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Filing # 100662831 E-Filed 12/20/2019 02:33:04 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
Alachua Chiropractic
1400 SE Magnolia Extension
Ocala, FL 34471
Medical Records Custodian
AdventHealth Ocala
Post Office Box 6000
Ocala, FL 34478-6000
Billing Records Custodian
AdventHealth Ocala
Post Office Box 6000
Ocala, FL 34478-6000
Electronically Filed Marion Case # 19CA002229AX 12/20/2019 02:33:04 PMRadiology Records Custodian
AdventHealth Ocala
Post Office Box 6000
Ocala, FL 34478-6000
Medical & Billing Records Custodian
Back to Health Chiropractic
Nathaniel E. Cox, DC
1400 S. Magnolia Avenue
Ocala, FL 34471
Medical & Billing Records Custodian
West Marion Community Hospital
Post Office Box 2200
Ocala, FL 34478-2200
Medical & Billing Records Custodian
Spine & Orthopaedic Specialists of Central, Florida, LLC
395 S. Wickham Rd
Melbourne, FL 32904
Medical & Billing Records Custodian
Radiology Imaging Associates (RIA)
10700 E. Geddes Avenue, Suite 200
Englewood, CO 80111
Medical & Billing Records Custodian
A-1 Medical Imaging of Ocala
301 SE 17" Street
Ocala, FL. 34471
Records Custodian
First Acceptance Insurance Company, Inc.
c/o Chief Financial Officer as Registered Agent
200 E. Gaines Street
Tallahassee, FL 32399
Records Custodian
Blue Cross Blue Shield of Mississippi
3545 Lakeland Drive
Flowood, MS 39232
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., Aitorneys for Plaintiff, MSmith@forthepeople.com,
ECannon@forthepeople.com this 20th day of December 2019.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, IT
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 5™
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
Alachua Chiropractic
1400 SE Magnolia Extension
Ocala, FL 34471-4443
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 January 24, 2020, at 10:00 A.M. the following:
The records to be produced include as FOLLOWS:
PEN AwawNS
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
Diagnostic reports EMG/MRI/EEG
Therapy records/reports/notes
Medical evaluation reports
Referral forms
Insurance documents/forms/ including copies of insurance cards15. 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
Year of Birth : 1963
Social Security No. tO
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 31ST __ day of December 2019,
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, II
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
(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
(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
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: MEDICAL Records Custodian
AdventHealth Ocala
Post Office Box 6000
Ocala, FL 34478-6000
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 January 24, 2020, at 10:00 A.M. the foliowing:
The records to be produced include as FOLLOWS:
ORIN AWERYNe
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
Diagnostic reports EMG/MRI/EEG
Therapy records/reports/notes
Medical evaluation reports
Referral forms
Insurance documents/forms/ including copies of insurance cards15. 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
Year of Birth : 1963
Social Security No.
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 31ST _ day of December 2019.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
__/s/ VIRGIL W WRIGHT, HT
VIRGIL W. WRIGHT, IH, 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.
qa)
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g
T have made:
a good faith attempt to provide written notice te the individual at the individual's last
known address and/or through the individual's legal counsel, and
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,
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, CASENO.: 2019-CA-2229
Plaintiff,
VS.
MICHAEL OWENS HERLONG,
Defendant.
TO:
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
BILLING Records Custodian
AdventHealth Ocala
Post Office Box 6000
Ocala, FL 34478-6000
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 January 24, 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
Diagnostic reports EMG/MRI/EEG
Therapy records/reports/notes
12. Medical evaluation reports
13. Referral forms
14. Insurance documents/forms/ including copies of insurance cards
PO RPANAWEWN SE
Ss15, 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
Year of Birth : 1963
Social Security No. :
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 31ST day of December 2019.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
fs/ VIRGIL W. WRIGHT, IL
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
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,
@
2
8
Thave 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
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,
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, CASENO.: 2019-CA-2229
Plaintiff,
VS.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: RADIOLOGY Records Custodian
AdventHealth Ocala
Post Office Box 6000
Ocala, FL 34478-6000
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 January 24, 2020, at 10:00 A.M. the following:
The records to be produced include as FOLLOWS:
FaNES
CREAN aM wh
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
Diagnostic reports EMG/MRI/EEG
Therapy records/reports/notes
Medical evaluation reports
Referral forms
Insurance documents/forms/ including copies of insurance cards15. 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
Year of Birth : 1963
Social Security No. :
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 wili 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 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 31ST _ day of December 2019.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, HT
VIRGIL W. WRIGHT, II, 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: 1 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.
q@)
@
@
Thave 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
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,
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
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: Medical & Billing Records Custodian
Back to Health Chiropractic
Nathaniel E. Cox, DC
1400 S. Magnolia Avenue
Ocala, FL 34471
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 January 24, 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
CRNA WND14. Insurance documents/forms/ ineluding 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
Year of Birth : 1963
Social Security No.
