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  • DAWN MECHEMVs.NAUTI NANCYS INC NEGLIGENCE - PREMISES LIABILITY - COMMERCIAL document preview
  • DAWN MECHEMVs.NAUTI NANCYS INC NEGLIGENCE - PREMISES LIABILITY - COMMERCIAL document preview
  • DAWN MECHEMVs.NAUTI NANCYS INC NEGLIGENCE - PREMISES LIABILITY - COMMERCIAL document preview
  • DAWN MECHEMVs.NAUTI NANCYS INC NEGLIGENCE - PREMISES LIABILITY - COMMERCIAL document preview
  • DAWN MECHEMVs.NAUTI NANCYS INC NEGLIGENCE - PREMISES LIABILITY - COMMERCIAL document preview
  • DAWN MECHEMVs.NAUTI NANCYS INC NEGLIGENCE - PREMISES LIABILITY - COMMERCIAL document preview
  • DAWN MECHEMVs.NAUTI NANCYS INC NEGLIGENCE - PREMISES LIABILITY - COMMERCIAL document preview
  • DAWN MECHEMVs.NAUTI NANCYS INC NEGLIGENCE - PREMISES LIABILITY - COMMERCIAL document preview
						
                                

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Filing # 76752006 E-Filed 08/21/2018 12:48:03 PM IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NO. 17-007589-CI DAWN MECHEM, Plaintiff(s), vs. NAUTI NANCY'S, INC, d/b/a NAUTI NANCY'S RESTAURANT, Defendant(s), NOTICE OF PRODUCTION FROM NON-PARTY TO ALL PARTIES: YOU ARE NOTIFIED that after 10 days from the date of service of this Notice, if service is by delivery, or 15 days from the date of electronic service, 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 subpoena(s) directed to: 1) DR. BRIAN BURKE 2) MAIL-MEDS CLINICAL PHARMACY 3) LARGO MEDICAL CENTER — MEDICAL RECORDS 4) LARGO MEDICAL CENTER — RADIOLOGY DEPT. 5) FUSION HEALTHCARE who are not parties, to produce the items listed at the time and place specified in the subpoena(s). MCS # 45136 DE52 ***ELECTRONICALLY FILED 08/21/2018 12:48:03 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 215‘: day of August , 2018, a true and correct copy of the foregoing has been furnished by electronic mail (email) at e-mail address: NEAL J.GAMBLER, 111,ESQUIRE, FARAH & FARAH, 1511 NW. 6TH STREET, GAINESVILLE, FL 32601, (352)240-7700, Primary Email: ngambler@farahandfarah.com, Secondary e-mail: cfrost@farahandfarah.com, Third e-mail: kmckenzie@farahandfarah.com; and I electronically filed the foregoing with the Clerk of PINELLAS COUNTY by using the Florida courts eFiling Portal. LAW OFFICE OF MARC M. CRUMPTON, JR. Attorneys for Defendant(s) 13577 FEATHER SOUND DRIVE SUITE 390 CLEARWATER, FL 33762 (727)954—1952 Janm fir (1m: By: JENNIFER K. FORTE, ESQUIRE Florida Bar No. 16664 MCS # 45136 DE52 IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NO. 17-007589-CI DAWN MECHEM, Plaintiff(s), vs. NAUTI NANCY'S, INC, d/b/a NAUTI NANCY'S RESTAURANT, Defendant(s), / SUBPOENA DUCES TECUM WITHOUT DEPOSITION (RECORDS MAIL IN ONLY) THE STATE OF FLORIDA: To: The Records Custodian for: DR. BRIAN BURKE 360 CENTRAL AVENUE SUITE 1560 ST. PETERSBURG, FL 33701 YOU ARE COMlVIANDED to furnish via US. Mail delivery to THE MCS GROUP, INC, 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 on September 28, 2018 at 9:00 a.m., and to have with you at that time and place the following: Any and all office, in-patient, out-patient and/or emergency room records, billing, and diagnostic files, including, but not limited to, any and all correspondence to and from the consulting and or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication and or prescription records, medical billing and payment records, X-ray films and tests with subsequent reports, MRI films and reports, intake sheets, all intraoperative photos and video tapes, including any and all such items as may be stored in a computer database or other electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: DAWN MECHEM, 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 MCS GROUP, INC, on behalf of 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 MCS GROUP, INC, at 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 and thereby eliminate your appearance at the time and place specified above. Prior approval required for fees in excess of $200.00. You have the right to object to the production pursuant to this subpoena MCS # 45136-35 SU14 at any time before production by giving written notice to THE MCS GROUP, INC. 