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Filing # 171530021 E-Filed 04/21/2023 01:17:42 PM
0124157 IN THE CIRCUIT COURT FOR THE
TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY,
FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.:21000968CA
Plaintiff,
V.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
/
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days of service of this Notice of
Production from Non-Party, the undersigned will apply to the Clerk of the Court for issuance of
the attached Subpoenas directed to:
ShorePoint Health Port Charlotte
ShorePoint Health Punta Gorda
Bayfront Health Punta Gorda
Ortho Specialists of SW Florida
Mr. Connect
Anesthesia & Pain Consultants of Southwest Florida, M.D., P.A.
American Imaging
Pulmonary Associates of Charlotte County
who are not a party to this action, to produce the items listed at the time and place
specified in the Subpoenas.
CERTIFICATE _OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregomg was e-mailed to all
counsel of the attached Service List this 21st day of April, 2023.
KUBICKI DRAPER
9100 South Dadeland Blvd.
Suite 1800
Miami, FL 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
Pleadings: FIC-KD@kubickidraper.com
By:_/s/ Francesca Ippolito-Crave
FRANCESCA IPPOLITO-CRAVEN
fic@kubickidraper.com
Florida Bar Number: 0145361
LISANDRA GUERRERO
Ig@kubickidraper.com
Florida Bar Number: 0098521
SERVICE LIST
Co-counsel for Plaintiff:
Michael J. Rossi, Esq.
MICHAEL J. ROSSI, P.A.
115 South Albany Avenue
Tampa, FL 33606
michael@ michaelrossilaw.com
Helen Stratigakos, Esq.
STRATIGAKOS LAW, P.A.
412 East Madison Street, Suite 814
Tampa, FL 33602
helen@stratigakoslaw.com
marty@stratigakoslaw.com
IN THE CIRCUIT COURT FOR THE
WENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY,
FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 21000968CA
Plaintiff,
V.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
/
SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS
AND THINGS WITHOUT _DEPOSITIONS
TO: Records Custodian (Medical, Billing, and Radiology)
American Imaging
23081 Harborview Rd
Port Charlotte, FL 33980
Ph: 941-235-8762
YOU ARE HEREBY COMMANDED to produce without deposition and deliver to
Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite
1800, Miami, Florida 33156, on May 22, 2023, copies of the following:
As to Plaintiff: Barbara Gonzalez; _D.O.B: Bag SS#: xxx-xx-y
YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but
not limited to any and all documents set forth below. All_medical, billing & radiology
records requested FILE_are_all-inclusive_and_ should _be_in_no_way limited to_one_date_of
incident.
MEDICAL:
a. office records and notes;
b. doctors and nurses notes;
Cc insurance records and claim forms;
d letters of protection, personal injury agreements or any contract and/or agreement you
have with Plamtiff and/or his/her attorney;
consent forms;
medical records with respect to any and all injuries or illnesses;
medical history forms;
intake forms;
consultations;
correspondence;
charts;
memoranda;
narrative reports;
treatment;
patient questionnaires;
progress notes;
computer generated reports and printouts;
laboratory reports;
radiology reports;
therapy notes;
prescriptions;
any hospital and/or emergency room records;
reports of diagnostic and surgical procedures;
any and all data pertaining to the diagnosis, treatment and care of the patient; and
any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of
plaintiff taken before and/or after plamntiffs mjury.
BILLING:
a. Assignment of Benefits forms;
“Signature on File” forms;
Doctor’s liens;
Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim
forms;
Superbills;
Statements of account;
Correspondence;
Memoranda;
Invoices;
Ledgers;
Computerized billing; and
Letters of Protection, Personal Injury Agreements or any contract and/or agreement you
have with Plaintiff and/or his/her attorney;
m. Itemized Bills
RADIOLOGY:
a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.);
b. Written & computer generated reports.
¢. Intake Sheets and other diagnostic tests, together with reports of the results
Before copying, please fax a detailed list of your complete inventory of films on this
patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the
dates taken and the costs involved in obtaining these copies. We would prefer to
obtain _all films _on disc.
All records requested are all-inclusive and should be in no way limited to one date of
incident. The records should include any notations on the file jacket as well and any and
all reports _or correspondence of other physicians or hospitals included in your file, as well
as all correspondence or any other record of any kind of nature that you have in your
possession regarding the treatment of the above-named person from the first date of
treatment to the present.
You have the right to make a legal objection to the production of these materials under
Rule 1.351 of the Florida Rules of Civil Procedure.
If you fail to comply, you may be held in contempt of Court.
You may request reasonable costs for preparing these documents in advance by making
written request within five (5) days.
A copy of this Subpoena has been furnished to all counsel of record. Also, please
complete, sign, and notarize the attached affidavit.
COMPLIANCE WITH HIPAA DISCLOSURE
Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the
Florida Rules of Civil Procedure. Undersigned certifies that:
1) Written notice has been provided to the insurance and/or the individual’s attorney for
whom the documents are sought,
2) The notice included sufficient information about the litigation and/or proceeding to
permit the individual or his/her attorney to raise an objection to the production of the requested
documents,
3) The time to raise an objection has elapsed and,
4) Neither the individual nor his/her attorney filed an objection to the above-listed
subpoena.
