Preview
Filing # 142857833 E-Filed 01/28/2022 12:08:45 PM
Chaim wu. s79uZ0-0r
ORDER#: FL0164404
TOTAL PAGES: 2
IN THE CIRCUIT COURT OF THE FOURTH
JUDICIAL CIRCUIT
IN AND FOR DUVAL COUNTY,
FLORIDA
JOHN VALIS
CASE NO. 2020-CA-002067
Plaintifi(s),
vs.
CHRISTINE HITCHCOCK
Defendant(s),
DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS
FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
Notice, service is by email, and if no objection is received from any party, the undersigned will
issue or apply to the Clerk of this court for the issuance of the attached Subpoena(s) directed to
the following:
Insurance Records Custodian for
GEICO GENERAL INSURANCE COMPANY
200 EAST GAINES STREET
TALLAHASSEE, FL 32399
The above listed are not a party to this lawsuit and are requested to produce the items listed at
the time and place specified in the attached Subpoena(s).
If you wish to receive copies of these documents, please advise the undersigned, in writing,
and same will be provided, at a cost for photocopies, upon receipt.
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES
INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES.
PLEASE BE GOVERNED ACCORDINGLY.
Page 1 of 2
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/28/2022 01:51:19 PM
CLAIM NO.: 793028-GF
ORDER #: FL0164404
TOTAL PAGES: 2
THEREBY CERTIFY that on the 28" day of January » 20 22 a true and correct copy
of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been
furnished by email to:
KATHLEEN CARLSON
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
200 WEST FORSYTH STREET, SUITE 1400
JACKSONVILLE, FL 32202
MICHAEL D. MARRESE, ESQ.
MORGAN & MORGAN, P.A.
2601 N. PONCE DE LEON BOULEVARD
SAINT AUGUSTINE, FL 32084
MMARRESE@FORTHEPEOPLE.COM
LAW OFFICE OF SONYA S. WESNER
200 EAST ROBINSON DRIVE, SUITE
510 ORLANDO, FL 32801
Telephone: 407-393-9100
Fax: 407-418-5550
By:
PAUL M. EZA, ESQ.
FL BAR NO. 68708
PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS
JAXSMAIL@NATIONWIDE.COM
Attorney for Defendant(s)
CHRISTINE HITCHCOCK
Page 2 of 2
CLAIM NO.: 793028-GF
ORDER #: FLO164404
TOTAL PAGES: 2
IN THE CIRCUIT COURT OF THE FOURTH
JUDICIAL CIRCUIT
IN AND FOR DUVAL COUNTY,
FLORIDA
JOHN VALIS
Plaintiff(s),
CASE NO. 2020-CA-002067
vs.
CHRISTINE HITCHCOCK
Defendant(s),
|
CERTIFICATE OF NON OBJECTION TO SUBPOENA(S)
I HEREBY CERTIFY that no objections to production under Rule 1.351, Florida Rules of
Civil Procedure, have been received by the undersigned with ten (10) days of service by email of the
Notice of Production from Non-Party, a copy of which is attached.
IHEREBY CERTIFY that on the day of »20 a true and
correct copy of the foregoing Certificate of Non Objection to Subpoena(s) has been furnished by
email to:
Page 1 of 2
CLAIM NO.: 793028-GF
ORDER #: FL0164404
TOTAL PAGES: 2
KATHLEEN CARLSON
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
200 WEST FORSYTH STREET, SUITE 1400
JACKSONVILLE, FL 32202
MICHAEL D. MARRESE, ESQ.
MORGAN & MORGAN, P.A.
2601 N. PONCE DE LEON BOULEVARD
SAINT AUGUSTINE, FL 32084
MMARRESE@FORTHEPEOPLE.COM
LAW OFFICE OF SONYA S. WESNER
200 EAST ROBINSON DRIVE, SUITE 510
ORLANDO, FL 32801
Telephone: 407-393-9100
Fax: 407-418-5550
By:
PAUL M. EZA, ESQ.
