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Filing # 148308798 E-Filed 04/25/2022 01:06:52 PM
State of Florida County of Charlotte Circuit Court
Case Number: 21-001118-CA Court Date: 5/2/2022 10:00 am
Plaintiff:
SANDRA PARSLEY,
vs.
Defendant:
THE STAINTON CORPORATION d/b/a DEAN'S SOUTH OF THE
BORDER,
For:
James E. S|
RITTER CHUSID, LLP
,
Received by CAPLAN, CAPLAN & CAPLAN PROCESS SERVERS on the 19th day of April, 2022 at 4:09 pm to be
served on Records Custodian Associates In Orthopedics, P.A. C/O Kelsey J. Veitengruber, Farr Law Firm, 99
NESBIT ST., PUNTA GORDA, FL 33950.
|, Sally Susino, do hereby affirm that on the 21st day of April, 2022 at 11:55 am, I:
served a CORPORATION, REGISTERED AGENT by delivering a true copy of the SUPOENA DUCES TECUM
WITHOUT DEPOSITION (RECORDS PRODUCTION ONLY), and LETTER FROM ATTORNEY, EXHIBIT "A",
CERTIFICATE OF COMPLETENESS with the date and hour of service endorsed thereon by me, to: KELSEY J.
VEITENGRUBER as DIRECTOR/ REGISTERED AGENT at the address of: 99 NESBIT STREET, PUNTA
GORDA, FL 33950 on behalf of Records Custodian Associates In Orthopedics, P.A. C/O Kelsey J. Veitengruber,
Farr Law Firm, and informed said person of the contents therein, in compliance pursuant to Fed.R.Civ.P. A(h)(1)
(b)
Military Status: Based upon inquiry of party served, Defendant is not in the military service of the United States of
Descripti
of Person
on Served: Age: 43, Sex: W, Race/Skin Color: WHITE, Height: 5'7, Weight: 170, Hair:
BLONDE, Glasses: N
RET URN OF SERVI
S E CE for 21-001
CE 118-CA
EEOC
| certify that | am over the age of 18, have no interest in the above action,
and am a Certified Process Server, in
good standing, in the judicial circuit in which the process was se! red,
Sally Susing
158080
Loe,A 7
aris
CAPLAN, CAPLAN & CAPLAN PROCESS SERVERS
14160 Palmetto Frontage Road, Suite 105
Miami Lakes, FL 33016
(305) 374-3426
Our Job Serial Number: BLZ-2022000151
Ref: 12339
Copyright © 1992-2011 Database Services, inc. - Process Server's Toolbox V6.5»
IN THE CIRCUIT COURT OF THE TWENTIETH JUDIC
IAL CIRCUIT,
IN AND FOR CHARLOTTE COUNTY, FLORIDA
SANDRA PARSLEY,
CASE NO.: 21-001118-CA.
Plaintiff,
vs.
_Ve-eure_
lg
THE STAINTON CORPORATION d/b/a
10
DEAN’S SOUTH OF THE BORDER, Ser,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
[Records May Be Mailed in Lieu of Appearance]
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN
Associates in Orthopedics, P.A.
c/o Kelsey J. Veitengruber
Farr Law Firm
99 Nesbit Street
Punta Gorda, FL 33950
Pursuant to the Health Insurance Portabil
Notified that the attorney ity and Accountability Act of 1996 (HIPAA)
for the referen iced patient and all parties to this action were , you are hereby
fifteen days in which to object to this sub joena. No obj jec ni otified and given
tioto servic
nse of this
by the patieni t's attorneyor by the p: atient him/herself. 45 C.F.R. §164. 512(e). subpoe! na have been filed
service of this subpoena have been served u pon the under Fi ‘urther, no objections to
Fla.R.Civ.P.(b), of service of the notice with attached subpo signed within ten (15) days, under Rule 1.351
ena given to all parties. Accordingly,
YOU ARE COMMANDED to produce and permit inspection and copying of the follow
ing
documents or objects at the law offices of RITTER CHUSID,
LLP,5850 Coral Ridge Drive, Suite
201, Coral Springs, Florida 33076, on May 2, 2022, at 10:00 A.M., and to have with you at that
time and place the following:
SEE EXHIBIT “A” ATTACHED HERETO
These items will be inspected and may be copied at that
time. You will not be required to
HERON BAY CORPORATE CENTER - 5850. RITTERIDGE
R CHUSID, LLP, ATTORNEYS AT LAW
DRIVE, SUITE 201 * CORAL SPRINGS, FLORIDA 39076 « (954) 340-2200
« FAX (954) 340-2210
Sandra Parsley v. The Stainton Corp. CASE NO.: 21-001118-CA
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
Page 2
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 these copies upon
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
attorney whose name appears on this subpoena and thereby eliminate your appearance at the time
and place specified above. You have the right to object to the production pursuant to this subpoena
at any time before production by giving written notice to the attorney whose name appears on this
subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as
provided above; or (3) object to this subpoena, you may be in contempt of Court. You are
subpoenaed to appear by the following attorney, and unless excused from this subpoena by this
attorney or the Court, you shall respond to this subpoena as directed.