WITNESS my hand and seal on May 2, 2023.
FRANCESCA A. IPPOLITO-CRAVEN
For the Court
4s/ Francesca Ippolito-Craven
Florida Bar Number 0145361
Francesca Ippolito-Craven, Esquire
KUBICKI DRAPER
9100 S. Dadeland Blvd.
Suite 1800
Miami, Florida 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
FIC-KD@kubickidraper.com
*Issued by attorney of record per Rule 1.410
If you are a person with a disability who needs any accommodation in order to
respond to this subpoena, you are entitled, at no cost to you, to the provision of
certain a! tance. Please contact FRANCESCA IPPOLITO-CRAVEN of
Kubicki aper at (305) 982-6737 at least 7 days before your scheduled
appearance, or immediately upon receiving this notification if the time before
the scheduled appearance is less than 7 days; if you are hearing or voice
impaired, call 711.
For questions regarding this Subpoena
Please contact Nicole Almeida (305) 982-6754
FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF
RECORDS CUSTODIAN
In accordance with Federal Rule of Evidence 902 Self-Authentication, I
» Custodian of Records, do hereby produce the attached records of
Barbara Gonzalez; DOB: Sg and do hereby certify that such records:
a) Were made at or near the time of the occurrence of the matters set forth by, or from
information transmitted by a person or persons with knowledge of the matters,
acting within the course of the regularly conducted business activity;
b) Were kept in the course of the regularly conducted business activity;
9) Were made as a regular practice in the course of the regularly conducted activity;
qd) And are true and accurate copies of the original records.
I have read every statement made in this certification, and each statement is true and
correct. I understand that falsely making such a certification or declaration would subject
me to criminal penalty under the laws of the foreign or domestic location in which the
certification or declaration was signed.
Records Custodian’s Signature Date
Sworn to or affirmed and signed before me on this day of
2022.
Notary Public
My commission expires:
IN THE CIRCUIT COURT FOR THE
WENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY,
FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 21000968CA
Plaintiff,
V.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
/
SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS
AND THINGS WITHOUT _DEPOSITIONS
TO: Records Custodian (Medical, Billing, and Radiology)
Anesthesia & Pain Consultants of Southwest Florida, MD, PA
12511 World Plaza Lane, Bldg 50
Ft. Myers, FL 33907
YOU ARE HEREBY COMMANDED to produce without deposition and deliver to
Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite
1800, Miami, Florida 33156, on May 22, 2023, copies of the following:
As to Plaintiff: Barbara Gonzalez; D.O.B: By SS#: xxx-xx-y
YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but
not limited to any and all documents set forth below. All_medical, billing & radiology
records requested FILE are all-inclusive and should be in no way limited to one date of
incident.
MEDICAL:
a. office records and notes;
b, doctors and nurses notes;
Cc insurance records and claim forms;
d letters of protection, personal injury agreements or any contract and/or agreement you
have with Plamtiff and/or his/her attorney;
consent forms;
medical records with respect to any and all injuries or illnesses;
medical history forms;
intake forms;
consultations;
correspondence;
charts;
memoranda;
narrative reports;
treatment;
patient questionnaires;
progress notes;
computer generated reports and printouts;
laboratory reports;
radiology reports;
therapy notes;
prescriptions;
any hospital and/or emergency room records;
reports of diagnostic and surgical procedures;
any and all data pertaining to the diagnosis, treatment and care of the patient; and
any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of
plaintiff taken before and/or after plamntiffs mjury.
BILLING:
a. Assignment of Benefits forms;
“Signature on File” forms;
Doctor’s liens;
Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim
forms;
Superbills;
Statements of account;
Correspondence;
Memoranda;
Invoices;
Ledgers;
Computerized billing; and
Letters of Protection, Personal Injury Agreements or any contract and/or agreement you
have with Plamtiff and/or his/her attorney;
m. Itemized Bills
RADIOLOGY:
a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.);
b. Written & computer generated reports.
C. Intake Sheets and other diagnostic tests, together with reports of the results
Before copying, please fax _a detailed list of your complete inventory of films _on this
patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the
dates taken and the costs involved in obtaining these copies. We would prefer to
obtain _all films _on disc.
All records requested are all-inclusive and should be in no way limited to one date of
incident. The records should include any notations on the file jacket as well and any and
all reports _or correspondence of other physicians or hospitals included in your file, as well
as all correspondence or any other record of any kind of nature that you have in your
possession regarding the treatment of the above-named person from the first date of
treatment to the present.
You have the right to make a legal objection to the production of these materials under
Rule 1.351 of the Florida Rules of Civil Procedure.
If you fail to comply, you may be held in contempt of Court.
You may request reasonable costs for preparing these documents in advance by making
written request within five (5) days.