FL BAR NO. 68708
PRINCIPLE EMAIL FOR SERVICE OF PLEADINGS
JAXSMAIL@NATIONWIDE.COM
Attorney for Defendant(s)
CHRISTINE HITCHCOCK
Page 2 of 2
CLAIM NO.: 793028-GF
ORDER #: FL0164404-029
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE FOURTH
JUDICIAL CIRCUIT
IN AND FOR DUVAL COUNTY,
FLORIDA
JOHN VALIS
CASE NO. 2020-CA-002067
Plaintiff(s),
vs.
CHRISTINE HITCHCOCK
Defendant(s),
|
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
GEICO GENERAL INSURANCE COMPANY 866-729-5201
200 EAST GAINES STREET
TALLAHASSEE, FL 32399
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
ANY AND ALL INSURANCE RECORDS STORED IN ANY FORMAT, INCLUDING BUT
NOT LIMITED TO CORRESPONDENCE, PAYMENTS, PAYMENT HISTORY, POLICY
INFORMATION, DECLARATIONS PAGE, COMPLETE CLAIM FILES, RECORDS OF
ANY LIENS, COLOR PHOTOS, AND DAMAGE REPAIR ESTIMATES, INJURY
RECORDS OR CLAIM AND ANY OTHER DOCUMENTS CONTAINED WITHIN ANY
INSURANCE FILE AND/OR CLAIM FILE.
REGARDING 8/25/16 ACCIDENT
CLAIM NUMBER 0116698750101158 JOHN VALIS ; DOB: SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
Page 1 of 3
CLAIM NO.: 793028-GF
ORDER #: FL0164404-029
TOTAL PAGES: 3
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
opies of the items to be produced to COMPEX LEGAL SERVICES, INC., the agent of
the attorney whose name appears on this subpoena, on or before the scheduled date of
production. "The records requested will be used for this litigation only and will be
returned or destroyed after litigation is complete." Please contact Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC.
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3
CLAIM NO.: 793028-GF
ORDER #: FL0164404-029
TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
| have made a good faith attempt to provide written notice to the above-named patient,
through counsel, of intent to obtain the patient's health information pursuant to this
subpoena;
The written notice provided sufficient information about this litigation or proceeding in which
the protected health information is requested to permit the patient to raise an objection to
the court or administrative tribunal; and
The time of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
tribunal and the disclosures being sought are consistent with such resolutions.
PAUL M. EZA, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 68708 ce
LAW OFFICE OF SONYA S. WESNER
200 EAST ROBINSON DRIVE, SUITE 510 By:
ORLANDO, FL 32801 For the Court
Telephone: 407-393-9100
Page 3 of 3
Preview
Filing # 142857833 E-Filed 01/28/2022 12:08:45 PM Chaim wu. s79uZ0-0r ORDER#: FL0164404 TOTAL PAGES: 2 IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA JOHN VALIS CASE NO. 2020-CA-002067 Plaintifi(s), vs. CHRISTINE HITCHCOCK Defendant(s), DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS FROM NON-PARTY YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this Notice, service is by email, and if no objection is received from any party, the undersigned will issue or apply to the Clerk of this court for the issuance of the attached Subpoena(s) directed to the following: Insurance Records Custodian for GEICO GENERAL INSURANCE COMPANY 200 EAST GAINES STREET TALLAHASSEE, FL 32399 The above listed are not a party to this lawsuit and are requested to produce the items listed at the time and place specified in the attached Subpoena(s). If you wish to receive copies of these documents, please advise the undersigned, in writing, and same will be provided, at a cost for photocopies, upon receipt. IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. PLEASE BE GOVERNED ACCORDINGLY. Page 1 of 2 ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/28/2022 01:51:19 PM CLAIM NO.: 793028-GF ORDER #: FL0164404 TOTAL PAGES: 2 THEREBY CERTIFY that on the 28" day of January » 20 22 a true and correct copy of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been furnished by email to: KATHLEEN CARLSON MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 200 WEST FORSYTH STREET, SUITE 1400 