Preview
Filing # 11072414 Electronically Filed 03/07/2014 10:35:01 AM
75962-8
IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
DEFENDANT’S 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 15 days from the date of service, if service is by e-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:
Francis E. Harrington, MD
848 Ist Avenue N.
Naples, FL 34102
Matthew L. Black, M.D.
2950 9th Street North, Suite 13
Naples, FL 34103
Skin Face Body Esthetics Spa
Diana Mei International, LLC
863 4th Avenue South
Naples, FL 34102
Stand Up MRI of Naples
4521 Executive Drive
Naples, FL 34119
Collier County EMS
8075 Lely Cultural Pkwy, Suite 267
Naples, FL 34113
Filed with Collier County Clerk of CourtsCASE NO. 2013-CA-003346
Ryder Orthopaedics, Inc.
1500 Royal Palm Square Blvd.
Ft. Myers, FL
Naples Day Surgery
311 Tamiami Trail N., Suite 200
Naples, FL 34102
Neuroscience & Spine Associates
1660 Medical Blvd., Suite 200
Naples, FL 34110
NCH Healthcare System, Inc.
2157 Pine Ridge Road
Naples, FL 34109
John R Wood, Inc.
800 5th Avenue South, Suite 200
Naples, FL 34102
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: Kenneth Hancock, eservice@carltonhancock.com; on this 7th day of March, 2014.
/s/ Craig Ferrante
Craig Ferrante, Esquire
Florida Bar No. 324752
WICKER SMITH O'HARA MCCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Francis E. Harrington, M.D.
848 1 Avenue N.
Naples, FL 34102
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all office records, office cards, written memoranda, correspondence, notes,
bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges,
prescriptions, referral forms, phone messages, patient information forms, laser copies of
any photographs, and any other records pertaining to the care and treatment of the person
named below.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: wie 7999CASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Matthew L. Black, M.D.
2950 9th Street North, Suite 13
Naples, FL 34103
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all office records, office cards, written memoranda, correspondence, notes,
bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges,
prescriptions, referral forms, phone messages, patient information forms, laser copies of
any photographs, and any other records pertaining to the care and treatment of the person
named below.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: wie 7999CASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Skin Face Body Esthetics Spa
Diana Mei International, LLC
863 4th Avenue South
Naples, FL 34102
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all office records, office cards, written memoranda, correspondence, notes,
bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges,
prescriptions, referral forms, phone messages, patient information forms, laser copies of
any photographs, and any other records pertaining to the care and treatment of the person
named below.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: HHI ODCASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Stand Up MRI of Naples
4521 Executive Drive
Naples, FL 34119
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all office records, office cards, written memoranda, correspondence, notes,
bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges,
prescriptions, referral forms, phone messages, patient information forms, laser copies of
any photographs, and any other records pertaining to the care and treatment of the person
named below.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: wie 7999CASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Collier County EMS
8075 Lely Cultural Pkwy, Suite 267
Naples, FL 34113
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all office records, office cards, written memoranda, correspondence, notes,
bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges,
prescriptions, referral forms, phone messages, patient information forms, laser copies of
any photographs, and any other records pertaining to the care and treatment of the person
named below.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: wie 7999CASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Ryder Orthopaedics, Inc.
1500 Royal Palm Square Blvd.
Ft. Myers, FL
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all office records, office cards, written memoranda, correspondence, notes,
bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges,
prescriptions, referral forms, phone messages, patient information forms, laser copies of
any photographs, and any other records pertaining to the care and treatment of the person
named below.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: wie 7999CASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Naples Day Surgery
311 Tamiami Trail N., Suite 200
Naples, FL 34102
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all office records, office cards, written memoranda, correspondence, notes,
bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges,
prescriptions, referral forms, phone messages, patient information forms, laser copies of
any photographs, and any other records pertaining to the care and treatment of the person
named below.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: wie 7999CASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Neuroscience & Spine Associates
1660 Medical Blvd., Suite 200
Naples, FL 34110
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all office records, office cards, written memoranda, correspondence, notes,
bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges,
prescriptions, referral forms, phone messages, patient information forms, laser copies of
any photographs, and any other records pertaining to the care and treatment of the person
named below.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: wie 7999CASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: NCH Healthcare System, Inc.
ATTN: Records Custodian
2157 Pine Ridge Road
Naples, FL 34109
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all office records, office cards, written memoranda, correspondence, notes,
bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges,
prescriptions, referral forms, phone messages, patient information forms, laser copies of
any photographs, and any other records pertaining to the care and treatment of the person
named below.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: wie 7999CASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.comCASE NO. 2013-CA-003346
oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
JAMES ELSON, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2013-CA-003346
vs.
RESTAURANT 460-5TH SOUTH,
LLC, A Florida Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
John R Wood, Inc.
800 5th Avenue South, Suite 200
Naples, FL 34102
YOU ARE COMMANDED to provide to the offices of the undersigned counsel within
ten (10) days from the date of service of this Subpoena, the following:
Any and all personnel records, employment records, health records, payroll records,
W-2 forms, records of earnings, time lost from work, reason for termination of
employment, correspondence, application for employment, any and all drug tests, and any
and all other records and documents pertaining to the person named below, who was
employed by your company.
