Preview
Filing # 167600554 E-Filed 02/27/2023 12:46:43 PM
CLAIM NO.: 046727328-0007
ORDER #: FL0181085-001
TOTAL PAGES: 2
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT
IN AND FOR DUVAL COUNTY,
FLORIDA
KEVIN FRANKLIN,
CASE NO. 162022CA006098
Plaintiff(s),
vs.
SAFECO INSURANCE COMPANY OF
ILLINOIS,
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:
Medical Records Custodian for
COASTAL INJURY CLINIC
2700 RIVERSIDE AVENUE, SUITE 1-B
JACKSONVILLE, FL 32205
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.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/27/2023 04:35:08 PM
CLAIM NO.: 046727328-0007
ORDER #: FL0181085-001
TOTAL PAGES: 2
I HEREBY CERTIFY that on the _27th.___ day of ___February____, 2023 a true and correct copy
of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been
furnished by email to:
BRANDI GARTRELL, ESQ.
MORGAN & MORGAN, P.A.
501 RIVERSIDE AVENUE, SUITE 1200
JACKSONVILLE, FL 32202
BGARTRELL@FORTHEPEOPLE.COM
LAW OFFICES OF J. CHRISTOPHER NORRIS
P.O. BOX 7217
LONDON, KY 40742
Telephone: 407-563-3416
Fax: 855-318-5922
By:
JORDAN BROUGHER, ESQ.
FL BAR NO.: 1036574
PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS:
ORLANDOLEGALMAIL@LIBERTYMUTUAL.COM
JORDAN.BROUGHER@LIBERTYMUTUAL.COM
Attorney for Defendant(s)
SAFECO INSURANCE COMPANY OF ILLINOIS
CLAIM NO.: 046727328-0007
ORDER #: FL0181085
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE FOURTH
JUDICIAL CIRCUIT
IN AND FOR DUVAL COUNTY,
FLORIDA
KEVIN FRANKLIN,
CASE NO. 162022CA006098
Plaintiff(s),
vs.
SAFECO INSURANCE COMPANY OF
ILLINOIS,
Defendant(s),
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
COASTAL INJURY CLINIC
2700 RIVERSIDE AVENUE, SUITE 1-B
JACKSONVILLE, FL 32205
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:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD
INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS,
PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL
OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND
OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY
RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION
RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS
OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND
TIME OF PATIENT'S APPOINTMENTS, INSURANCE DOCUMENTS, ALL
RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS
MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF
THE PATIENT; AND
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
Page 1 of 3
CLAIM NO.: 046727328-0007
ORDER #: FL0181085
TOTAL PAGES: 3
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY
AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF
BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE
BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS
AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION; AND
COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER
SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT
SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. KEVIN
FRANKLIN ; DOB:
IF COPY CHARGES EXCEED $ 5 0 0 . 0 0 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.
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 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.
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 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.: 046727328-0007
ORDER #: FL0181085
TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. I 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;
2. 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
3. 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.
Objection was filed but per agreement of counsel, objection has been resolved.
JORDAN BROUGHER, ESQ. Dated:
Attorney for Defendant(s)
Safeco insurance company of Illinois
FL Bar No. 1036574
LAW OFFICES OF J. CHRISTOPHER NORRIS
P.O. BOX 7217 By:
LONDON, KY 40742 For the Court
Telephone: 407-648-0123
Page 3 of 3
Preview
Filing # 167600554 E-Filed 02/27/2023 12:46:43 PM CLAIM NO.: 046727328-0007 ORDER #: FL0181085-001 TOTAL PAGES: 2 IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA KEVIN FRANKLIN, CASE NO. 162022CA006098 Plaintiff(s), vs. SAFECO INSURANCE COMPANY OF ILLINOIS, 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: Medical Records Custodian for COASTAL INJURY CLINIC 2700 RIVERSIDE AVENUE, SUITE 1-B JACKSONVILLE, FL 32205 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. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/27/2023 04:35:08 PM CLAIM NO.: 046727328-0007 ORDER #: FL0181085-001 TOTAL PAGES: 2 I HEREBY CERTIFY that on the _27th.___ day of ___February____, 2023 a true and correct copy of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been furnished by email to: BRANDI GARTRELL, ESQ. MORGAN & MORGAN, P.A. 501 RIVERSIDE AVENUE, SUITE 1200 JACKSONVILLE, FL 32202 BGARTRELL@FORTHEPEOPLE.COM LAW OFFICES OF J. CHRISTOPHER NORRIS P.O. BOX 7217 LONDON, KY 40742 Telephone: 407-563-3416 Fax: 855-318-5922 By: JORDAN BROUGHER, ESQ. FL BAR NO.: 1036574 PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS: ORLANDOLEGALMAIL@LIBERTYMUTUAL.COM JORDAN.BROUGHER@LIBERTYMUTUAL.COM Attorney for Defendant(s) SAFECO INSURANCE COMPANY OF ILLINOIS CLAIM NO.: 046727328-0007 ORDER #: FL0181085 TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA KEVIN FRANKLIN, CASE NO. 162022CA006098 Plaintiff(s), vs. SAFECO INSURANCE COMPANY OF ILLINOIS, Defendant(s), SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR COASTAL INJURY CLINIC 2700 RIVERSIDE AVENUE, SUITE 1-B JACKSONVILLE, FL 32205 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: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS, PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS, INSURANCE DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT; AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR Page 1 of 3 CLAIM NO.: 046727328-0007 ORDER #: FL0181085 TOTAL PAGES: 3 CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; AND COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. KEVIN FRANKLIN ; DOB: IF COPY CHARGES EXCEED $ 5 0 0 . 0 0 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. 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 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. 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 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.: 046727328-0007 ORDER #: FL0181085 TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. I 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; 2. 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 3. 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. Objection was filed but per agreement of counsel, objection has been resolved. JORDAN BROUGHER, ESQ. Dated: Attorney for Defendant(s) Safeco insurance company of Illinois FL Bar No. 1036574 LAW OFFICES OF J. CHRISTOPHER NORRIS P.O. BOX 7217 By: LONDON, KY 40742 For the Court Telephone: 407-648-0123 Page 3 of 3