A copy of this Subpoena has been furnished to all counsel of record. Also, please
complete, sign, and notarize the attached affidavit.
COMPLIANCE WITH HIPAA DISCLOSURE
Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the
Florida Rules of Civil Procedure. Undersigned certifies that:
1) Written notice has been provided to the insurance and/or the individual’s attorney for
whom the documents are sought,
2) The notice included sufficient information about the litigation and/or proceeding to
permit the individual or his/her attorney to raise an objection to the production of the requested
documents,
3) The time to raise an objection has elapsed and,
4) Neither the individual nor his/her attorney filed an objection to the above-listed
subpoena.
WITNESS my hand and seal on May 2, 2023.
FRANCESCA A. IPPOLITO-CRAVEN
For the Court
4s/ Francesca Ippolito-Craven
Florida Bar Number 0145361
Francesca Ippolito-Craven, Esquire
KUBICKI DRAPER
9100 S. Dadeland Blvd.
Suite 1800
Miami, Florida 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
FIC-KD@kubickidraper.com
*Issued by attorney of record per Rule 1.410
If you are a person with a disability who needs any accommodation in order to
respond to this subpoena, you are entitled, at no cost to you, to the provision of
certain a tance. Please contact FRANCESCA IPPOLITO-CRAVEN of
Kubicki aper at (305) 982-6737 at least 7 days before your scheduled
appearance, or immediately upon receiving this notification if the time before
the scheduled appearance is less than 7 days; if you are hearing or voice
impaired, call 711.
For questions regarding this Subpoena
Please contact Nicole Almeida (305) 982-6754
FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF
RECORDS CUSTODIAN
In accordance with Federal Rule of Evidence 902 Self-Authentication, I
» Custodian of Records, do hereby produce the attached records of
Barbara Gonzalez; DOB: Sg and do hereby certify that such records:
a) Were made at or near the time of the occurrence of the matters set forth by, or from
information transmitted by a person or persons with knowledge of the matters,
acting within the course of the regularly conducted business activity;
b) Were kept in the course of the regularly conducted business activity;
9) Were made as a regular practice in the course of the regularly conducted activity;
qd) And are true and accurate copies of the original records.
I have read every statement made in this certification, and each statement is true and
correct. I understand that falsely making such a certification or declaration would subject
me to criminal penalty under the laws of the foreign or domestic location in which the
certification or declaration was signed.
Records Custodian’s Signature Date
Sworn to or affirmed and signed before me on this day of
2022.
Notary Public
My commission expires:
IN THE CIRCUIT COURT FOR THE
WENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY,
FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 21000968CA
Plaintiff,
V.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
/
SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS
AND THINGS WITHOUT _DEPOSITIONS
TO: Records Custodian (Medical, Billing, and Radiology)
Bayfront Health Punta Gorda
Attn: Bayfront Health Medical Records Department
701 6th Street S.
St. Petersburg, FL 32701
YOU ARE HEREBY COMMANDED to produce without deposition and deliver to
Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite
1800, Miami, Florida 33156, on May 22, 2023, copies of the following:
As to Plaintiff: Barbara Gonzalez; D.O.B: Bag SS#: xxx-xx-y
YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but
not limited to any and all documents set forth below. All_medical, billing & radiology
records requested FILE_are_all-inclusive_and_ should _be_in_no_way limited to_one_date_of
incident.
MEDICAL:
a. office records and notes;
b. doctors and nurses notes;
Cc insurance records and claim forms;
d letters of protection, personal injury agreements or any contract and/or agreement you
have with Plamtiff and/or his/her attorney;
consent forms;
medical records with respect to any and all injuries or illnesses;
medical history forms;
intake forms;
consultations;
correspondence;
charts;
memoranda;
narrative reports;
treatment;
patient questionnaires;
progress notes;
computer generated reports and printouts;
laboratory reports;
radiology reports;
therapy notes;
prescriptions;
any hospital and/or emergency room records;
reports of diagnostic and surgical procedures;
any and all data pertaining to the diagnosis, treatment and care of the patient; and
any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of
plaintiff taken before and/or after plamntiffs mjury.
BILLING:
a. Assignment of Benefits forms;
“Signature on File” forms;
Doctor’s liens;
Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim
forms;
Superbills;
Statements of account;
Correspondence;
Memoranda;
Invoices;
Ledgers;
Computerized billing; and
Letters of Protection, Personal Injury Agreements or any contract and/or agreement you
have with Plaintiff and/or his/her attorney;
m. Itemized Bills
RADIOLOGY:
a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.);
b. Written & computer generated reports.
¢. Intake Sheets and other diagnostic tests, together with reports of the results
Before copying, please fax a detailed list of your complete inventory of films on this
patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the
dates taken and the costs involved in obtaining these copies. We would prefer to
obtain _all films _on disc.
All records requested are all-inclusive and should be in no way limited to one date of
incident. The records should include any notations on the file jacket as well and any and
all reports _or correspondence of other physicians or hospitals included in your file, as well
as all correspondence or any other record of any kind of nature that you have in your
possession regarding the treatment of the above-named person from the first date of
treatment to the present.