JACKSONVILLE, FL 32202 MICHAEL D. MARRESE, ESQ. MORGAN & MORGAN, P.A. 2601 N. PONCE DE LEON BOULEVARD SAINT AUGUSTINE, FL 32084 MMARRESE@FORTHEPEOPLE.COM LAW OFFICE OF SONYA S. WESNER 200 EAST ROBINSON DRIVE, SUITE 510 ORLANDO, FL 32801 Telephone: 407-393-9100 Fax: 407-418-5550 By: PAUL M. EZA, ESQ. FL BAR NO. 68708 PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS JAXSMAIL@NATIONWIDE.COM Attorney for Defendant(s) CHRISTINE HITCHCOCK Page 2 of 2 CLAIM NO.: 793028-GF ORDER #: FLO164404 TOTAL PAGES: 2 IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA JOHN VALIS Plaintiff(s), CASE NO. 2020-CA-002067 vs. CHRISTINE HITCHCOCK Defendant(s), | CERTIFICATE OF NON OBJECTION TO SUBPOENA(S) I HEREBY CERTIFY that no objections to production under Rule 1.351, Florida Rules of Civil Procedure, have been received by the undersigned with ten (10) days of service by email of the Notice of Production from Non-Party, a copy of which is attached. IHEREBY CERTIFY that on the day of »20 a true and correct copy of the foregoing Certificate of Non Objection to Subpoena(s) has been furnished by email to: Page 1 of 2 CLAIM NO.: 793028-GF ORDER #: FL0164404 TOTAL PAGES: 2 KATHLEEN CARLSON MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 200 WEST FORSYTH STREET, SUITE 1400 JACKSONVILLE, FL 32202 MICHAEL D. MARRESE, ESQ. MORGAN & MORGAN, P.A. 2601 N. PONCE DE LEON BOULEVARD SAINT AUGUSTINE, FL 32084 MMARRESE@FORTHEPEOPLE.COM LAW OFFICE OF SONYA S. WESNER 200 EAST ROBINSON DRIVE, SUITE 510 ORLANDO, FL 32801 Telephone: 407-393-9100 Fax: 407-418-5550 By: PAUL M. EZA, ESQ. FL BAR NO. 68708 PRINCIPLE EMAIL FOR SERVICE OF PLEADINGS JAXSMAIL@NATIONWIDE.COM Attorney for Defendant(s) CHRISTINE HITCHCOCK Page 2 of 2 CLAIM NO.: 793028-GF ORDER #: FL0164404-029 TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA JOHN VALIS CASE NO. 2020-CA-002067 Plaintiff(s), vs. CHRISTINE HITCHCOCK Defendant(s), | SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR GEICO GENERAL INSURANCE COMPANY 866-729-5201 200 EAST GAINES STREET TALLAHASSEE, FL 32399 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ANY AND ALL INSURANCE RECORDS STORED IN ANY FORMAT, INCLUDING BUT NOT LIMITED TO CORRESPONDENCE, PAYMENTS, PAYMENT HISTORY, POLICY INFORMATION, DECLARATIONS PAGE, COMPLETE CLAIM FILES, RECORDS OF ANY LIENS, COLOR PHOTOS, AND DAMAGE REPAIR ESTIMATES, INJURY RECORDS OR CLAIM AND ANY OTHER DOCUMENTS CONTAINED WITHIN ANY INSURANCE FILE AND/OR CLAIM FILE. REGARDING 8/25/16 ACCIDENT CLAIM NUMBER 0116698750101158 JOHN VALIS ; DOB: SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. Page 1 of 3 CLAIM NO.: 793028-GF ORDER #: FL0164404-029 TOTAL PAGES: 3 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 opies of the items to be produced to COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears on this subpoena, on or before the scheduled date of production. "The records requested will be used for this litigation only and will be returned or destroyed after litigation is complete." Please contact Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC. 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3 CLAIM NO.: 793028-GF ORDER #: FL0164404-029 TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: | have made a good faith attempt to provide written notice to the above-named patient, through counsel, of intent to obtain the patient's health information pursuant to this subpoena; The written notice provided sufficient information about this litigation or proceeding in which the protected health information is requested to permit the patient to raise an objection to the court or administrative tribunal; and The time of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative tribunal and the disclosures being sought are consistent with such resolutions. PAUL M. EZA, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 68708 ce LAW OFFICE OF SONYA S. WESNER 200 EAST ROBINSON DRIVE, SUITE 510 By: ORLANDO, FL 32801 For the Court Telephone: 407-393-9100 Page 3 of 3