All records requested should be ali 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 of
court. 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 31ST day of December 2019.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, IT
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
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
{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
y 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, CASENO.: —2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: Medical & Billing Records Custodian
West Marion Community Hospital
Post Office Box 2200
Ocala, FL 34478-2200
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 January 24, 2020, at 10:00 A.M. the following:
The records to be produced include as FOLLOWS:
CRN AMEWN>
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
Diagnostic reports EMG/MRI/EEG
Therapy records/reports/notes
Medical evaluation reports
Referral forms
Insurance documents/forms/ including copies of insurance cards15. 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
Year of Birth : 1963
Social Security No.
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, "Reguired 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 31ST day of December 2019.
CAMERON, HODGES, COLEMAN,
LaPOINTE & WRIGHT, P.A.
{si VIRGIL W. WRIGHT, HT
VIRGIL W. WRIGHT, IIL, 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
(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
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, CASENO.: 2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: Medical & Billing Records Custodian
Spine & Orthopaedic Specialists of Central Florida LLC
395 S. Wickham Road
Melbourne, FL 32904
YOU ARE HEREBY COMMANDED io furnish to the Law Offices of CAMERON,
HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
Florida 34471 on January 24, 2020, at 10:00 A.M. the following:
The records to be produced include as FOLLOWS:
PEN AMWEHN >
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
Diagnostic reports EMG/MRI/EEG
Therapy records/reports/notes
Medical evaluation reports
Referral forms
Insurance documents/forms/ including copies of insurance cards15. 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
Year of Birth : 1963
Social Security No. :
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 31ST day of December 2019.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, HI
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
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
(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
8 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, CASENO.: 2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
TO:
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
Medical & Billing Records Custodian
Radiology Imaging Associates (RIA)
10700 E. Geddes Avenue, Suite 200
Englewood,CO 80111
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 January 24, 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
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
CRN HAMAPYNS
S15. 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
Year of Birth : 1963
Social Security No.
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 JS 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 31ST day of December 2019.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, I
VIRGIL W. WRIGHT, HI, 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 1 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
( 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
GB 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, CASENO.: 2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: Medical & Billing Records Custodian
A-1 Medical Imaging of Ocala
301 SE 17" Street
Ocala, FL 34471
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 January 24, 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
VENIAM YN14. 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,
Year of Birth 2 1963
Social Security No. :
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 of
court. 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 31ST day of December 2019.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, HT
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.
@)
2)
38
Ihave 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
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,
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, CASENO,: 2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: — Records Custodian
First Acceptance Insurance Company, Inc.
c/o Chief Financial Officer as Registered Agent
200 E. Gaines Street
Tallahassee, FL 32399
YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON, HODGES,
COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18 Avenue, Suite 1, Ocala, Florida 34471, on
January 24, 2020, at 10:00 A.M. the following:
Any and_all documents and information concerning any and all memberships
and/or benefits paid to or on behalf of__ JESUS MANUEL SANTIAGO
MARTINEZ __ as a result of any and all incidents including, but not limited
to Worker's Compensation, PIP, Med Pay, etc. and lost wages at_any time.
Request is for all records and not limited to this date of accident.
Claimant 3 Jesus Manuel Santiago Martinez
Year of Birth : 1963
Date of Loss : 05/12/2017
Policy No. / Claim No. : CSFL201556 / 091703752
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 notlimited 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 _APRIE _ @ (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 of court. You
are subpoenaed by the altormeys 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 31ST day of December 2019.
CAMERON, HODGES. COLEMAN,
LaPOINTE & WRIGHT, P.A.