You have the right to make a legal objection to the production of these materials under
Rule 1.351 of the Florida Rules of Civil Procedure.
If you fail to comply, you may be held in contempt of Court.
You may request reasonable costs for preparing these documents in advance by making
written request within five (5) days.
A copy of this Subpoena has been furnished to all counsel of record. Also, please
complete, sign, and notarize the attached affidavit.
COMPLIANCE WITH HIPAA DISCLOSURE
Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the
Florida Rules of Civil Procedure. Undersigned certifies that:
1) Written notice has been provided to the insurance and/or the individual’s attorney for
whom the documents are sought,
2) The notice included sufficient information about the litigation and/or proceeding to
permit the individual or his/her attorney to raise an objection to the production of the requested
documents,
3) The time to raise an objection has elapsed and,
4) Neither the individual nor his/her attorney filed an objection to the above-listed
subpoena.
WITNESS my hand and seal on May 2, 2023.
FRANCESCA A. IPPOLITO-CRAVEN
For the Court
4s/ Francesca Ippolito-Craven
Florida Bar Number 0145361
Francesca Ippolito-Craven, Esquire
KUBICKI DRAPER
9100 S. Dadeland Blvd.
Suite 1800
Miami, Florida 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
FIC-KD@kubickidraper.com
*Issued by attorney of record per Rule 1.410
If you are a person with a disability who needs any accommodation in order to
respond to thi subpoena, you are entitled, at no cost to you, to the provision of
certain a! tance. Please contact FRANCESCA IPPOLITO-CRAVEN of
Kubicki aper at (305) 982-6737 at least 7 days before your scheduled
appearance, or immediately upon receiving this notification if the time before
the scheduled appearance is less than 7 days; if you are hearing or voice
impaired, call 711.
For questions regarding this Subpoena
Please contact Nicole Almeida (305) 982-6754
FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF
RECORDS CUSTODIAN
In accordance with Federal Rule of Evidence 902 Self-Authentication, I
» Custodian of Records, do hereby produce the attached records of
Barbara Gonzalez; DOB:
Sg and do hereby certify that such records:
a) Were made at or near the time of the occurrence of the matters set forth by, or from
information transmitted by a person or persons with knowledge of the matters,
acting within the course of the regularly conducted business activity;
b) Were kept in the course of the regularly conducted business activity;
9) Were made as a regular practice in the course of the regularly conducted activity;
qd) And are true and accurate copies of the original records.
I have read every statement made in this certification, and each statement is true and
correct. I understand that falsely making such a certification or declaration would subject
me to criminal penalty under the laws of the foreign or domestic location in which the
certification or declaration was signed.
Records Custodian’s Signature Date
Sworn to or affirmed and signed before me on this day of
2022.
Notary Public
My commission expires:
IN THE CIRCUIT COURT FOR THE
WENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY,
FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 21000968CA
Plaintiff,
V.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
/
SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS
AND THINGS WITHOUT _DEPOSITIONS
TO: Records Custodian (Medical, Billing, and Radiology)
Mr. Connect
2701 Renaissance Blvd., Suite 200
PO Box 61570
Kind of Prussia, PA 19406
YOU ARE HEREBY COMMANDED to produce without deposition and deliver to
Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite
1800, Miami, Florida 33156, on May 22, 2023, copies of the following:
As to Plaintiff: Barbara Gonzalez; _D.O.B: Bag SS#: xxx-xx-y
YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but
not limited to any and all documents set forth below. All_medical, billing & radiology
records requested FILE_are_all-inclusive_and_ should _be_in_no_way limited to_one_date_of
incident.
MEDICAL:
a. office records and notes;
b. doctors and nurses notes;
Cc insurance records and claim forms;
d letters of protection, personal injury agreements or any contract and/or agreement you
have with Plamtiff and/or his/her attorney;
consent forms;
medical records with respect to any and all injuries or illnesses;
medical history forms;
intake forms;
consultations;
correspondence;
charts;
memoranda;
narrative reports;
treatment;
patient questionnaires;
progress notes;
computer generated reports and printouts;
laboratory reports;
radiology reports;
therapy notes;
prescriptions;
any hospital and/or emergency room records;
reports of diagnostic and surgical procedures;
any and all data pertaining to the diagnosis, treatment and care of the patient; and
any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of
plaintiff taken before and/or after plamntiffs mjury.
BILLING:
a. Assignment of Benefits forms;
“Signature on File” forms;
Doctor’s liens;
Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim
forms;
Superbills;
Statements of account;
Correspondence;
Memoranda;
Invoices;
Ledgers;
Computerized billing; and
Letters of Protection, Personal Injury Agreements or any contract and/or agreement you
have with Plaintiff and/or his/her attorney;
m. Itemized Bills
RADIOLOGY:
a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.);
b. Written & computer generated reports.
