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Filing # 114006894 E-Filed 09/25/2020 04:25:42 PM
IN THE CIRCUIT COURT 5™
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
JESUS SANTIAGO, CASE NO.: 2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
NOTICE OF PRODUCTION FROM NON-PARTY
TO: Michael J. Smith, Esq.
Morgan & Morgan, P.A.
14229 US Hwy 441
Tavares, FL 32778
YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice, the
undersigned will apply to the Clerk of this Court for issuance of the attached Subpoena directed
to:
Medical & Billing Records Custodian
Doctors Medical Center
S. Cifuentes, ARNP
26085 S. Dixie Hwy
Homestead, FL 33032
Medical & Billing Records Custodian
Borinquen Health Center
Ivan A. Arostegui, MD
3602 Federal Hwy
Homestead, FL 33137
Medical & Billing Records Custodian
Derek G. Bazemore, Jr., MD
401 NW 42™ Avenue
Electronically Filed Marion Case # 19CA002229AX 09/25/2020 04:25:42 PMPlantation, FL 33317
Medical & Billing Records Custodian
Center for Digestive medicine
German Gonzalez, Jr., MD
7887 N. Kendall Drive, Suite 101
Miami, FL 33156
who are not parties, to produce the items listed at the time and place specified in the Subpoena.
CERTIFICATE OF SERVICE
HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by
electronic mail via the Court’s E-Portal to all known designated addresses for Michael J. Smith,
Esq.. MORGAN & MORGAN, P.A., Aftorneys for Plaintiff, MSmith@forthepeople.com,
ECannon@forthepeople.com this 25th _ day of SEPTEMBER, 2020.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, IIT
VIRGIL W. WRIGHT, III, ESQ.
Florida Bar No. 993141
CHRISTOPHER C. COLEMAN, ESQ.
Florida Bar No. 0716359
1820 SE 18th Avenue
Ocala, Florida 34471
Phone (352) 351-1119 (al/eg)
Fax (352) 351-0151
Designated Electronic Mail:
Servicevww@cameronhodges3.com
Attorney for DefendantIN THE CIRCUIT COURT S™
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
JESUS SANTIAGO, CASE NO.: — 2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: Medical & Billing Records Custodian
Doctors Medical Center
Siurky Cifuentes, ARNP
26085 S. Dixie Hwy
Homestead, FL 33032
YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON,
HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
Florida 34471 on OCTOBER 390, 2020, at 10:00 A.M. the following:
The records to be produced include as FOLLOWS:
Inside and outside covers of the chart jacket
Doctor's records/reports/notes
Nurse's records/reports/notes
Administrative reports/notes/memos
All billing statements
All letters
Laboratory records/reports
Radiology records/reports
Any and all radiology and diagnostic studies including but not limited to MRIs,
CT scans and X-rays, preferably on disk
10. Diagnostic reports EMG/MRI/EEG
11. Therapy records/reports/notes
12. Medical evaluation reports
13. Referral forms
CRNAMARYWNS14. Insurance documents/forms/ including copies of insurance cards
15. Patient history forms/ including copies of photo identification
16. Pharmacy records/logs
17. Consultation reports
18. Hospital or outpatient records/billings
19. | Ambulance/EMS reports
20. Any other written information pertaining to:
Patient : Jesus Manuel Santiago-Martinez
Date of Birth : as
Social Security No. : eae
All records requested should be all inclusive and should in no way be limited to one
incident.
Pursuant to 45 C.F.R. 164.512, "A covered entity may use or disclose
protected health information without the written consent or authorization of
the individual..."to the extent that such use or disclosure is "required by law"
and the use or disclosure complied with and is limited to the relevant
requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
law" includes, but is not limited to, court orders and court-ordered warrants;
subpoenas or summons...a civil or an authorized investigative demand."
(emphasis added)
IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
TO THE PARTY TO WHOM THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS
SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
IF YOU HAVE A QUESTION, PLEASE CALL _APRIL_ @ (352) 351-1119.
THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
TESTIMONY SHALL BE TAKEN.
These items will be inspected and may be copied at that time. You will not be required
to surrender the original items. You may comply with this subpoena by providing legible
copies of the items to be produced to the attorney whose name appears on this subpoena on or
before the scheduled date of production. You may condition the preparation of the copies upon
the payment in advance of the reasonable cost of preparation. You may mail or deliver the
copies to the attorney whose name appears on this subpoena. 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.
