Preview
Filing # 122791860 E-Filed 03/09/2021 04:43:29 PM
92235-7
IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
ELVIS NEVERS CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2019-011633CA01
v.
CECILIA SOLARES
Defendant.
____________________________/
AMENDED NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service
is by delivery or email, or 15 days from the date of service if service is by mail, and if no objection
is received from any party, the undersigned will issue or apply to the clerk of this court for issuance
of the attached subpoenas directed to:
North Broward Radiologists Phoenix Ed Med of Broward, LLC
1801 S Perimeter Rd. PO Box 38048
Fort Lauderdale, FL 33309 Philadelphia, PA 19101-0813
Phoenix Emergency Medicine Of Equian
Broward LLC P.O. Box 32100
1600 S Andrews Ave Louisville, KY 40232
Ft Lauderdale, FL 33316-2510
who are not parties and whose addresses are indicated on the attached subpoenas, to produce the
items listed at the time and place specified in the subpoena.
WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida
ePortal to: Michael P. Maguire, lawpro70@aol.com; Elis Rojas, elis.rojas@wilsonelser.com;
rebecca.lacayo@wilsonelser.com; eservice.miami@wilsonelser.com; on this 9th day of March,
2021.
CASE NO. 2019-011633CA01
/s/ Robert E. Paradela
Robert E. Paradela, Esquire
Florida Bar No. 842095
WICKER SMITH O'HARA MCCOY & FORD, P.A.
Attorneys for Cecilia Solares
515 E. Las Olas BoulevardSuite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800; Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
92235-7
IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
ELVIS NEVERS CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2019-011633CA01
v.
CECILIA SOLARES
Defendant.
____________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
North Broward Radiologists
1801 S Perimeter Rd.
Fort Lauderdale, FL 33309
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on
March 19, 2021, at 9:00 a.m., and to have with you at that time and place the following:
Any and all in-patient, out-patient and emergency room records including but not limited to
reports, charts, documents, microfilmed documents, radiology reports and radiology studies
including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services
(paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions,
correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG /
echocardiograms, requests for records, and any and all other evidence relating to the
examination, treatment care, diagnosis, physical and mental condition of the person named
below, from the inception of your records to the present.
If the records are maintained in an electronic format, please produce all records via e-mail, CD,
USB flash drive, or a ShareFile link.
IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00,
PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE-
APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF
YOUR INVOICE.
NAME: Elvis Nevers DOB: SSN:
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given
10 days’ notice to object our obtaining these records and this exact form has been provided
to the patient and/or the patient’s legal counsel.
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 and thereby eliminate
your appearance at the time and place specified above. You have the right to object to the
production pursuant to this subpoena at any time before production by giving written notice to
the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO
TESTIMONY WILL BE TAKEN.
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney and
unless excused from this subpoena by this attorney or the Court, you must respond to this
subpoena as directed.
DATED on /s/ Robert E. Paradela
Robert E. Paradela, Esquire
For the Court
Florida Bar No. 842095
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Cecilia Solares
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities
needing a special accommodation to participate in this proceeding should contact
the undersigned attorney’s secretary at the address and phone number given above
not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-
800-955-8770 via Florida Relay Service.
92235-7
IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
ELVIS NEVERS CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2019-011633CA01
v.
CECILIA SOLARES
Defendant.
____________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Phoenix Ed Med of Broward, LLC
PO Box 38048
Philadelphia, PA 19101-0813
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on
March 19, 2021, at 9:00 a.m., and to have with you at that time and place the following:
Any and all in-patient, out-patient and emergency room records including but not limited to
reports, charts, documents, microfilmed documents, radiology reports and radiology studies
including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services
(paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions,
correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG /
echocardiograms, requests for records, and any and all other evidence relating to the
examination, treatment care, diagnosis, physical and mental condition of the person named
below, from the inception of your records to the present.
If the records are maintained in an electronic format, please produce all records via e-mail, CD,
USB flash drive, or a ShareFile link.
IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00,
PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE-
APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF
YOUR INVOICE.
NAME: Elvis Nevers DOB: SSN:
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given
10 days’ notice to object our obtaining these records and this exact form has been provided
to the patient and/or the patient’s legal counsel.
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 and thereby eliminate
your appearance at the time and place specified above. You have the right to object to the
production pursuant to this subpoena at any time before production by giving written notice to
the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO
TESTIMONY WILL BE TAKEN.
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney and
unless excused from this subpoena by this attorney or the Court, you must respond to this
subpoena as directed.
DATED on /s/ Robert E. Paradela
Robert E. Paradela, Esquire
For the Court
Florida Bar No. 842095
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Cecilia Solares
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities
needing a special accommodation to participate in this proceeding should contact
the undersigned attorney’s secretary at the address and phone number given above
not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-
800-955-8770 via Florida Relay Service.
92235-7
IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
ELVIS NEVERS CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2019-011633CA01
v.
CECILIA SOLARES
Defendant.
____________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Phoenix Emergency Medicine Of
Broward LLC
1600 S Andrews Ave
Ft Lauderdale, FL 33316-2510
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on
March 19, 2021, at 9:00 a.m., and to have with you at that time and place the following:
Any and all in-patient, out-patient and emergency room records including but not limited to
reports, charts, documents, microfilmed documents, radiology reports and radiology studies
including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services
(paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions,
correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG /
echocardiograms, requests for records, and any and all other evidence relating to the
examination, treatment care, diagnosis, physical and mental condition of the person named
below, from the inception of your records to the present.
If the records are maintained in an electronic format, please produce all records via e-mail, CD,
USB flash drive, or a ShareFile link.
IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00,
PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE-
APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF
YOUR INVOICE.
NAME: Elvis Nevers DOB: SSN:
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given
10 days’ notice to object our obtaining these records and this exact form has been provided
to the patient and/or the patient’s legal counsel.
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 and thereby eliminate
your appearance at the time and place specified above. You have the right to object to the
production pursuant to this subpoena at any time before production by giving written notice to
the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO
TESTIMONY WILL BE TAKEN.
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney and
unless excused from this subpoena by this attorney or the Court, you must respond to this
subpoena as directed.
DATED on /s/ Robert E. Paradela
Robert E. Paradela, Esquire
For the Court
Florida Bar No. 842095
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Cecilia Solares
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities
needing a special accommodation to participate in this proceeding should contact
the undersigned attorney’s secretary at the address and phone number given above
not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-
800-955-8770 via Florida Relay Service.
92235-7
IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
ELVIS NEVERS CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2019-011633CA01
v.
CECILIA SOLARES
Defendant.
____________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Equian
P.O. Box 32100
Louisville, KY 40232
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on
March 19, 2021, at 9:00 a.m., and to have with you at that time and place the following:
Any and all in-patient, out-patient and emergency room records including but not limited to
reports, charts, documents, microfilmed documents, radiology reports and radiology studies
including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services
(paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions,
correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG /
echocardiograms, requests for records, and any and all other evidence relating to the
examination, treatment care, diagnosis, physical and mental condition of the person named
below, from the inception of your records to the present.
If the records are maintained in an electronic format, please produce all records via e-mail, CD,
USB flash drive, or a ShareFile link.
IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00,
PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE-
APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF
YOUR INVOICE.
NAME: Elvis Nevers DOB: SSN:
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given
10 days’ notice to object our obtaining these records and this exact form has been provided
to the patient and/or the patient’s legal counsel.
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 and thereby eliminate
your appearance at the time and place specified above. You have the right to object to the
production pursuant to this subpoena at any time before production by giving written notice to
the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO
TESTIMONY WILL BE TAKEN.
If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney and
unless excused from this subpoena by this attorney or the Court, you must respond to this
subpoena as directed.