A copy of this subpoena has been furnished to all counsel of record, and specifically, the
attorney for the Plaintiff named herein.
DATED on April 18, 2022
BY /s/_ James Sposato
JAMES F. SPOSATO, ESQUIRE
Florida Bar No. 644171
For the Court pursuant to Fla.R.Civ.P.,
Rule 1.351 (c)
RITTER CHUSID, LLP, ATTORNEYS AT LAW
HERON BAY CORPORATE CENTER - 5850 CORAL RIDGE DRIVE, SUITE 201 * CORAL SPRINGS, FLORIDA 33076 + (954) 340-2200 + FAX (954) 340-2210
Sandra Parsley v. The Stainton Corp. CASE NO.: 21-001118-CA
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
Page 3
SEND DOCUMENTS TO:
Attorney for Defendant
Mitchel Chusid, Esquire
Florida Bar No. 879282
James F. Sposato, Esquire
Florida Bar No. 644171
Michael Rubin, Esquire
Florida Bar No.: 1027903
Ritter Chusid, LLP
5850 Coral Ridge Drive
Suite 201
Coral Springs, FL 33076
Telephone: (954) 340-2200
Please contact Janet Popova at jpopova@ritterchusid.com if you have any questions
regarding this subpoena. Thank you!
If you are a person with a disability who needs any accommodation in order to
participate in this proceeding, you are entitled, at no cost to you, to the provision of
certain assistance. Please contact the Administrative Services Manager, whose office
is located at 350 E. Marion Avenue, Punta Gorda, Florida 33950, and whose
telephone number is (941) 637-2281, within two working days of your receipt of this
subpoena; if you are hearing or voice impaired, call 711.
RITTER CHUSID, LLP, ATTORNEYS AT LAW
HERON BAY CORPORATE CENTER + 5850 CORAL RIDGE DRIVE, SUITE 201 « CORAL SPRINGS, FLORIDA 33076 + (954) 340-2200 « FAX (954) 340-2210
Sandra Parsley v. The Stainton Corp. CASE NO.: 21-001118-CA
SUBPOENA DUCES TECUM_ WITHOUT DEPOSITION
Page 4
EXHIBIT “A”
RE: Name of Patient: Sandra Parsley
Date of Birth:
You are hereby requested to provide copies of the following for any and all examinations and/or
treatment of the above-referenced patient:
1 Any and all prescription records, physician orders, medication refills, prescription summaries
print-outs;
Any and all insurance documents, including, but not limited to all applications, approvals,
employment records, insurance forms, claims records, providers information, billing
information, billing reports or correspondence, notes and memoranda;
All medical records regarding the medical or psychiatric treatment and care of the above
patient rendered by any health care provider, including, but not limited to: doctors, nurses,
therapists, social workers, or medical assistants, in your facility or by any other health care
provider records which are in your possession;
Any and all reports, opinions, evaluations, consultations, correspondence, memoranda,
telephone messages, or prescriptions regarding the above patient;
All patient information forms or questionnaires, sign-in sheets, or any other information
provided by the patient; including but not limited to histories of illness;
Any x-rays and other radiographic films and all written reports from x-rays, nerve conduction
studies, MRI’s, CT scans, or other diagnostic testing;
All emergency room records, notes, hospital records and all other data pertaining to
diagnosis, treatment and care of the above-named patient;
Any and all medical records or reports, including, but not limited to, testing, consultations
and reports of consultations and notes made by any physician, doctor, psychiatrist,
psychologist or counselors of their interview or counseling of the above-named patient;
Every written piece of paper included within the patient’s chart, including a copy of any
notations on the file jacket;
10. All billing records, lien information and all insurance forms, records, or correspondence;
RITTER CHUSID, LLP, ATTORNEYS AT LAW
HERON BAY CORPORATE CENTER + 5850 CORAL RIDGE DRIVE, SUITE 201 + CORAL SPRINGS, FLORIDA 33076 + (954) 340-2200 » FAX (954) 340-2210