If you fail to furnish the records or object to this subpoena, you may be in contempt ofcourt. You are subpoenaed by the attorneys whose name appears on this subpoena and unless
excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
as directed.
DATED this 6TH _ day of OCTOBER, 2020.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, IIT
VIRGIL W. WRIGHT, Ill, ESQ.
Florida Bar No. 993141
CHRISTOPHER C. COLEMAN, ESQ.
Florida Bar No. 0716359
1820 SE 18th Avenue
Ocala, Florida 34471
Phone (352) 351-1119 (al/eg)
Fax (352) 351-0151
Attorneys for Defendant
HIPAA Discovery Demand
SATISFACTORY ASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
request for patient information contained in the above referenced legal process to the individual whose
information is sought. I have made:
@ a good faith attempt to provide written notice to the individual at the individual's last
known address and/or through the individual's legal counsel, and
Q the notice included sufficient information about the above referenced legal proceeding
so that the individual could raise an objection to the Court or administrative tribunal,
and
(3) the time for the individual to raise objections with the Court or administrative tribunal
has elapsed and either no objections were filed or all abjections were resolved by the
Court in favor of disclosure.IN THE CIRCUIT COURT S™
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
JESUS SANTIAGO, CASE NO.: — 2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: Medical & Billing Records Custodian
Borinquen Health Center
Ivan A. Arostegui, MD
3601 Federal Hwy
Homestead, FL 33137
YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON,
HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
Florida 34471 on OCTOBER 390, 2020, at 10:00 A.M. the following:
The records to be produced include as FOLLOWS:
Inside and outside covers of the chart jacket
Doctor's records/reports/notes
Nurse's records/reports/notes
Administrative reports/notes/memos
All billing statements
All letters
Laboratory records/reports
Radiology records/reports
Any and all radiology and diagnostic studies including but not limited to MRIs,
CT scans and X-rays, preferably on disk
10. Diagnostic reports EMG/MRI/EEG
11. Therapy records/reports/notes
12. Medical evaluation reports
13. Referral forms
CRNAMARYWNS14. Insurance documents/forms/ including copies of insurance cards
15. Patient history forms/ including copies of photo identification
16. Pharmacy records/logs
17. Consultation reports
18. Hospital or outpatient records/billings
19. | Ambulance/EMS reports
20. Any other written information pertaining to:
Patient : Jesus Manuel Santiago-Martinez
Date of Birth : as
Social Security No. : eae
All records requested should be all inclusive and should in no way be limited to one
incident.
Pursuant to 45 C.F.R. 164.512, "A covered entity may use or disclose
protected health information without the written consent or authorization of
the individual..."to the extent that such use or disclosure is "required by law"
and the use or disclosure complied with and is limited to the relevant
requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
law" includes, but is not limited to, court orders and court-ordered warrants;
subpoenas or summons...a civil or an authorized investigative demand."
(emphasis added)
IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
TO THE PARTY TO WHOM THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS
SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
IF YOU HAVE A QUESTION, PLEASE CALL _APRIL_ @ (352) 351-1119.
THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
TESTIMONY SHALL BE TAKEN.
These items will be inspected and may be copied at that time. You will not be required
to surrender the original items. You may comply with this subpoena by providing legible
copies of the items to be produced to the attorney whose name appears on this subpoena on or
before the scheduled date of production. You may condition the preparation of the copies upon
the payment in advance of the reasonable cost of preparation. You may mail or deliver the
copies to the attorney whose name appears on this subpoena. 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.
If you fail to furnish the records or object to this subpoena, you may be in contempt ofcourt. You are subpoenaed by the attorneys whose name appears on this subpoena and unless
excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
as directed.
DATED this 6th _ day of OCTOBER, 2020.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, IIT
VIRGIL W. WRIGHT, Ill, ESQ.
Florida Bar No. 993141
CHRISTOPHER C. COLEMAN, ESQ.
Florida Bar No. 0716359
1820 SE 18th Avenue
Ocala, Florida 34471
Phone (352) 351-1119 (al/eg)
Fax (352) 351-0151
Attorneys for Defendant
HIPAA Discovery Demand
SATISFACTORY ASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
request for patient information contained in the above referenced legal process to the individual whose
information is sought. I have made:
@ a good faith attempt to provide written notice to the individual at the individual's last
known address and/or through the individual's legal counsel, and
Q the notice included sufficient information about the above referenced legal proceeding
so that the individual could raise an objection to the Court or administrative tribunal,
and
(3) the time for the individual to raise objections with the Court or administrative tribunal
has elapsed and either no objections were filed or all abjections were resolved by the
Court in favor of disclosure.IN THE CIRCUIT COURT 5™
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
JESUS SANTIAGO, CASE NO.: 2019-CA-2229
vs.