¢. Intake Sheets and other diagnostic tests, together with reports of the results
Before copying, please fax a detailed list of your complete inventory of films on this
patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the
dates taken and the costs involved in obtaining these copies. We would prefer to
obtain _all films _on disc.
All records requested are all-inclusive and should be in no way limited to one date of
incident. The records should include any notations on the file jacket as well and any and
all reports _or correspondence of other physicians or hospitals included in your file, as well
as all correspondence or any other record of any kind of nature that you have in your
possession regarding the treatment of the above-named person from the first date of
treatment to the present.
You have the right to make a legal objection to the production of these materials under
Rule 1.351 of the Florida Rules of Civil Procedure.
If you fail to comply, you may be held in contempt of Court.
You may request reasonable costs for preparing these documents in advance by making
written request within five (5) days.
A copy of this Subpoena has been furnished to all counsel of record. Also, please
complete, sign, and notarize the attached affidavit.
COMPLIANCE WITH HIPAA DISCLOSURE
Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the
Florida Rules of Civil Procedure. Undersigned certifies that:
1) Written notice has been provided to the insurance and/or the individual’s attorney for
whom the documents are sought,
2) The notice included sufficient information about the litigation and/or proceeding to
permit the individual or his/her attorney to raise an objection to the production of the requested
documents,
3) The time to raise an objection has elapsed and,
4) Neither the individual nor his/her attorney filed an objection to the above-listed
subpoena.
WITNESS my hand and seal on May 2, 2023.
FRANCESCA A. IPPOLITO-CRAVEN
For the Court
4s/ Francesca Ippolito-Craven
Florida Bar Number 0145361
Francesca Ippolito-Craven, Esquire
KUBICKI DRAPER
9100 S. Dadeland Blvd.
Suite 1800
Miami, Florida 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
FIC-KD@kubickidraper.com
*Issued by attorney of record per Rule 1.410
If you are a person with a disability who needs any accommodation in order to
respond to this subpoena, you are entitled, at no cost to you, to the provision of
certain a! tance. Please contact FRANCESCA IPPOLITO-CRAVEN of
Kubicki aper at (305) 982-6737 at least 7 days before your scheduled
appearance, or immediately upon receiving this notification if the time before
the scheduled appearance is less than 7 days; if you are hearing or voice
impaired, call 711.
For questions regarding this Subpoena
Please contact Nicole Almeida (305) 982-6754
FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF
RECORDS CUSTODIAN
In accordance with Federal Rule of Evidence 902 Self-Authentication, I
» Custodian of Records, do hereby produce the attached records of
Barbara Gonzalez; DOB: Sg and do hereby certify that such records:
a) Were made at or near the time of the occurrence of the matters set forth by, or from
information transmitted by a person or persons with knowledge of the matters,
acting within the course of the regularly conducted business activity;
b) Were kept in the course of the regularly conducted business activity;
9) Were made as a regular practice in the course of the regularly conducted activity;
qd) And are true and accurate copies of the original records.
I have read every statement made in this certification, and each statement is true and
correct. I understand that falsely making such a certification or declaration would subject
me to criminal penalty under the laws of the foreign or domestic location in which the
certification or declaration was signed.
Records Custodian’s Signature Date
Sworn to or affirmed and signed before me on this day of
2022.
Notary Public
My commission expires:
IN THE CIRCUIT COURT FOR THE
WENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY,
FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 21000968CA
Plaintiff,
V.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
/
SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS
AND THINGS WITHOUT _DEPOSITIONS
TO: Records Custodian (Medical, Billing, and Radiology)
Ortho Specialists of SW Florida
2531 Cleveland Ave, Suite 1
Fort Myers, FL 33901
YOU ARE HEREBY COMMANDED to produce without deposition and deliver to
Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite
1800, Miami, Florida 33156, on May 22, 2023, copies of the following:
As to Plaintiff: Barbara Gonzalez; _D.O.B: By SS#: xxx-xx-y
YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but
not limited to any and all documents set forth below. All_medical, billing & radiology
records requested FILE are all-inclusive and should be in no way limited to one date of
incident.
MEDICAL:
a. office records and notes;
b, doctors and nurses notes;
Cc insurance records and claim forms;
d letters of protection, personal injury agreements or any contract and/or agreement you
have with Plamtiff and/or his/her attorney;
consent forms;
medical records with respect to any and all injuries or illnesses;
medical history forms;
intake forms;
consultations;
correspondence;
charts;
memoranda;
narrative reports;
treatment;
patient questionnaires;
progress notes;
computer generated reports and printouts;
laboratory reports;
radiology reports;
therapy notes;
prescriptions;
any hospital and/or emergency room records;
reports of diagnostic and surgical procedures;
any and all data pertaining to the diagnosis, treatment and care of the patient; and
any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of
plaintiff taken before and/or after plamntiffs mjury.