Sandra Parsley v. The Stainton Corp. CASE NO.: 21-001118-CA
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
Page 5
11 All computer print-outs of all data stored and or available in your data base regarding the
above patient;
12. If not already encompassed above, your ENTIRE file, including, but not limited to: any
and all handwritten notes by the doctor or other medical personnel. This should
include records you have for any examination and/or treatment of the above named
individual and not limited to any particular visit. In short, you must produce each and
every piece of paper contained in any of your files regarding the patient, whether or not
prepared by you (i.e. including letters or records sent to you from another source).
Further, this includes telephone messages, letters from attorneys and letters from the
patient. In other words, please do not leave anything out for any reason. If you have
any questions, please contact us at (954) 340-2200. In the event that your records
egarding the above patient have been purged or destroyed, please forward a computer
print-out of all data stored and or available in your data base, along with written
confirmation that said records are no longer available.
NOTE:
A reasonable fee will be paid for the photocopying of said records. IF THE CHARGE FOR
PHOTOCOPYING WILL EXCEED FIFTY ($50.00) DOLLARS, PLEASE CONTACT OUR
OFFICE (954-340-2200) IN ADVANCE OF THE COPYING, FOR AUTHORIZATION OF THE
CHARGES. If it is necessary to have the fee in advance, or if the records cannot be gathered by the
appointed date, please call our office on or before the appointed date and arrangements will be made.
RITTER CHUSID, LLP, ATTORNEYS AT LAW
HERON BAY CORPORATE CENTER + 5850 CORAL RIDGE DRIVE, SUITE 201 + CORAL SPRINGS, FLORIDA 33076 + (954) 340-2200 + FAX (954) 340-2210
Preview
Filing # 148308798 E-Filed 04/25/2022 01:06:52 PM State of Florida County of Charlotte Circuit Court Case Number: 21-001118-CA Court Date: 5/2/2022 10:00 am Plaintiff: SANDRA PARSLEY, vs. Defendant: THE STAINTON CORPORATION d/b/a DEAN'S SOUTH OF THE BORDER, For: James E. S| RITTER CHUSID, LLP , Received by CAPLAN, CAPLAN & CAPLAN PROCESS SERVERS on the 19th day of April, 2022 at 4:09 pm to be served on Records Custodian Associates In Orthopedics, P.A. C/O Kelsey J. Veitengruber, Farr Law Firm, 99 NESBIT ST., PUNTA GORDA, FL 33950. |, Sally Susino, do hereby affirm that on the 21st day of April, 2022 at 11:55 am, I: served a CORPORATION, REGISTERED AGENT by delivering a true copy of the SUPOENA DUCES TECUM WITHOUT DEPOSITION (RECORDS PRODUCTION ONLY), and LETTER FROM ATTORNEY, EXHIBIT "A", CERTIFICATE OF COMPLETENESS with the date and hour of service endorsed thereon by me, to: KELSEY J. VEITENGRUBER as DIRECTOR/ REGISTERED AGENT at the address of: 99 NESBIT STREET, PUNTA GORDA, FL 33950 on behalf of Records Custodian Associates In Orthopedics, P.A. C/O Kelsey J. Veitengruber, Farr Law Firm, and informed said person of the contents therein, in compliance pursuant to Fed.R.Civ.P. A(h)(1) (b) Military Status: Based upon inquiry of party served, Defendant is not in the military service of the United States of Descripti of Person on Served: Age: 43, Sex: W, Race/Skin Color: WHITE, Height: 5'7, Weight: 170, Hair: BLONDE, Glasses: N RET URN OF SERVI S E CE for 21-001 CE 118-CA EEOC | certify that | am over the age of 18, have no interest in the above action, and am a Certified Process Server, in good standing, in the judicial circuit in which the process was se! red, Sally Susing 158080 Loe,A 7 aris CAPLAN, CAPLAN & CAPLAN PROCESS SERVERS 14160 Palmetto Frontage Road, Suite 105 Miami Lakes, FL 33016 (305) 374-3426 Our Job Serial Number: BLZ-2022000151 Ref: 12339 Copyright © 1992-2011 