DATED on /s/ Robert E. Paradela
Robert E. Paradela, Esquire
For the Court
Florida Bar No. 842095
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Cecilia Solares
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities
needing a special accommodation to participate in this proceeding should contact
the undersigned attorney’s secretary at the address and phone number given above
not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-
800-955-8770 via Florida Relay Service.
Preview
Filing # 122791860 E-Filed 03/09/2021 04:43:29 PM 92235-7 IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA ELVIS NEVERS CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2019-011633CA01 v. CECILIA SOLARES Defendant. ____________________________/ AMENDED NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service is by delivery or email, or 15 days from the date of service if service is by mail, and if no objection is received from any party, the undersigned will issue or apply to the clerk of this court for issuance of the attached subpoenas directed to: North Broward Radiologists Phoenix Ed Med of Broward, LLC 1801 S Perimeter Rd. PO Box 38048 Fort Lauderdale, FL 33309 Philadelphia, PA 19101-0813 Phoenix Emergency Medicine Of Equian Broward LLC P.O. Box 32100 1600 S Andrews Ave Louisville, KY 40232 Ft Lauderdale, FL 33316-2510 who are not parties and whose addresses are indicated on the attached subpoenas, to produce the items listed at the time and place specified in the subpoena. WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida ePortal to: Michael P. Maguire, lawpro70@aol.com; Elis Rojas, elis.rojas@wilsonelser.com; rebecca.lacayo@wilsonelser.com; eservice.miami@wilsonelser.com; on this 9th day of March, 2021. CASE NO. 2019-011633CA01 /s/ Robert E. Paradela Robert E. Paradela, Esquire Florida Bar No. 842095 WICKER SMITH O'HARA MCCOY & FORD, P.A. Attorneys for Cecilia Solares 515 E. Las Olas BoulevardSuite 1400 Ft. Lauderdale, FL 33301 Phone: (954) 847-4800; Fax: (954) 760-9353 ftlcrtpleadings@wickersmith.com 92235-7 IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA ELVIS NEVERS CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2019-011633CA01 v. CECILIA SOLARES Defendant. ____________________________/ SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: North Broward Radiologists 1801 S Perimeter Rd. Fort Lauderdale, FL 33309 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on March 19, 2021, at 9:00 a.m., and to have with you at that time and place the following: Any and all in-patient, out-patient and emergency room records including but not limited to reports, charts, documents, microfilmed documents, radiology reports and radiology studies including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services (paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions, correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG / echocardiograms, requests for records, and any and all other evidence relating to the examination, treatment care, diagnosis, physical and mental condition of the person named below, from the inception of your records to the present. If the records are maintained in an electronic format, please produce all records via e-mail, CD, USB flash drive, or a ShareFile link. IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00, PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE- APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF YOUR INVOICE. NAME: Elvis Nevers DOB: SSN: HIPAA COMPLIANCE In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 10 days’ notice to object our obtaining these records and this exact form has been provided to the patient and/or the patient’s legal counsel. 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 and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the Court, you must respond to this subpoena as directed. DATED on /s/ Robert E. Paradela Robert E. Paradela, Esquire For the Court Florida Bar No. 842095 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Cecilia Solares 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 Ft. Lauderdale, FL 33301 Phone: (954) 847-4800 Fax: (954) 760-9353 ftlcrtpleadings@wickersmith.com In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the undersigned attorney’s secretary at the address and phone number given above not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1- 800-955-8770 via Florida Relay Service. 92235-7 IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA ELVIS NEVERS CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2019-011633CA01 v. CECILIA SOLARES Defendant. ____________________________/ SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Phoenix Ed Med of Broward, LLC PO Box 38048 Philadelphia, PA 19101-0813 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on March 19, 2021, at 9:00 a.m., and to have with you at that time and place the following: Any and all in-patient, out-patient and emergency room records including but not limited to reports, charts, documents, microfilmed documents, radiology reports and radiology studies including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services (paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions, correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG / echocardiograms, requests for records, and any and all other evidence relating to the examination, treatment care, diagnosis, physical and mental condition of the person named below, from the inception of your records to the present. If the records are maintained in an electronic format, please produce all records via e-mail, CD, USB flash drive, or a ShareFile link. IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00, PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE- APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF YOUR INVOICE. NAME: Elvis Nevers DOB: SSN: HIPAA COMPLIANCE In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 10 days’ notice to object our obtaining these records and this exact form has been provided to the patient and/or the patient’s legal counsel. 