/s/ VIRGIL W. WRIGHT, IIT
VIRGIL W. WRIGHT, II, 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 DefendantHIPAA 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:
qd) 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 tribuna, and
GB) the time for the individual to raise objections with the Court or administrative tribunal
has elapsed and either no objections were filed or all objections were resolved by the
Court in favor of disclosure.IN THE CIRCUIT COURT 5™
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
JESUS SANTIAGO, CASENO,: 2019-CA-2229
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
TO: Records Custodian
Blue Cross Blue Shield of Mississippi
3545 Lakeland Drive
Flowood, MS 392332
YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON, HODGES,
COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18 Avenue, Suite 1, Ocala, Florida 34471, on
January 24, 2020, at 10:00 A.M. the following:
Any and all documents and information concerning any and all memberships
and/or benefits paid to or on behalf
Preview
Filing # 100662831 E-Filed 12/20/2019 02:33:04 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 Alachua Chiropractic 1400 SE Magnolia Extension Ocala, FL 34471 Medical Records Custodian AdventHealth Ocala Post Office Box 6000 Ocala, FL 34478-6000 Billing Records Custodian AdventHealth Ocala Post Office Box 6000 Ocala, FL 34478-6000 Electronically Filed Marion Case # 19CA002229AX 12/20/2019 02:33:04 PMRadiology Records Custodian AdventHealth Ocala Post Office Box 6000 Ocala, FL 34478-6000 Medical & Billing Records Custodian Back to Health Chiropractic Nathaniel E. Cox, DC 1400 S. Magnolia Avenue Ocala, FL 34471 Medical & Billing Records Custodian West Marion Community Hospital Post Office Box 2200 Ocala, FL 34478-2200 Medical & Billing Records Custodian Spine & Orthopaedic Specialists of Central, Florida, LLC 395 S. Wickham Rd Melbourne, FL 32904 Medical & Billing Records Custodian Radiology Imaging Associates (RIA) 10700 E. Geddes Avenue, Suite 200 Englewood, CO 80111 Medical & Billing Records Custodian A-1 Medical Imaging of Ocala 301 SE 17" Street Ocala, FL. 34471 Records Custodian First Acceptance Insurance Company, Inc. c/o Chief Financial Officer as Registered Agent 200 E. Gaines Street Tallahassee, FL 32399 Records Custodian Blue Cross Blue Shield of Mississippi 3545 Lakeland Drive Flowood, MS 39232 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., Aitorneys for Plaintiff, MSmith@forthepeople.com, ECannon@forthepeople.com this 20th day of December 2019. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, IT 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 5™ 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 Alachua Chiropractic 1400 SE Magnolia Extension Ocala, FL 34471-4443 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 January 24, 2020, at 10:00 A.M. the following: The records to be produced include as FOLLOWS: PEN AwawNS 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 Diagnostic reports EMG/MRI/EEG Therapy records/reports/notes Medical evaluation reports Referral forms Insurance documents/forms/ including copies of insurance cards15. 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 Year of Birth : 1963 Social Security No. tO 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 31ST __ day of December 2019, CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, II 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 (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 (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 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: MEDICAL Records Custodian AdventHealth Ocala Post Office Box 6000 Ocala, FL 34478-6000 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 January 24, 2020, at 10:00 A.M. the foliowing: The records to be produced include as FOLLOWS: ORIN AWERYNe 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 Diagnostic reports EMG/MRI/EEG Therapy records/reports/notes Medical evaluation reports Referral forms Insurance documents/forms/ including copies of insurance cards15. 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 Year of Birth : 1963 Social Security No. 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 31ST _ day of December 2019. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. __/s/ VIRGIL W WRIGHT, HT VIRGIL W. WRIGHT, IH, 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. qa) @ g T have made: a good faith attempt to provide written notice te the individual at the individual's last known address and/or through the individual's legal counsel, and 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, 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, CASENO.: 2019-CA-2229 Plaintiff, VS. MICHAEL OWENS HERLONG, Defendant. TO: SUBPOENA DUCES TECUM WITHOUT DEPOSITION BILLING Records Custodian AdventHealth Ocala Post Office Box 6000 Ocala, FL 34478-6000 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 January 24, 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 Diagnostic reports EMG/MRI/EEG Therapy records/reports/notes 12. Medical evaluation reports 13. Referral forms 14. Insurance documents/forms/ including copies of insurance cards PO RPANAWEWN SE Ss15, 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 Year of Birth : 1963 Social Security No. : 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 31ST day of December 2019. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. fs/ VIRGIL W. WRIGHT, IL 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 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, @ 2 8 Thave 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 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, 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, CASENO.: 2019-CA-2229 Plaintiff, VS. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: RADIOLOGY Records Custodian AdventHealth Ocala Post Office Box 6000 Ocala, FL 34478-6000 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 January 24, 2020, at 10:00 A.M. the following: The records to be produced include as FOLLOWS: FaNES CREAN aM wh 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 Diagnostic reports EMG/MRI/EEG Therapy records/reports/notes Medical evaluation reports Referral forms Insurance documents/forms/ including copies of insurance cards15. 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 Year of Birth : 1963 Social Security No. : 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 wili 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 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 31ST _ day of December 2019. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, HT VIRGIL W. WRIGHT, II, 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: 1 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. q@) @ @ Thave 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 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, 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 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: Medical & Billing Records Custodian Back to Health Chiropractic Nathaniel E. Cox, DC 1400 S. Magnolia Avenue Ocala, FL 34471 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 January 24, 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 CRNA WND14. Insurance documents/forms/ ineluding 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 Year of Birth : 1963 Social Security No. All records requested should be ali 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 of court. 