Plaintiff,
MICHAEL OWENS HERLONG,
Defendant.
TO:
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
Medical & Billing Records Custodian
Derek G. Bazemore, Jr., MD
401 NW 42" Avenue
Plantation, FL 3317
YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON,
HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
Florida 34471 on OCTOBER 30, 2020, at 10:00 A.M. the following:
The records to be produced include as FOLLOWS:
Inside and outside covers of the chart jacket
Doctor's records/reports/notes
Nurse's records/reports/notes
Administrative reports/notes/memos
All billing statements
All letters
Laboratory records/reports
Radiology records/reports
Any and all radiology and diagnostic studies including but not limited to MRIs,
CT scans and X-rays, preferably on disk
10. Diagnostic reports EMG/MRI/EEG
11. Therapy records/reports/notes
12. Medical evaluation reports
13. Referral forms
14. Insurance documents/forms/ including copies of insurance cards
SC RPNAMEYNS15. Patient history forms/ including copies of photo identification
16. Pharmacy records/logs
17. Consultation reports
18. Hospital or outpatient records/billings
19. | Ambulance/EMS reports
20. Any other written information pertaining to:
Patient : Jesus Manuel Santiago-Martinez
Date of Birth : as
Social Security No. : ey
All records requested should be all inclusive and should in no way be limited to one
incident.
Pursuant to 45 C.F.R. 164,512, "A covered entity may use or disclose
protected health information without the written consent or authorization of
the individual..."to the extent that such use or disclosure is "required by law"
and the use or disclosure complied with and is limited to the relevant
requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
law" includes, but is not limited to, court orders and court-ordered warrants;
subpoenas or summons...a civil or an authorized investigative demand."
(emphasis added)
IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
TO THE PARTY TO WHOM THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS
SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
IF YOU HAVE A QUESTION, PLEASE CALL _APRIL_ @ (352) 351-1119.
THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
TESTIMONY SHALL BE TAKEN.
These items will be inspected and may be copied at that time. You will not be required
to surrender the original items. You may comply with this subpoena by providing legible
copies of the items to be produced to the attorney whose name appears on this subpoena on or
before the scheduled date of production. You may condition the preparation of the copies upon
the payment in advance of the reasonable cost of preparation. You may mail or deliver the
copies to the attorney whose name appears on this subpoena. 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.
Tf you fail to furnish the records or object to this subpoena, you may be in contempt of
court. You are subpoenaed by the attorneys whose name appears on this subpoena and unlessexcused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
as directed.
DATED this 6th __ day of OCTOBER, 2020.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, III
VIRGIL W. WRIGHT, Il, ESQ.
Florida Bar No. 993141
CHRISTOPHER C. COLEMAN, ESQ.
Florida Bar No. 0716359
1820 SE 18th Avenue
Ocala, Florida 34471
Phone (352) 351-1119 (al/eg)
Fax (352) 351-0151
Attorneys for Defendant
HIPAA Discovery Demand
SATISFACTORY ASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
request for patient information contained in the above referenced legal process to the individual whose
information is sought. I have made:
@ 4 good faith attempt to provide written notice to the individual at the individual's last
known address and/or through the individual's legal counsel, and
(2) the notice included sufficient information about the above referenced legal proceeding
so that the individual could raise an objection to the Court or administrative tribunal,
and
the time for the individual to raise objections with the Court or administrative tribunal
has elapsed and either no objections were filed or all abjections were resolved by the
Court in favor of disclosure.IN THE CIRCUIT COURT S™
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
JESUS SANTIAGO, CASE NO.: — 2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: Medical & Billing Records Custodian
Center for Digestive Medicine
German Gonzalez, Jr., MD
7887 North Kendall Drive, Suite 101
Miami, FL 33156
YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON,
HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
Florida 34471 on OCTOBER 390, 2020, at 10:00 A.M. the following:
The records to be produced include as FOLLOWS:
Inside and outside covers of the chart jacket
Doctor's records/reports/notes
Nurse's records/reports/notes
Administrative reports/notes/memos
All billing statements
All letters
Laboratory records/reports
Radiology records/reports
Any and all radiology and diagnostic studies including but not limited to MRIs,
CT scans and X-rays, preferably on disk
10. Diagnostic reports EMG/MRI/EEG
11. Therapy records/reports/notes
12. Medical evaluation reports
13. Referral forms
CRNAMARYWNS14. Insurance documents/forms/ including copies of insurance cards
15. Patient history forms/ including copies of photo identification
16. Pharmacy records/logs
17. Consultation reports
18. Hospital or outpatient records/billings
19. | Ambulance/EMS reports
20. Any other written information pertaining to:
Patient : Jesus Manuel Santiago-Martinez
Date of Birth : as
Social Security No. : eae
All records requested should be all inclusive and should in no way be limited to one
incident.