Database Services, inc. - Process Server's Toolbox V6.5» IN THE CIRCUIT COURT OF THE TWENTIETH JUDIC IAL CIRCUIT, IN AND FOR CHARLOTTE COUNTY, FLORIDA SANDRA PARSLEY, CASE NO.: 21-001118-CA. Plaintiff, vs. _Ve-eure_ lg THE STAINTON CORPORATION d/b/a 10 DEAN’S SOUTH OF THE BORDER, Ser, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION [Records May Be Mailed in Lieu of Appearance] THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN Associates in Orthopedics, P.A. c/o Kelsey J. Veitengruber Farr Law Firm 99 Nesbit Street Punta Gorda, FL 33950 Pursuant to the Health Insurance Portabil Notified that the attorney ity and Accountability Act of 1996 (HIPAA) for the referen iced patient and all parties to this action were , you are hereby fifteen days in which to object to this sub joena. No obj jec ni otified and given tioto servic nse of this by the patieni t's attorneyor by the p: atient him/herself. 45 C.F.R. §164. 512(e). subpoe! na have been filed service of this subpoena have been served u pon the under Fi ‘urther, no objections to Fla.R.Civ.P.(b), of service of the notice with attached subpo signed within ten (15) days, under Rule 1.351 ena given to all parties. Accordingly, YOU ARE COMMANDED to produce and permit inspection and copying of the follow ing documents or objects at the law offices of RITTER CHUSID, LLP,5850 Coral Ridge Drive, Suite 201, Coral Springs, Florida 33076, on May 2, 2022, at 10:00 A.M., and to have with you at that time and place the following: SEE EXHIBIT “A” ATTACHED HERETO These items will be inspected and may be copied at that time. You will not be required to HERON BAY CORPORATE CENTER - 5850. RITTERIDGE R CHUSID, LLP, ATTORNEYS AT LAW DRIVE, SUITE 201 * CORAL SPRINGS, FLORIDA 39076 « (954) 340-2200 « FAX (954) 340-2210 Sandra Parsley v. The Stainton Corp. CASE NO.: 21-001118-CA SUBPOENA DUCES TECUM WITHOUT DEPOSITION Page 2 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 these copies upon payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of Court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. A copy of this subpoena has been furnished to all counsel of record, and specifically, the attorney for the Plaintiff named herein. DATED on April 18, 2022 BY /s/_ James Sposato JAMES F. SPOSATO, ESQUIRE Florida Bar No. 644171 For the Court pursuant to Fla.R.Civ.P., Rule 1.351 (c) RITTER CHUSID, LLP, ATTORNEYS AT LAW HERON BAY CORPORATE CENTER - 5850 CORAL RIDGE DRIVE, SUITE 201 * CORAL SPRINGS, FLORIDA 33076 + (954) 340-2200 + FAX (954) 340-2210 Sandra Parsley v. The Stainton Corp. CASE NO.: 21-001118-CA SUBPOENA DUCES TECUM WITHOUT DEPOSITION Page 3 SEND DOCUMENTS TO: Attorney for Defendant Mitchel Chusid, Esquire Florida Bar No. 879282 James F. Sposato, Esquire Florida Bar No. 644171 Michael Rubin, Esquire Florida Bar No.: 1027903 Ritter Chusid, LLP 5850 Coral Ridge Drive Suite 201 Coral Springs, FL 33076 Telephone: (954) 340-2200 Please contact Janet Popova at jpopova@ritterchusid.com if you have any questions regarding this subpoena. Thank you! If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the Administrative Services Manager, whose office is located at 350 E. Marion Avenue, Punta Gorda, Florida 33950, and whose telephone number is (941) 637-2281, within two working days of your receipt of this subpoena; if you are hearing or voice impaired, call 711. RITTER CHUSID, LLP, ATTORNEYS AT LAW HERON BAY CORPORATE CENTER + 5850 CORAL RIDGE DRIVE, SUITE 201 « CORAL SPRINGS, FLORIDA 33076 + (954) 340-2200 « FAX (954) 340-2210 Sandra Parsley v. The Stainton Corp. CASE NO.: 21-001118-CA SUBPOENA DUCES TECUM_ WITHOUT DEPOSITION Page 4 EXHIBIT “A” RE: Name of Patient: Sandra Parsley Date of Birth: You are hereby requested to provide copies of the following for any and all examinations