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 31ST day of December 2019. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, IT 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 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 {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 y 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, CASENO.: —2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: Medical & Billing Records Custodian West Marion Community Hospital Post Office Box 2200 Ocala, FL 34478-2200 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 January 24, 2020, at 10:00 A.M. the following: The records to be produced include as FOLLOWS: CRN AMEWN> 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 Diagnostic reports EMG/MRI/EEG Therapy records/reports/notes Medical evaluation reports Referral forms Insurance documents/forms/ including copies of insurance cards15. 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 Year of Birth : 1963 Social Security No. 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, "Reguired 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 31ST day of December 2019. CAMERON, HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A. {si VIRGIL W. WRIGHT, HT VIRGIL W. WRIGHT, IIL, 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 (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 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, CASENO.: 2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: Medical & Billing Records Custodian Spine & Orthopaedic Specialists of Central Florida LLC 395 S. Wickham Road Melbourne, FL 32904 YOU ARE HEREBY COMMANDED io furnish to the Law Offices of CAMERON, HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18th Avenue, Suite 1, Ocala, Florida 34471 on January 24, 2020, at 10:00 A.M. the following: The records to be produced include as FOLLOWS: PEN AMWEHN > 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 Diagnostic reports EMG/MRI/EEG Therapy records/reports/notes Medical evaluation reports Referral forms Insurance documents/forms/ including copies of insurance cards15. 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 Year of Birth : 1963 Social Security No. : 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 31ST day of December 2019. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, HI 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 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 (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 8 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, CASENO.: 2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. TO: SUBPOENA DUCES TECUM WITHOUT DEPOSITION Medical & Billing Records Custodian Radiology Imaging Associates (RIA) 10700 E. Geddes Avenue, Suite 200 Englewood,CO 80111 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 January 24, 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 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 CRN HAMAPYNS S15. 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 Year of Birth : 1963 Social Security No. 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 JS 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 31ST day of December 2019. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, I VIRGIL W. WRIGHT, HI, 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 1 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 ( 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 GB 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, CASENO.: 2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: Medical & Billing Records Custodian A-1 Medical Imaging of Ocala 301 SE 17" Street Ocala, FL 34471 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 January 24, 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 VENIAM YN14. 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, Year of Birth 2 1963 Social Security No. : 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 of court. 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 31ST day of December 2019. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, HT 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. @) 2) 38 Ihave 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 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, 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, CASENO,: 2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: — Records Custodian First Acceptance Insurance Company, Inc. c/o Chief Financial Officer as Registered Agent 200 E. Gaines Street Tallahassee, FL 32399 YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON, HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18 Avenue, Suite 1, Ocala, Florida 34471, on January 24, 2020, at 10:00 A.M. the following: Any and_all documents and information concerning any and all memberships and/or benefits paid to or on behalf of__ JESUS MANUEL SANTIAGO MARTINEZ __ as a result of any and all incidents including, but not limited to Worker's Compensation, PIP, Med Pay, etc. and lost wages at_any time. Request is for all records and not limited to this date of accident. Claimant 3 Jesus Manuel Santiago Martinez Year of Birth : 1963 Date of Loss : 05/12/2017 Policy No. / Claim No. : CSFL201556 / 091703752 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 notlimited 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 _APRIE _ @ (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 of court. You are subpoenaed by the altormeys 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 31ST day of December 2019. CAMERON, HODGES. COLEMAN, LaPOINTE & WRIGHT, P.A. /s/ VIRGIL W. WRIGHT, IIT VIRGIL W. WRIGHT, II, 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 DefendantHIPAA 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: qd) 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 tribuna, and GB) the time for the individual to raise objections with the Court or administrative tribunal has elapsed and either no objections were filed or all objections were resolved by the Court in favor of disclosure.IN THE CIRCUIT COURT 5™ JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA JESUS SANTIAGO, CASENO,: 2019-CA-2229 Plaintiff, vs. MICHAEL OWENS HERLONG, Defendant. SUBPOENA DUCES TECUM WITHOUT DEPOSITION TO: Records Custodian Blue Cross Blue Shield of Mississippi 3545 Lakeland Drive Flowood, MS 392332 YOU ARE HEREBY COMMANDED to furnish to the Law Offices of CAMERON, HODGES, COLEMAN, LaPOINTE & WRIGHT, P.A., 1820 SE 18 Avenue, Suite 1, Ocala, Florida 34471, on January 24, 2020, at 10:00 A.M. the following: Any and all documents and information concerning any and all memberships and/or benefits paid to or on behalf