BILLING:
a. Assignment of Benefits forms;
“Signature on File” forms;
Doctor’s liens;
Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim
forms;
Superbills;
Statements of account;
Correspondence;
Memoranda;
Invoices;
Ledgers;
Computerized billing; and
Letters of Protection, Personal Injury Agreements or any contract and/or agreement you
have with Plamtiff and/or his/her attorney;
m. Itemized Bills
RADIOLOGY:
a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.);
b. Written & computer generated reports.
C. Intake Sheets and other diagnostic tests, together with reports of the results
Before copying, please fax _a detailed list of your complete inventory of films _on this
patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the
dates taken and the costs involved in obtaining these copies. We would prefer to
obtain _all films _on disc.
All records requested are all-inclusive and should be in no way limited to one date of
incident. The records should include any notations on the file jacket as well and any and
all reports _or correspondence of other physicians or hospitals included in your file, as well
as all correspondence or any other record of any kind of nature that you have in your
possession regarding the treatment of the above-named person from the first date of
treatment to the present.
You have the right to make a legal objection to the production of these materials under
Rule 1.351 of the Florida Rules of Civil Procedure.
If you fail to comply, you may be held in contempt of Court.
You may request reasonable costs for preparing these documents in advance by making
written request within five (5) days.
A copy of this Subpoena has been furnished to all counsel of record. Also, please
complete, sign, and notarize the attached affidavit.
COMPLIANCE WITH HIPAA DISCLOSURE
Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the
Florida Rules of Civil Procedure. Undersigned certifies that:
1) Written notice has been provided to the insurance and/or the individual’s attorney for
whom the documents are sought,
2) The notice included sufficient information about the litigation and/or proceeding to
permit the individual or his/her attorney to raise an objection to the production of the requested
documents,
3) The time to raise an objection has elapsed and,
4) Neither the individual nor his/her attorney filed an objection to the above-listed
subpoena.
WITNESS my hand and seal on May 2, 2023.
FRANCESCA A. IPPOLITO-CRAVEN
For the Court
4s/ Francesca Ippolito-Craven
Florida Bar Number 0145361
Francesca Ippolito-Craven, Esquire
KUBICKI DRAPER
9100 S. Dadeland Blvd.
Suite 1800
Miami, Florida 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
FIC-KD@kubickidraper.com
*Issued by attorney of record per Rule 1.410
If you are a person with a disability who needs any accommodation in order to
respond to this subpoena, you are entitled, at no cost to you, to the provision of
certain a tance. Please contact FRANCESCA IPPOLITO-CRAVEN of
Kubicki aper at (305) 982-6737 at least 7 days before your scheduled
appearance, or immediately upon receiving this notification if the time before
the scheduled appearance is less than 7 days; if you are hearing or voice
impaired, call 711.
For questions regarding this Subpoena
Please contact Nicole Almeida (305) 982-6754
FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF
RECORDS CUSTODIAN
In accordance with Federal Rule of Evidence 902 Self-Authentication, I
» Custodian of Records, do hereby produce the attached records of
Barbara Gonzalez; DOB: Sg and do hereby certify that such records:
a) Were made at or near the time of the occurrence of the matters set forth by, or from
information transmitted by a person or persons with knowledge of the matters,
acting within the course of the regularly conducted business activity;
b) Were kept in the course of the regularly conducted business activity;
9) Were made as a regular practice in the course of the regularly conducted activity;
qd) And are true and accurate copies of the original records.
I have read every statement made in this certification, and each statement is true and
correct. I understand that falsely making such a certification or declaration would subject
me to criminal penalty under the laws of the foreign or domestic location in which the
certification or declaration was signed.
Records Custodian’s Signature Date
Sworn to or affirmed and signed before me on this day of
2022.
Notary Public
My commission expires:
IN THE CIRCUIT COURT FOR THE
WENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY,
FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 21000968CA
Plaintiff,
V.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
/
SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS
AND THINGS WITHOUT _DEPOSITIONS
TO: Records Custodian (Medical, Billing, and Radiology)
Pulmonary Associates of Charlotte County
2400 Harbor Blvd, Unit 2
Port Charlotte, FL 33952
Phone: (941) 205-5864
YOU ARE HEREBY COMMANDED to produce without deposition and deliver to
Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite
1800, Miami, Florida 33156, on May 22, 2023, copies of the following:
As to Plaintiff: Barbara Gonzalez; D.O.B: Mg SS#: xxx-xx- ay
YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but
not limited to any and all documents set forth below. All_medical, billing & radiology
records requested FILE_are_all-inclusive_and_ should _be_in_no_way limited to_one_date_of
incident.