Pursuant to 45 C.F.R. 164.512, "A covered entity may use or disclose
protected health information without the written consent or authorization of
the individual..."to the extent that such use or disclosure is "required by law"
and the use or disclosure complied with and is limited to the relevant
requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
law" includes, but is not limited to, court orders and court-ordered warrants;
subpoenas or summons...a civil or an authorized investigative demand."
(emphasis added)
IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
TO THE PARTY TO WHOM THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS
SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
IF YOU HAVE A QUESTION, PLEASE CALL _APRIL_ @ (352) 351-1119.
THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
TESTIMONY SHALL BE TAKEN.
These items will be inspected and may be copied at that time. You will not be required
to surrender the original items. You may comply with this subpoena by providing legible
copies of the items to be produced to the attorney whose name appears on this subpoena on or
before the scheduled date of production. You may condition the preparation of the copies upon
the payment in advance of the reasonable cost of preparation. You may mail or deliver the
copies to the attorney whose name appears on this subpoena. 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.
If you fail to furnish the records or object to this subpoena, you may be in contempt ofcourt. You are subpoenaed by the attorneys whose name appears on this subpoena and unless
excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
as directed.
DATED this 6th _ day of OCTOBER, 2020.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, IIT
VIRGIL W. WRIGHT, Ill, ESQ.
Florida Bar No. 993141
CHRISTOPHER C. COLEMAN, ESQ.
Florida Bar No. 0716359
1820 SE 18th Avenue
Ocala, Florida 34471
Phone (352) 351-1119 (al/eg)
Fax (352) 351-0151
Attorneys for Defendant
HIPAA Discovery Demand
SATISFACTORY ASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
request for patient information contained in the above referenced legal process to the individual whose
information is sought. I have made:
@ a good faith attempt to provide written notice to the individual at the individual's last
known address and/or through the individual's legal counsel, and
Q the notice included sufficient information about the above referenced legal proceeding
so that the individual could raise an objection to the Court or administrative tribunal,
and
(3) the time for the individual to raise objections with the Court or administrative tribunal
has elapsed and either no objections were filed or all abjections were resolved by the
Court in favor of disclosure.
Preview
Filing # 114006894 E-Filed 09/25/2020 04:25:42 PM IN THE CIRCUIT COURT 5™ JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA JESUS SANTIAGO, CASE NO.: 2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. NOTICE OF PRODUCTION FROM NON-PARTY TO: Michael J. Smith, Esq. Morgan & Morgan, P.A. 14229 US Hwy 441 Tavares, FL 32778 YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice, the undersigned will apply to the Clerk of this Court for issuance of the attached Subpoena directed to: Medical & Billing Records Custodian Doctors Medical Center S. Cifuentes, ARNP 26085 S. Dixie Hwy Homestead, FL 33032 Medical & Billing Records Custodian Borinquen Health Center Ivan A. Arostegui, MD 3602 Federal Hwy Homestead, FL 33137 Medical & Billing Records Custodian Derek G. Bazemore, Jr., MD 401 NW 42™ Avenue Electronically Filed Marion Case # 19CA002229AX 09/25/2020 04:25:42 PMPlantation, FL 33317 Medical & Billing Records Custodian Center for Digestive medicine German Gonzalez, Jr., MD 7887 N. Kendall Drive, Suite 101 Miami, FL 33156 who are not parties, to produce the items listed at the time and place specified in the Subpoena. CERTIFICATE OF SERVICE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by electronic mail via the Court’s E-Portal to all known designated addresses for Michael J. Smith, Esq.. MORGAN & MORGAN, P.A., Aftorneys for Plaintiff, MSmith@forthepeople.com, ECannon@forthepeople.com this 25th _ day of SEPTEMBER, 2020. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, IIT VIRGIL W. WRIGHT, III, ESQ. Florida Bar No. 993141 CHRISTOPHER C. COLEMAN, ESQ. Florida Bar No. 0716359 1820 SE 18th Avenue Ocala, Florida 34471 Phone (352) 351-1119 (al/eg) Fax (352) 351-0151 Designated Electronic Mail: Servicevww@cameronhodges3.com Attorney for DefendantIN THE CIRCUIT COURT S™ JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA JESUS SANTIAGO, CASE NO.: — 2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: Medical & Billing Records Custodian Doctors Medical Center Siurky Cifuentes, ARNP 26085 S. Dixie Hwy Homestead, FL 33032 YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON, HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala, Florida 34471 on OCTOBER 390, 2020, at 10:00 A.M. the following: The records to be produced include as FOLLOWS: Inside and outside covers of the chart jacket Doctor's records/reports/notes Nurse's records/reports/notes Administrative reports/notes/memos All billing statements All letters Laboratory records/reports Radiology records/reports Any and all radiology and diagnostic studies including but not limited to MRIs, CT scans and X-rays, preferably on disk 10. Diagnostic reports EMG/MRI/EEG 11. Therapy records/reports/notes 12. Medical evaluation reports 13. Referral forms CRNAMARYWNS14. Insurance documents/forms/ including copies of insurance cards 15. Patient history forms/ including copies of photo identification 16. Pharmacy records/logs 17. Consultation reports 18. Hospital or outpatient records/billings 19. | Ambulance/EMS reports 20. Any other written information pertaining to: Patient : Jesus Manuel Santiago-Martinez Date of Birth : as Social Security No. : eae All records requested should be all inclusive and should in no way be limited to one incident. Pursuant to 45 C.F.R. 164.512, "A covered entity may use or disclose protected health information without the written consent or authorization of the individual..."to the extent that such use or disclosure is "required by law" and the use or disclosure complied with and is limited to the relevant requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by law" includes, but is not limited to, court orders and court-ordered warrants; subpoenas or summons...a civil or an authorized investigative demand." (emphasis added) IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR TO THE PARTY TO WHOM THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT), PERTAINING TO THE ABOVE-NAMED INDIVIDUAL. IF YOU HAVE A QUESTION, PLEASE CALL _APRIL_ @ (352) 351-1119. THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL TESTIMONY SHALL BE TAKEN. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena. 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. If you fail to furnish the records or object to this subpoena, you may be in contempt ofcourt. You are subpoenaed by the attorneys whose name appears on this subpoena and unless excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed. DATED this 6TH _ day of OCTOBER, 2020. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, IIT VIRGIL W. WRIGHT, Ill, ESQ. Florida Bar No. 993141 CHRISTOPHER C. COLEMAN, ESQ. Florida Bar No. 0716359 1820 SE 18th Avenue Ocala, Florida 34471 Phone (352) 351-1119 (al/eg) Fax (352) 351-0151 Attorneys for Defendant HIPAA Discovery Demand SATISFACTORY ASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the request for patient information contained in the above referenced legal process to the individual whose information is sought. I have made: @ a good faith attempt to provide written notice to the individual at the individual's last known address and/or through the individual's legal counsel, and Q the notice included sufficient information about the above referenced legal proceeding so that the individual could raise an objection to the Court or administrative tribunal, and (3) the time for the individual to raise objections with the Court or administrative tribunal has elapsed and either no objections were filed or all abjections were resolved by the Court in favor of disclosure.IN THE CIRCUIT COURT S™ JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA JESUS SANTIAGO, CASE NO.: — 2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: Medical & Billing Records Custodian Borinquen Health Center Ivan A. Arostegui, MD 3601 Federal Hwy Homestead, FL 33137 YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON, HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala, Florida 34471 on OCTOBER 390, 2020, at 10:00 A.M. the following: The records to be produced include as FOLLOWS: Inside and outside covers of the chart jacket Doctor's records/reports/notes Nurse's records/reports/notes Administrative reports/notes/memos All billing statements All letters Laboratory records/reports Radiology records/reports Any and all radiology and diagnostic studies including but not limited to MRIs, CT scans and X-rays, preferably on disk 10. Diagnostic reports EMG/MRI/EEG 11. Therapy records/reports/notes 12. Medical evaluation reports 13. Referral forms CRNAMARYWNS14. Insurance documents/forms/ including copies of insurance cards 15. Patient history forms/ including copies of photo identification 16. Pharmacy records/logs 17. Consultation reports 18. Hospital or outpatient records/billings 19. | Ambulance/EMS reports 20. Any other written information pertaining to: Patient : Jesus Manuel Santiago-Martinez Date of Birth : as Social Security No. : eae All records requested should be all inclusive and should in no way be limited to one incident. Pursuant to 45 C.F.R. 164.512, "A covered