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 and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the Court, you must respond to this subpoena as directed. DATED on /s/ Robert E. Paradela Robert E. Paradela, Esquire For the Court Florida Bar No. 842095 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Cecilia Solares 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 Ft. Lauderdale, FL 33301 Phone: (954) 847-4800 Fax: (954) 760-9353 ftlcrtpleadings@wickersmith.com In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the undersigned attorney’s secretary at the address and phone number given above not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1- 800-955-8770 via Florida Relay Service. 92235-7 IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA ELVIS NEVERS CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2019-011633CA01 v. CECILIA SOLARES Defendant. ____________________________/ SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Phoenix Emergency Medicine Of Broward LLC 1600 S Andrews Ave Ft Lauderdale, FL 33316-2510 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on March 19, 2021, at 9:00 a.m., and to have with you at that time and place the following: Any and all in-patient, out-patient and emergency room records including but not limited to reports, charts, documents, microfilmed documents, radiology reports and radiology studies including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services (paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions, correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG / echocardiograms, requests for records, and any and all other evidence relating to the examination, treatment care, diagnosis, physical and mental condition of the person named below, from the inception of your records to the present. If the records are maintained in an electronic format, please produce all records via e-mail, CD, USB flash drive, or a ShareFile link. IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00, PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE- APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF YOUR INVOICE. NAME: Elvis Nevers DOB: SSN: HIPAA COMPLIANCE In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 10 days’ notice to object our obtaining these records and this exact form has been provided to the patient and/or the patient’s legal counsel. 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 and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the Court, you must respond to this subpoena as directed. DATED on /s/ Robert E. Paradela Robert E. Paradela, Esquire For the Court Florida Bar No. 842095 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Cecilia Solares 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 Ft. Lauderdale, FL 33301 Phone: (954) 847-4800 Fax: (954) 760-9353 ftlcrtpleadings@wickersmith.com In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the undersigned attorney’s secretary at the address and phone number given above not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1- 800-955-8770 via Florida Relay Service. 92235-7 IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA ELVIS NEVERS CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2019-011633CA01 v. CECILIA SOLARES Defendant. ____________________________/ SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Equian P.O. Box 32100 Louisville, KY 40232 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on March 19, 2021, at 9:00 a.m., and to have with you at that time and place the following: Any and all in-patient, out-patient and emergency room records including but not limited to reports, charts, documents, microfilmed documents, radiology reports and radiology studies including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services (paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions, correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG / echocardiograms, requests for records, and any and all other evidence relating to the examination, treatment care, diagnosis, physical and mental condition of the person named below, from the inception of your records to the present. If the records are maintained in an electronic format, please produce all records via e-mail, CD, USB flash drive, or a ShareFile link. IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00, PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE- APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF YOUR INVOICE. NAME: Elvis Nevers DOB: SSN: HIPAA COMPLIANCE In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 10 days’ notice to object our obtaining these records and this exact form has been provided to the patient and/or the patient’s legal counsel. 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 and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the Court, you must respond to this subpoena as directed. DATED on /s/ Robert E. Paradela Robert E. Paradela, Esquire For the Court Florida Bar No. 842095 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Cecilia Solares 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 Ft. Lauderdale, FL 33301 Phone: (954) 847-4800 Fax: (954) 760-9353 ftlcrtpleadings@wickersmith.com In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the undersigned attorney’s secretary at the address and phone number given above not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1- 800-955-8770 via Florida Relay Service.