*** Tf the cost of copies will exceed $50.00 or $.25 per page, please call
the attorneys for authorization. ***
NAME: James Elson
DOB: 1/7/1949
SS#: wie 7999CASE NO. 2013-CA-003346
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.
Tf 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: March » 2014
Craig Ferrante, Esquire
For the Court
Florida Bar No. 324752
WICKER, SMITH, O’HARA,
McCOY & FORD, P.A.
Attorneys for Restaurant 460-5th South, LLC
9128 Strada Place, Suite 10200
Naples, FL 34108-2683
Phone: (239) 552-5300
Fax: (239) 552-5399
napertpleadings@wickersmith.com
Preview
Filing # 11072414 Electronically Filed 03/07/2014 10:35:01 AM 75962-8 IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / DEFENDANT’S 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 15 days from the date of service, if service is by e-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: Francis E. Harrington, MD 848 Ist Avenue N. Naples, FL 34102 Matthew L. Black, M.D. 2950 9th Street North, Suite 13 Naples, FL 34103 Skin Face Body Esthetics Spa Diana Mei International, LLC 863 4th Avenue South Naples, FL 34102 Stand Up MRI of Naples 4521 Executive Drive Naples, FL 34119 Collier County EMS 8075 Lely Cultural Pkwy, Suite 267 Naples, FL 34113 Filed with Collier County Clerk of CourtsCASE NO. 2013-CA-003346 Ryder Orthopaedics, Inc. 1500 Royal Palm Square Blvd. Ft. Myers, FL Naples Day Surgery 311 Tamiami Trail N., Suite 200 Naples, FL 34102 Neuroscience & Spine Associates 1660 Medical Blvd., Suite 200 Naples, FL 34110 NCH Healthcare System, Inc. 2157 Pine Ridge Road Naples, FL 34109 John R Wood, Inc. 800 5th Avenue South, Suite 200 Naples, FL 34102 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: Kenneth Hancock, eservice@carltonhancock.com; on this 7th day of March, 2014. /s/ Craig Ferrante Craig Ferrante, Esquire Florida Bar No. 324752 WICKER SMITH O'HARA MCCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Francis E. Harrington, M.D. 848 1 Avenue N. Naples, FL 34102 YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all office records, office cards, written memoranda, correspondence, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: wie 7999CASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Matthew L. Black, M.D. 2950 9th Street North, Suite 13 Naples, FL 34103 YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all office records, office cards, written memoranda, correspondence, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: wie 7999CASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Skin Face Body Esthetics Spa Diana Mei International, LLC 863 4th Avenue South Naples, FL 34102 YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all office records, office cards, written memoranda, correspondence, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: HHI ODCASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Stand Up MRI of Naples 4521 Executive Drive Naples, FL 34119 YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all office records, office cards, written memoranda, correspondence, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: wie 7999CASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Collier County EMS 8075 Lely Cultural Pkwy, Suite 267 Naples, FL 34113 YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all office records, office cards, written memoranda, correspondence, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: wie 7999CASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Ryder Orthopaedics, Inc. 1500 Royal Palm Square Blvd. Ft. Myers, FL YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all office records, office cards, written memoranda, correspondence, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: wie 7999CASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Naples Day Surgery 311 Tamiami Trail N., Suite 200 Naples, FL 34102 YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all office records, office cards, written memoranda, correspondence, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: wie 7999CASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Neuroscience & Spine Associates 1660 Medical Blvd., Suite 200 Naples, FL 34110 YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all office records, office cards, written memoranda, correspondence, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: wie 7999CASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: NCH Healthcare System, Inc. ATTN: Records Custodian 2157 Pine Ridge Road Naples, FL 34109 YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all office records, office cards, written memoranda, correspondence, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: wie 7999CASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.comCASE NO. 2013-CA-003346 oN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA JAMES ELSON, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 2013-CA-003346 vs. RESTAURANT 460-5TH SOUTH, LLC, A Florida Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: John R Wood, Inc. 800 5th Avenue South, Suite 200 Naples, FL 34102 YOU ARE COMMANDED to provide to the offices of the undersigned counsel within ten (10) days from the date of service of this Subpoena, the following: Any and all personnel records, employment records, health records, payroll records, W-2 forms, records of earnings, time lost from work, reason for termination of employment, correspondence, application for employment, any and all drug tests, and any and all other records and documents pertaining to the person named below, who was employed by your company. *** Tf the cost of copies will exceed $50.00 or $.25 per page, please call the attorneys for authorization. *** NAME: James Elson DOB: 1/7/1949 SS#: wie 7999CASE NO. 2013-CA-003346 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. Tf 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: March » 2014 Craig Ferrante, Esquire For the Court Florida Bar No. 324752 WICKER, SMITH, O’HARA, McCOY & FORD, P.A. Attorneys for Restaurant 460-5th South, LLC 9128 Strada Place, Suite 10200 Naples, FL 34108-2683 Phone: (239) 552-5300 Fax: (239) 552-5399 napertpleadings@wickersmith.com