Party Discovery: BEDSTONE HOLDINGS INC A FLORIDA CORPORATION vs DOOLEY & DRAKE P.A.

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                                IN THE CIRCUIT COURT OF THE 12TH JUDICIAL CIRCUIT IN AND
FOR SARASOTA COUNTY, FLORIDA

CASE NO: 2007-CA-15727NC

Bedstone Holdings, Inc.

A Florida Corporation,
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Defendant(s).

SUBPOENA DUCES TECUM WITHOUT DEPOSITION

THE STATE OF FLORIDA:

TO:

Brad Bailey or other representative of Sarasota County
1301 Cattleman Road, Bldg. D.
Sarasota, FL 34232

YOU ARE HEREBY COMMANDED to appear at the offices of Cole, Scott & Kissane
P.A.c/o U.S. Legal Support, Inc., 515 E. Las Olas Blvd. 3rd Floor, Ft. Lauderdale, FL 33301,
(954) 797-7135 on the date of/CT_ 0 4atfifo have with you at said time and place the

following:

1.

(| ii HA

All correspondence between Brad Bailey or other representative of
Sarasota County and Bedstone Holdings, Inc. or counsel for Bedstone
Holdings, Inc. regarding the subject matter of the above-captioned
lawsuit.

The curriculum vitae of Brad Bailey or other representative of Sarasota
County and any other professional who has provided expert
services in the above-captioned lawsuit.

A list of all trials and depositions in which Brad Bailey or other
representative of Sarasota County has testified in the last five (5)
years.

A list of all matters in which Brad Bailey or other representative ofSarasota County has provided expert services for Plaintiff or
Plaintiff's counsel at any time.

5. All documents or tangible things reviewed by Brad Bailey or other
representative of Sarasota County in preparation for forming any
opinions to be expressed in this litigation.

6. Photographs taken in regards to the subject incident.

7. Copies of any regulations or statutes provided to or relied upon by
any of your experts in forming their opinions in this case.

8. All correspondence between Plaintiff and/or Plaintiff's counsel and

Brad Bailey or other representative of Sarasota County relating to the
subject accident or any issues relating to this lawsuit.

9. Any reports generated or any notes by Brad Bailey or other
representative of Sarasota County containing any opinions formed in
this case.

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 payment in advance of 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 by the attorneys whose names
appear on this subpoena and unless excused by them or the court, you shall respond to
this subpoena as directed.WITNESS my hand and the seal on SeptembattP 14 201810.

By:

DANIEL A. SHAPIRO
FBN: 965960

VINCENT S. GANNUSCIO
FBN: 0018110

COLE, SCOTT & KISSANE, P.A.
Attorneys for Defendant(s)

4301 W. Boy Scout Boulevard

Suite 400 Tampa, Florida 33607
E-Mail Address: shapiro@csklegal.com
Telephone: (813) 289-9300

Facsimile: (813) 286-2900
L:\0314-0011-O0\P\SDT Or. John Lloyd.doc

-3-NOTICE OF HIPAA COMPLIANCE

Pursuant to 42 CFR 164.512(e)(1)(ili) and Rule 1.351, Florida Rules of CivilProcedure,
the attached Notice of Production From Non-Parties was served upopy plaintiff more
than 15 days before this subpoena was issued and no objections were filed regarding
the medical records requested by way of this subpoena.

FBN: 0018110

-4-‘ AFFIDAVIT OF SERVICE

State of Florida County of For Sarasota 12th Judicial Circuit
in and Court

Case Number: 2007-CA-15727NC

Plaintiff:
Bedstone Holdings, Inc.
A Florida Corporation,

VS.

Defendant:
Dooley & Drake, P.A., William A. Dooley, and
J. Kevin Drake,

For: VINCENT S. GANNUSCIO
COLE, SCOTT & KISSANE, P.A.
4301 West Boy Scout Boulevard Suite 400
Tampa, FL 33607

THE AFFIANT, being duly sworn, states: I am authorized by law to serve process and/or I am not a party and not less than
18 years of age. I personally served a true copy of the Subpoena Duces Tecum on:

CUSTODIAN OF RECORDS FOR:

Brad Bailey or other representative of Sarasota County , 1301 Cattleman Road, Bldg. D. , Sarasota, FL 34232

DATE OF SERVICE: G bn ho

TIME OF SERVICE: 2 1S p. ou

By leaving a true copy of the documents with: W4 A, L A

Who is authorized to accept service.

Pursuant to Rule 1.410, Florida Rules of Civil Procedure,

Subscribed and Sworn to before me:

My Commission Expires:
NOTARY PUBLIC
STATE OF FLORIDA AT LARGE

Order No. 02-15197-003