, Bills, Films 210 South Federal Highway, Hollywood,FL 33020 Surgery Services of South FloridaMedicalRecords Department Med, Bills, Films 18459 Pines Boulevard,#315, Pembroke Pines, FL 33029 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/02/2021 03:18:46 PM.**** YOU ARE FURTHER NOTIFIED that the records will be directed to and processedby Center City Legal Reproductions, Inc., who is an agent for HINSHAW & CULBERTSON LLR Pursuantto Florida Rule of Civil Procedure 1.351, which incorporates by referenceRule 1.350(a),undersignedcounsel is authorized to utilize Center City Legal Reproductions, Inc., as an entity "acting in the requestingparty's behalf" to receive and copy the requested documents. Center City Legal Reproductions, Inc. routinely obtains protectedhealthinfonnation on behalf of HINSHAW & CULBERTSONLLP. The Center City Legal Reproductions, Inc. HIPAA Compliance officer ensures all infonnation obtained is transmitted, stored, and destroyed in accordancewith HIPAA rules. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 2nd day of August 2021, I electronicallyfiled the foregoing document with the Clerk of Court using FloridaCourts eFiling Portal. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified as follows, eithervia transmissionsofNotices of Electronic Filing generated by FloridaCourts eFiling Portal or in some other authorizedmanner for those counsel or partieswho are not authorized to receive electronicnotices of Electronic Filing: Derek Lewis, Esquire The Injury Firm 1608 E. CommercialBoulevard Fort Lauderdale,FL 33334 com ss:// Anthony Torrente ANTHONY TORRENTE, ESQUIRE Florida Bar No.093644 HINSHAW & CULBERTSON LLP Counsel for Defendant 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 .... (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com MARILYN CONEY CCLR File No: 21-14587JF Case No: 2021-010690 VS. MZ COMMUNICATIONS, INC. COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated / /2021 regarding records in the custody of (see attached subpoena(s)) and respond as follow: (Ordering records through CCLR is more cost effective than getting them from a provider or another servicecarrier - see rates below) (1) COPIES yes / no I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) I would like copies of X-Rays on CD sent to me. yes / no (3) OBJECTION In accordanceto rules governing civil procedure a copy of date/timestamped filing needs to be sent to Center City Legal Reproductionsprior to / /2021. Failure to do so shall serve as an agreement that the records reproduction serviceshould proceed with the records collection process. 2021 Copy Fees/PerLocation AdministrativeFee: $10.00 Attorney for plaintiff(s) / defendant(s) Date Pages 1-20: $1.00 DEREK LEWIS, ESQUIRE Pages 21-60: $0.75 THE INJURY FIRM Pages 61 & above: $0.50 1608 E. COMMERCIAL BOULEVARD X-Rays on CD (per CD): $25.00 FORT LAUDERDALE, FL 33334 If Billing is NOT to Firm (but to an insurance company, etc.), enter the bill-to information below: Bill-to Company: Adjuster Name: Claim Number:: Address: CCLR ID #: 966144/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIAN OF RECORDS ALL PRO ORTHOPEDIC & SPORTS MEDICINE,PA. 17779 SW 2ND STREET PEMBROKE PINES, FL 33029 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA- OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES, BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT, ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ] REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS, OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED PRIOR TO COPIES BEING MADE. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired andno objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 093644 HINSHAW & CULBERTSON LLP Counsel for DEFENDANT 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance. Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are hearing or voice impaired, call 1-800-955-8771. CCLR ID #: 966150/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIANOF RECORDS BEACHES MRI 7186 NORTH UNIVERSITY DRIVE TAMARAC, FL 33321 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA- OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES, BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT, ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ] REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS, OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED PRIOR TO COPIES BEING MADE. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 093644 HINSHAW & CULBERTSON LLP Counsel for DEFENDANT 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance. Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are hearing or voice impaired, call 1-800-955-8771. CCLR ID #: 966149/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIANOF RECORDS BROWARD HEALTH MEDICAL CENTER 1600 SOUTH ANDREWS AVENUE FT. LAUDERDALE,FL 33316 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY AND ALL BILLINGRECORDS, LEDGERS, SERVICES RENDERED, CLAIM FORMS, BILLS (PAID OR UNPAID), LEDGER CARDS, STATEMENTS OR CHARGES INCURRED, INVOICES OR RECEIPTS PERTAINING TO THE EXAMINATION AND/OR TREATMENT OF MARILYN CONEY. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 093644 HINSHAW & CULBERTSON LLP Counsel for DEFENDANT 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance. Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are hearing or voice impaired, call 1-800-955-8771. CCLR ID #: 966146/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIANOF RECORDS BROWARD HEALTH MEDICAL CENTER 1600 SOUTH ANDREWS AVENUE FT. LAUDERDALE,FL 33316 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA- OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, TESTS, REPORTS, MEMORANDA, CORRESPONDENCE,CONSULTATIONS,OPERATIONS, INSURANCERECORDS AND/OR CLAIMS, RECORDS AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL DOCUMENTSWHICH MAY BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTEN NOTES, TELEPHONE MESSAGES,BUT NOT LIMITED TO ANY AND ALL RECORDS, PERTAINING TO PSYCHOLOGICAL TREATMENT, ALCOHOL/DRUGABUSE TREATMENT, AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, IF REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES, DISEASES, INJURIES, ACCIDENTS, OPERATIONS AND CHECKUPS OF MARILYN CONEY. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 093644 HINSHAW & CULBERTSON LLP Counsel for DEFENDANT 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance. Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are hearing or voice impaired, call 1-800-955-8771. CCLR ID #: 966147/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIANOF RECORDS BROWARD HEALTH MEDICAL CENTER 1600 SOUTH ANDREWS AVENUE FT. LAUDERDALE,FL 33316 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY AND ALL FILMS ** PLEASE PROVIDE A LIST FIRST **, MRIS, CAT SCANS, X-RAYS, INCLUDING RADIOLOGYREPORTS,ETC., PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED PRIOR TO COPIES BEING MADE. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and thereby. eliminate your appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 093644 HINSHAW & CULBERTSON LLP Counsel for DEFENDANT 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance. Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are hearing or voice impaired, call 1-800-955-8771. CCLR ID #: 966165/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIANOF RECORDS DOUGLAS CHIROPRACTIC 8910 MIRAMAR PARKWAY #115 MIRAMAR, FL 33025 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA- OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES, BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT, ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ] REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS, OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED PRIOR TO COPIES BEING MADE. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 093644 HINSHAW & CULBERTSON LLP Counsel for DEFENDANT 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance. Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are hearing or voice impaired, call 1-800-955-8771. CCLR ID #: 966162/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIANOF RECORDS NORTH BROWARD RADIOLOGISTS 1801 S PERIMETER ROAD SUITE 180 FORT LAUDERDALE,FL 33309 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY AND ALL BILLINGRECORDS, LEDGERS, SERVICES RENDERED, CLAIM FORMS, BILLS (PAID OR UNPAID), LEDGER CARDS, STATEMENTS OR CHARGES INCURRED, INVOICES OR RECEIPTS PERTAINING TO THE EXAMINATION AND/OR TREATMENT OF MARILYN CONEY. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 093644 HINSHAW & CULBERTSON LLP Counsel for DEFENDANT 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance. Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are hearing or voice impaired, call 1-800-955-8771. CCLR ID #: 966161/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIANOF RECORDS NORTH BROWARD RADIOLOGISTS 1801 S PERIMETER ROAD SUITE 180 FORT LAUDERDALE,FL 33309 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA- OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, TESTS, REPORTS, MEMORANDA, CORRESPONDENCE,CONSULTATIONS,OPERATIONS, INSURANCERECORDS AND/OR CLAIMS, RECORDS AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL DOCUMENTSWHICH MAY BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTEN NOTES, TELEPHONE MESSAGES,BUT NOT LIMITED TO ANY AND ALL RECORDS, PERTAINING TO PSYCHOLOGICAL TREATMENT, ALCOHOL/DRUGABUSE TREATMENT, AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, IF REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES, DISEASES, INJURIES, ACCIDENTS, OPERATIONS AND NY AND ALL FILMS, MRIS, CAT SCANS, X-RAYS INCLUDING RADIOLOGYREPORTS,ETC., PERTAININGTO KIM RIST. **CERTIFICATION PAGE MUST B] SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED PRIOR TO COPIES BEING MADE. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 093644 HINSHAW & CULBERTSON LLP Counsel for DEFENDANT 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance. Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are hearing or voice impaired, call 1-800-955-8771. CCLR ID #: 966166/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIANOF RECORDS RADIOLOGY CONSULTANTS OF HOLLYWOOD 210 SOUTH FEDERAL HIGHWAY HOLLYWOOD,FL 33020 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA- OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES, BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT, ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ] REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS, OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED PRIOR TO COPIES BEING MADE. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 093644 HINSHAW & CULBERTSON LLP Counsel for DEFENDANT 2525 PONCE DE LEON BLVD. 4TH FLOOR CORAL GABLES, FL 33134 Telephone No.: (305)358-7747 Facsimile No.: (305)577-1063 com In accordancewith the Americans With DisabilitiesAct, ifyou are a personwith a disabilitywho needs any accommodation in order to participate in thisproceeding, you are entitled, to the provision ofcertain assistance. Please contact ANTHONYTORRENTE, ESQUIRE, at 2525 PONCE DE LEONBLVD., 4TH FLOOR, CORAL GABLES, FL 33134. Telephone (305)358-7747 within two (2) working days ofyourreceipt ofthis Subpoena. Ifyou are hearing or voice impaired, call 1-800-955-8771. CCLR ID #: 966168/21-14587JF IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: 2021-010690 MARILYN CONEY Plaintiff, VS MZ COMMUNICATIONS,INC. Defendant. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: CUSTODIANOF RECORDS SURGERY SERVICES OF SOUTH FLORIDA 18459 PINES BOULEVARD #315 PEMBROKE PINES, FL 33029 YOU ARE COMMANDEDto furnish no later than fifteen (15) days within receipt of this subpoena Duces Tecum Without Deposition,to Hinshaw & Culbertson LLP, c/o Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, Phone (215)732-1177the following: ANY & ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO, COLOR PHOTOGRAPHS, INTRA- OPERATIVE PHOTOGRAPHS, EMERGENCYROOM RECORDS, X-RAYS, BILLING RECORDS (PAID OR UNPAID), TESTS, REPORTS, MEMORANDA,CORRESPONDENCE,CONSULTATIONS,MRI'S, MRI REPORTS, CT SCANS, INSURANCERECORDS AND/OR CLAIMS, WORKER'S COMPENSATION RECORDS AND/OR CLAIMS, PATHOLOGY REPORTS, INCLUDING BUT NOT LIMITED TO ANY AND ALL DOCUMENTS WHICH BE CONTAINED IN PATIENT FILE FROM OTHER CARE PROVIDERS,INCLUDING PATIENT INFORMATION SHEET, DOCTOR'S NOTES, HANDWRITTENNOTES, TELEPHONE MESSAGES, BUT NOT LIMITED TO ANY AND ALL RECORDS,PERTAINING TO PSYCHOLOGICALTREATMENT, ALCOHOL/DRUGABUSE TREATMENT,AND ANY ADDITIONAL RECORDS GENERATED THEREAFTER, ] REQUESTED,FOR ANY AND ALL ILLNESSES, SICKNESSES,DISEASES, INJURIES, ACCIDENTS, OPERATIONS AND CHECKUPS PERTAINING TO MARILYN CONEY. **CERTIFICATION PAGE MUST BE SIGNED AND DATED. A COMPLETE BREAKDOWN IS REQUIREDPRIOR TO APPROVAL OF DUPLICATION.REIMBURSEMENTFOR FILMS WILL NOT BE MADE IF APPROVAL IS NOT RECEIVED PRIOR TO COPIES BEING MADE. These items will be inspectedand may be copied at that time. You will not be required to surrenderthe originalitems. You may comply with this Subpoena by providing legible copies of the items to be producedto CenterCity Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107, on behalf of the requestingattorneyon or before the scheduleddate of production and, thereby, eliminateyour appearance. You may condition the preparationof the copies upon the paymentin advance of the reasonable cost of preparation. 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 name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKENIf any fee exceeds $100.00 in accordancewith Florida Statute 395.3025 notify our office for approval before duplicating the records. Please contact our office for approval before duplicating any films. Reimbursementfor films will NOT be made if approval is not received prior to copies being made. Ifyou fail to: (1) appear as specified;or (2) furnish the records instead of appearingas provided above; or (3) object to this Subpoena you may be in contempt of court. You are subpoenaedby the following attorney and unless excused from this Subpoena by this attorney or the court, you shall respond to this Subpoena as directed. HIPAA CERTIFICATE This certifies that this subpoenahas been issued in compliance with the Health Insurance Portabilityand Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(I)(ii) as this subpoenahas been issued pursuant to Rules 1.410 and 1.351., Fla. R. Civ. P. The Party issuing this subpoenahas made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sendinghis/her attorney,a notice of the issuance of this subpoenawhich included sufficient infonnation about the litigationto permit the Plaintiff/Patientto raise an objectionto the court or administrative tribunal. The time for the Plaintiff/Patientto raise an objectionpursuanl to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. ***** PLEASE SEND INVOICES, RECORDS,AND CORRESPONDENCETO Center City Legal Reproductions, Inc., 1315 Walnut Street, Suite 601, Philadelphia, PA 19107;j fennal@cclrinc.com, (215)825-7290 (Fax) DATED: ANTHONY TORRENTE, ESQUIRE FBN: 09364