MEDICAL:
a. office records and notes;
b. doctors and nurses notes;
Cc insurance records and claim forms;
d letters of protection, personal injury agreements or any contract and/or agreement you
have with Plamtiff and/or his/her attorney;
Preview
Filing # 171530021 E-Filed 04/21/2023 01:17:42 PM 0124157 IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.:21000968CA Plaintiff, V. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE HEREBY NOTIFIED that after ten (10) days of service of this Notice of Production from Non-Party, the undersigned will apply to the Clerk of the Court for issuance of the attached Subpoenas directed to: ShorePoint Health Port Charlotte ShorePoint Health Punta Gorda Bayfront Health Punta Gorda Ortho Specialists of SW Florida Mr. Connect Anesthesia & Pain Consultants of Southwest Florida, M.D., P.A. American Imaging Pulmonary Associates of Charlotte County who are not a party to this action, to produce the items listed at the time and place specified in the Subpoenas. CERTIFICATE _OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregomg was e-mailed to all counsel of the attached Service List this 21st day of April, 2023. KUBICKI DRAPER 9100 South Dadeland Blvd. Suite 1800 Miami, FL 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 Pleadings: FIC-KD@kubickidraper.com By:_/s/ Francesca Ippolito-Crave FRANCESCA IPPOLITO-CRAVEN fic@kubickidraper.com Florida Bar Number: 0145361 LISANDRA GUERRERO Ig@kubickidraper.com Florida Bar Number: 0098521 SERVICE LIST Co-counsel for Plaintiff: Michael J. Rossi, Esq. MICHAEL J. ROSSI, P.A. 115 South Albany Avenue Tampa, FL 33606 michael@ michaelrossilaw.com Helen Stratigakos, Esq. STRATIGAKOS LAW, P.A. 412 East Madison Street, Suite 814 Tampa, FL 33602 helen@stratigakoslaw.com marty@stratigakoslaw.com IN THE CIRCUIT COURT FOR THE WENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 21000968CA Plaintiff, V. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS AND THINGS WITHOUT _DEPOSITIONS TO: Records Custodian (Medical, Billing, and Radiology) American Imaging 23081 Harborview Rd Port Charlotte, FL 33980 Ph: 941-235-8762 YOU ARE HEREBY COMMANDED to produce without deposition and deliver to Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite 1800, Miami, Florida 33156, on May 22, 2023, copies of the following: As to Plaintiff: Barbara Gonzalez; _D.O.B: Bag SS#: xxx-xx-y YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but not limited to any and all documents set forth below. All_medical, billing & radiology records requested FILE_are_all-inclusive_and_ should _be_in_no_way limited to_one_date_of incident. MEDICAL: a. office records and notes; b. doctors and nurses notes; Cc insurance records and claim forms; d letters of protection, personal injury agreements or any contract and/or agreement you have with Plamtiff and/or his/her attorney; consent forms; medical records with respect to any and all injuries or illnesses; medical history forms; intake forms; consultations; correspondence; charts; memoranda; narrative reports; treatment; patient questionnaires; progress notes; computer generated reports and printouts; laboratory reports; radiology reports; therapy notes; prescriptions; any hospital and/or emergency room records; reports of diagnostic and surgical procedures; any and all data pertaining to the diagnosis, treatment and care of the patient; and any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of plaintiff taken before and/or after plamntiffs mjury. BILLING: a. Assignment of Benefits forms; “Signature on File” forms; Doctor’s liens; Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim forms; Superbills; Statements of account; Correspondence; Memoranda; Invoices; Ledgers; Computerized billing; and Letters of Protection, Personal Injury Agreements or any contract and/or agreement you have with Plaintiff and/or his/her attorney; m. Itemized Bills RADIOLOGY: a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.); b. Written & computer generated reports. ¢. Intake Sheets and other diagnostic tests, together with reports of the results Before copying, please fax a detailed list of your complete inventory of films on this patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the dates taken and the costs involved in obtaining these copies. We would prefer to obtain _all films _on disc. All records requested are all-inclusive and should be in no way limited to one date of incident. The records should include any notations on the file jacket as well and any and all reports _or correspondence of other physicians or hospitals included in your file, as well as all correspondence or any other record of any kind of nature that you have in your possession regarding the treatment of the above-named person from the first date of treatment to the present. You have the right to make a legal objection to the production of these materials under Rule 1.351 of the Florida Rules of Civil Procedure. If you fail to comply, you may be held in contempt of Court. You may request reasonable costs for preparing these documents in advance by making written request within five (5) days. A copy of this Subpoena has been furnished to all counsel of record. Also, please complete, sign, and notarize the attached affidavit. COMPLIANCE WITH HIPAA DISCLOSURE Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the Florida Rules of Civil Procedure. Undersigned certifies that: 1) Written notice has been provided to the insurance and/or the individual’s attorney for whom the documents are sought, 2) The notice included sufficient information about the litigation and/or proceeding to permit the individual or his/her attorney to raise an objection to the production of the requested documents, 3) The time to raise an objection has elapsed and, 4) Neither the individual nor his/her attorney filed an objection to the above-listed subpoena. WITNESS my hand and seal on May 2, 2023. FRANCESCA A. IPPOLITO-CRAVEN For the Court 4s/ Francesca Ippolito-Craven Florida Bar Number 0145361 Francesca Ippolito-Craven, Esquire KUBICKI DRAPER 9100 S. Dadeland Blvd. Suite 1800 Miami, Florida 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 FIC-KD@kubickidraper.com *Issued by