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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