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 shall respond to this subpoena as directed. DATED ON JENNIFER K. FORTE, ESQUIRE Florida Bar No. 16664 LAW OFFICE OF MARC M. CRUMPTON, JR. Attorneys for Defendant(s) c/o THE MCS GROUP, INC. 7925 NW 12TH STREET, SUITE 318 MIAMI, FL 33126 (305)374-1166 MCS # 45136-35 SU14 IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NO. 17-007589-CI DAWN MECHEM, Plaintiff(s), vs. NAUTI NANCY'S, INC, d/b/a NAUTI NANCY'S RESTAURANT, Defendant(s), / SUBPOENA DUCES TECUM WITHOUT DEPOSITION (RECORDS MAIL IN ONLY) THE STATE OF FLORIDA: To: The Records Custodian for: MAIL-MEDS CLINICAL PHARMACY 2692 OAK RIDGE COURT FORT MYERS, FL 33901 YOU ARE COMlVIANDED to furnish via US. Mail delivery to THE MCS GROUP, INC, 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 on September 28, 2018 at 9:00 a.m., and to have with you at that time and place the following: Any and all prescription records kept in the regular course of business including but not limited to prescription prescribed, physicians prescribing medications, medication description, medication side effect print out, frequency medication to be taken, billing, insurance and payment records, and any and all records kept in your file pertaining to: DAWN MECHEM, 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 MCS GROUP, INC, on behalf of 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 MCS GROUP, INC, at 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 and thereby eliminate your appearance at the time and place specified above. Prior approval required for fees in excess of $200.00. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to THE MCS GROUP, INC. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. MCS # 45136-36 SU14 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 shall respond to this subpoena as directed. DATED ON JENNIFER K. FORTE, ESQUIRE Florida Bar No. 16664 LAW OFFICE OF MARC M. CRUMPTON, JR. Attorneys for Defendant(s) c/o THE MCS GROUP, INC. 7925 NW 12TH STREET, SUITE 318 MIAMI, FL 33126 (305)374-1166 MCS # 45136-36 SU14 IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NO. 17-007589-CI DAWN MECHEM, Plaintiff(s), vs. NAUTI NANCY'S, INC, d/b/a NAUTI NANCY'S RESTAURANT, Defendant(s), / SUBPOENA DUCES TECUM WITHOUT DEPOSITION (RECORDS MAIL IN ONLY) THE STATE OF FLORIDA: To: The Records Custodian for: LARGO MEDICAL CENTER ATTN: MEDICAL RECORDS 201 14TH STREET S.W. LARGO, FL 33770 YOU ARE COMlVIANDED to furnish via US. Mail delivery to THE MCS GROUP, INC, 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 on September 28, 2018 at 9:00 a.m., and to have with you at that time and place the following: Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physician files, memoranda, handwritten notes, intake sheets, history and physical reports, medication, prescription records, intra-operative photos and video tapes including any and all such items as may be stored in a computer database or other electronic form, relating to any examination, consultation, diagnosis of treatment pertaining to: DAWN MECHEM, 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 MCS GROUP, INC, on behalf of 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 MCS GROUP, INC, at 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 and thereby eliminate your appearance at the time and place specified above. Prior approval required for fees in excess of $200.00. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to THE MCS GROUP, INC. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. MCS # 45136-37 SU14 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 shall respond to this subpoena as directed. DATED ON JENNIFER K. FORTE, ESQUIRE Florida Bar No. 16664 LAW OFFICE OF MARC M. CRUMPTON, JR. Attorneys for Defendant(s) c/o THE MCS GROUP, INC. 7925 NW 12TH STREET, SUITE 318 MIAMI, FL 33126 (305)374-1166 MCS # 45136-37 SU14 IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NO. 17-007589-CI DAWN MECHEM, Plaintiff(s), vs. NAUTI NANCY'S, INC, d/b/a NAUTI NANCY'S RESTAURANT, Defendant(s), / SUBPOENA DUCES TECUM WITHOUT DEPOSITION (RECORDS MAIL IN ONLY) THE STATE OF FLORIDA: To: The Records Custodian for: LARGO MEDICAL CENTER ATTN: RADIOLOGY DEPT. 201 14TH STREET S.W. LARGO, FL 33770 YOU ARE COMlVIANDED to furnish via US. Mail delivery to THE MCS GROUP, INC, 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 on September 28, 2018 at 9:00 a.m., and to have with you at that time and place the following: Any and all x-rays, CT scans, MRIs, ultrasounds, mammograms and any other diagnostic or radiographic tests as well as all documents included within the X-ray jacket for all films pertaining to: DAWN MECHEM, 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 MCS GROUP, INC, on behalf of 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 MCS GROUP, INC, at 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 and thereby eliminate your appearance at the time and place specified above. Prior approval required for fees in excess of $200.00. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to THE MCS GROUP, INC. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. MCS # 45136-38 SU14 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 shall respond to this subpoena as directed. DATED ON JENNIFER K. FORTE, ESQUIRE Florida Bar No. 16664 LAW OFFICE OF MARC M. CRUMPTON, JR. Attorneys for Defendant(s) c/o THE MCS GROUP, INC. 7925 NW 12TH STREET, SUITE 318 MIAMI, FL 33126 (305)374-1166 MCS # 45136-38 SU14 IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NO. 17-007589-CI DAWN MECHEM, Plaintiff(s), vs. NAUTI NANCY'S, INC, d/b/a NAUTI NANCY'S RESTAURANT, Defendant(s), / SUBPOENA DUCES TECUM WITHOUT DEPOSITION (RECORDS MAIL IN ONLY) THE STATE OF FLORIDA: To: The Records Custodian for: FUSION HEALTHCARE 10901 CORPORATE CIRCLE N. SUITE A ST. PETERSBURG, FL 33706 YOU ARE COMlVIANDED to furnish via US. Mail delivery to THE MCS GROUP, INC, 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 on September 28, 2018 at 9:00 a.m., and to have with you at that time and place the following: Any and all office, in-patient, out-patient and/or emergency room records, billing, and diagnostic files, including, but not limited to, any and all correspondence to and from the consulting and or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication and or prescription records, medical billing and payment records, X-ray films and tests with subsequent reports, MRI films and reports, intake sheets, all intraoperative photos and video tapes, including any and all such items as may be stored in a computer database or other electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: DAWN MECHEM, 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 MCS GROUP, INC, on behalf of 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 MCS GROUP, INC, at 7925 NW 12TH STREET, SUITE 318, MIAMI, FL 33126 and thereby eliminate your appearance at the time and place specified above. Prior approval required for fees in excess of $200.00. You have the right to object to the production pursuant to this subpoena MCS # 45136-39 SU14 at any time before production by giving written notice to THE MCS GROUP, INC. 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 shall respond to this subpoena as directed. DATED ON JENNIFER K. FORTE, ESQUIRE Florida Bar No. 16664 LAW OFFICE OF MARC M. CRUMPTON, JR. Attorneys for Defendant(s) c/o THE MCS GROUP, INC. 7925 NW 12TH STREET, SUITE 318 MIAMI, FL 33126 (305)374-1166 MCS # 45136-39 SU14