and/or treatment of the above-referenced patient: 1 Any and all prescription records, physician orders, medication refills, prescription summaries print-outs; Any and all insurance documents, including, but not limited to all applications, approvals, employment records, insurance forms, claims records, providers information, billing information, billing reports or correspondence, notes and memoranda; All medical records regarding the medical or psychiatric treatment and care of the above patient rendered by any health care provider, including, but not limited to: doctors, nurses, therapists, social workers, or medical assistants, in your facility or by any other health care provider records which are in your possession; Any and all reports, opinions, evaluations, consultations, correspondence, memoranda, telephone messages, or prescriptions regarding the above patient; All patient information forms or questionnaires, sign-in sheets, or any other information provided by the patient; including but not limited to histories of illness; Any x-rays and other radiographic films and all written reports from x-rays, nerve conduction studies, MRI’s, CT scans, or other diagnostic testing; All emergency room records, notes, hospital records and all other data pertaining to diagnosis, treatment and care of the above-named patient; Any and all medical records or reports, including, but not limited to, testing, consultations and reports of consultations and notes made by any physician, doctor, psychiatrist, psychologist or counselors of their interview or counseling of the above-named patient; Every written piece of paper included within the patient’s chart, including a copy of any notations on the file jacket; 10. All billing records, lien information and all insurance forms, records, or correspondence; RITTER CHUSID, LLP, ATTORNEYS AT LAW HERON BAY CORPORATE CENTER + 5850 CORAL RIDGE DRIVE, SUITE 201 + CORAL SPRINGS, FLORIDA 33076 + (954) 340-2200 » FAX (954) 340-2210 Sandra Parsley v. The Stainton Corp. CASE NO.: 21-001118-CA SUBPOENA DUCES TECUM WITHOUT DEPOSITION Page 5 11 All computer print-outs of all data stored and or available in your data base regarding the above patient; 12. If not already encompassed above, your ENTIRE file, including, but not limited to: any and all handwritten notes by the doctor or other medical personnel. This should include records you have for any examination and/or treatment of the above named individual and not limited to any particular visit. In short, you must produce each and every piece of paper contained in any of your files regarding the patient, whether or not prepared by you (i.e. including letters or records sent to you from another source). Further, this includes telephone messages, letters from attorneys and letters from the patient. In other words, please do not leave anything out for any reason. If you have any questions, please contact us at (954) 340-2200. In the event that your records egarding the above patient have been purged or destroyed, please forward a computer print-out of all data stored and or available in your data base, along with written confirmation that said records are no longer available. NOTE: A reasonable fee will be paid for the photocopying of said records. IF THE CHARGE FOR PHOTOCOPYING WILL EXCEED FIFTY ($50.00) DOLLARS, PLEASE CONTACT OUR OFFICE (954-340-2200) IN ADVANCE OF THE COPYING, FOR AUTHORIZATION OF THE CHARGES. If it is necessary to have the fee in advance, or if the records cannot be gathered by the appointed date, please call our office on or before the appointed date and arrangements will be made. RITTER CHUSID, LLP, ATTORNEYS AT LAW HERON BAY CORPORATE CENTER + 5850 CORAL RIDGE DRIVE, SUITE 201 + CORAL SPRINGS, FLORIDA 33076 + (954) 340-2200 + FAX (954) 340-2210