entity may use or disclose protected health information without the written consent or authorization of the individual..."to the extent that such use or disclosure is "required by law" and the use or disclosure complied with and is limited to the relevant requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by law" includes, but is not limited to, court orders and court-ordered warrants; subpoenas or summons...a civil or an authorized investigative demand." (emphasis added) IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR TO THE PARTY TO WHOM THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT), PERTAINING TO THE ABOVE-NAMED INDIVIDUAL. IF YOU HAVE A QUESTION, PLEASE CALL _APRIL_ @ (352) 351-1119. THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL TESTIMONY SHALL BE TAKEN. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena. 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. If you fail to furnish the records or object to this subpoena, you may be in contempt ofcourt. You are subpoenaed by the attorneys whose name appears on this subpoena and unless excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed. DATED this 6th _ day of OCTOBER, 2020. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, IIT VIRGIL W. WRIGHT, Ill, ESQ. Florida Bar No. 993141 CHRISTOPHER C. COLEMAN, ESQ. Florida Bar No. 0716359 1820 SE 18th Avenue Ocala, Florida 34471 Phone (352) 351-1119 (al/eg) Fax (352) 351-0151 Attorneys for Defendant HIPAA Discovery Demand SATISFACTORY ASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the request for patient information contained in the above referenced legal process to the individual whose information is sought. I have made: @ a good faith attempt to provide written notice to the individual at the individual's last known address and/or through the individual's legal counsel, and Q the notice included sufficient information about the above referenced legal proceeding so that the individual could raise an objection to the Court or administrative tribunal, and (3) the time for the individual to raise objections with the Court or administrative tribunal has elapsed and either no objections were filed or all abjections were resolved by the Court in favor of disclosure.IN THE CIRCUIT COURT 5™ JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA JESUS SANTIAGO, CASE NO.: 2019-CA-2229 vs. Plaintiff, MICHAEL OWENS HERLONG, Defendant. TO: SUBPOENA DUCES TECUM WITHOUT DEPOSITION Medical & Billing Records Custodian Derek G. Bazemore, Jr., MD 401 NW 42" Avenue Plantation, FL 3317 YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON, HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala, Florida 34471 on OCTOBER 30, 2020, at 10:00 A.M. the following: The records to be produced include as FOLLOWS: Inside and outside covers of the chart jacket Doctor's records/reports/notes Nurse's records/reports/notes Administrative reports/notes/memos All billing statements All letters Laboratory records/reports Radiology records/reports Any and all radiology and diagnostic studies including but not limited to MRIs, CT scans and X-rays, preferably on disk 10. Diagnostic reports EMG/MRI/EEG 11. Therapy records/reports/notes 12. Medical evaluation reports 13. Referral forms 14. Insurance documents/forms/ including copies of insurance cards SC RPNAMEYNS15. Patient history forms/ including copies of photo identification 16. Pharmacy records/logs 17. Consultation reports 18. Hospital or outpatient records/billings 19. | Ambulance/EMS reports 20. Any other written information pertaining to: Patient : Jesus Manuel Santiago-Martinez Date of Birth : as Social Security No. : ey All records requested should be all inclusive and should in no way be limited to one incident. Pursuant to 45 C.F.R. 164,512, "A covered entity may use or disclose protected health information without the written consent or authorization of the individual..."to the extent that such use or disclosure is "required by law" and the use or disclosure complied with and is limited to the relevant requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by law" includes, but is not limited to, court orders and court-ordered warrants; subpoenas or summons...a civil or an authorized investigative demand." (emphasis added) IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR TO THE PARTY TO WHOM THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT), PERTAINING TO THE ABOVE-NAMED INDIVIDUAL. IF YOU HAVE A QUESTION, PLEASE CALL _APRIL_ @ (352) 351-1119. THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL TESTIMONY SHALL BE TAKEN. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena. 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. Tf you fail to furnish the records or object to this subpoena, you may be in contempt of court. You are subpoenaed by the attorneys whose name appears on this subpoena and unlessexcused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed. DATED this 6th __ day of OCTOBER, 2020. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, III VIRGIL W. WRIGHT, Il, ESQ. Florida Bar No. 993141 CHRISTOPHER C. COLEMAN, ESQ. Florida Bar No. 0716359 1820 SE 18th Avenue Ocala, Florida 34471 Phone (352) 351-1119 (al/eg) Fax (352) 351-0151 Attorneys for Defendant HIPAA Discovery Demand SATISFACTORY ASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the request for patient information contained in the above referenced legal process to the individual whose information is sought. I have made: @ 4 good faith attempt to provide written notice to the individual at the individual's last known address and/or through the individual's legal counsel, and (2) the notice included sufficient information about the above referenced legal proceeding so that the individual could raise an objection to the Court or administrative tribunal, and the time for the individual to raise objections with the Court or administrative tribunal has elapsed and either no objections were filed or all abjections were resolved by the Court in favor of disclosure.IN THE CIRCUIT COURT S™ JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA JESUS SANTIAGO, CASE NO.: — 2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: Medical & Billing Records Custodian Center for Digestive Medicine German Gonzalez, Jr., MD 7887 North Kendall Drive, Suite 101 Miami, FL 33156 YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON, HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala, Florida 34471 on OCTOBER 390, 2020, at 10:00 A.M. the following: The records to be produced include as FOLLOWS: Inside and outside covers of the chart jacket Doctor's records/reports/notes Nurse's records/reports/notes Administrative reports/notes/memos All billing statements All letters Laboratory records/reports Radiology records/reports Any and all radiology and diagnostic studies including but not limited to MRIs, CT scans and X-rays, preferably on disk 10. Diagnostic reports EMG/MRI/EEG 11. Therapy records/reports/notes 12. Medical evaluation reports 13. Referral forms CRNAMARYWNS14. Insurance documents/forms/ including copies of insurance cards 15. Patient history forms/ including copies of photo identification 16. Pharmacy records/logs 17. Consultation reports 18. Hospital or outpatient records/billings 19. | Ambulance/EMS reports 20. Any other written information pertaining to: Patient : Jesus Manuel Santiago-Martinez Date of Birth : as Social Security No. : eae All records requested should be all inclusive and should in no way be limited to one incident. Pursuant to 45 C.F.R. 164.512, "A covered entity may use or disclose protected health information without the written consent or authorization of the individual..."to the extent that such use or disclosure is "required by law" and the use or disclosure complied with and is limited to the relevant requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by law" includes, but is not limited to, court orders and court-ordered warrants; subpoenas or summons...a civil or an authorized investigative demand." (emphasis added) IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR TO THE PARTY TO WHOM THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT), PERTAINING TO THE ABOVE-NAMED INDIVIDUAL. IF YOU HAVE A QUESTION, PLEASE CALL _APRIL_ @ (352) 351-1119. THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL TESTIMONY SHALL BE TAKEN. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena. 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. If you fail to furnish the records or object to this subpoena, you may be in contempt ofcourt. You are subpoenaed by the attorneys whose name appears on this subpoena and unless excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed. DATED this 6th _ day of OCTOBER, 2020. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, IIT VIRGIL W. WRIGHT, Ill, ESQ. Florida Bar No. 993141 CHRISTOPHER C. COLEMAN, ESQ. Florida Bar No. 0716359 1820 SE 18th Avenue Ocala, Florida 34471 Phone (352) 351-1119 (al/eg) Fax (352) 351-0151 Attorneys for Defendant HIPAA Discovery Demand SATISFACTORY ASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the request for patient information contained in the above referenced legal process to the individual whose information is sought. I have made: @ a good faith attempt to provide written notice to the individual at the individual's last known address and/or through the individual's legal counsel, and Q the notice included sufficient information about the above referenced legal proceeding so that the individual could raise an objection to the Court or administrative tribunal, and (3) the time for the individual to raise objections with the Court or administrative tribunal has elapsed and either no objections were filed or all abjections were resolved by the Court in favor of disclosure.