attorney of record per Rule 1.410 If you are a person with a disability who needs any accommodation in order to respond to this subpoena, you are entitled, at no cost to you, to the provision of certain a! tance. Please contact FRANCESCA IPPOLITO-CRAVEN of Kubicki aper at (305) 982-6737 at least 7 days before your scheduled appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. For questions regarding this Subpoena Please contact Nicole Almeida (305) 982-6754 FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF RECORDS CUSTODIAN In accordance with Federal Rule of Evidence 902 Self-Authentication, I » Custodian of Records, do hereby produce the attached records of Barbara Gonzalez; DOB: Sg and do hereby certify that such records: a) Were made at or near the time of the occurrence of the matters set forth by, or from information transmitted by a person or persons with knowledge of the matters, acting within the course of the regularly conducted business activity; b) Were kept in the course of the regularly conducted business activity; 9) Were made as a regular practice in the course of the regularly conducted activity; qd) And are true and accurate copies of the original records. I have read every statement made in this certification, and each statement is true and correct. I understand that falsely making such a certification or declaration would subject me to criminal penalty under the laws of the foreign or domestic location in which the certification or declaration was signed. Records Custodian’s Signature Date Sworn to or affirmed and signed before me on this day of 2022. Notary Public My commission expires: IN THE CIRCUIT COURT FOR THE WENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 21000968CA Plaintiff, V. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS AND THINGS WITHOUT _DEPOSITIONS TO: Records Custodian (Medical, Billing, and Radiology) Anesthesia & Pain Consultants of Southwest Florida, MD, PA 12511 World Plaza Lane, Bldg 50 Ft. Myers, FL 33907 YOU ARE HEREBY COMMANDED to produce without deposition and deliver to Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite 1800, Miami, Florida 33156, on May 22, 2023, copies of the following: As to Plaintiff: Barbara Gonzalez; D.O.B: By SS#: xxx-xx-y YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but not limited to any and all documents set forth below. All_medical, billing & radiology records requested FILE are all-inclusive and should be in no way limited to one date of incident. MEDICAL: a. office records and notes; b, doctors and nurses notes; Cc insurance records and claim forms; d letters of protection, personal injury agreements or any contract and/or agreement you have with Plamtiff and/or his/her attorney; consent forms; medical records with respect to any and all injuries or illnesses; medical history forms; intake forms; consultations; correspondence; charts; memoranda; narrative reports; treatment; patient questionnaires; progress notes; computer generated reports and printouts; laboratory reports; radiology reports; therapy notes; prescriptions; any hospital and/or emergency room records; reports of diagnostic and surgical procedures; any and all data pertaining to the diagnosis, treatment and care of the patient; and any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of plaintiff taken before and/or after plamntiffs mjury. BILLING: a. Assignment of Benefits forms; “Signature on File” forms; Doctor’s liens; Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim forms; Superbills; Statements of account; Correspondence; Memoranda; Invoices; Ledgers; Computerized billing; and Letters of Protection, Personal Injury Agreements or any contract and/or agreement you have with Plamtiff and/or his/her attorney; m. Itemized Bills RADIOLOGY: a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.); b. Written & computer generated reports. C. Intake Sheets and other diagnostic tests, together with reports of the results Before copying, please fax _a detailed list of your complete inventory of films _on this patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the dates taken and the costs involved in obtaining these copies. We would prefer to obtain _all films _on disc. All records requested are all-inclusive and should be in no way limited to one date of incident. The records should include any notations on the file jacket as well and any and all reports _or correspondence of other physicians or hospitals included in your file, as well as all correspondence or any other record of any kind of nature that you have in your possession regarding the treatment of the above-named person from the first date of treatment to the present. You have the right to make a legal objection to the production of these materials under Rule 1.351 of the Florida Rules of Civil Procedure. If you fail to comply, you may be held in contempt of Court. You may request reasonable costs for preparing these documents in advance by making written request within five (5) days. A copy of this Subpoena has been furnished to all counsel of record. Also, please complete, sign, and notarize the attached affidavit. COMPLIANCE WITH HIPAA DISCLOSURE Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the Florida Rules of Civil Procedure. Undersigned certifies that: 1) Written notice has been provided to the insurance and/or the individual’s attorney for whom the documents are sought, 2) The notice included sufficient information about the litigation and/or proceeding to permit the individual or his/her attorney to raise an objection to the production of the requested documents, 3) The time to raise an objection has elapsed and, 4) Neither the individual nor his/her attorney filed an objection to the above-listed subpoena. WITNESS my hand and seal on May 2, 2023. FRANCESCA A. IPPOLITO-CRAVEN For the Court 4s/ Francesca Ippolito-Craven Florida Bar Number 0145361 Francesca Ippolito-Craven, Esquire KUBICKI DRAPER 9100 S. Dadeland Blvd. Suite 1800 Miami, Florida 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 FIC-KD@kubickidraper.com *Issued by attorney of record per Rule 1.410 If you are a person with a disability who needs any accommodation in order to respond to this subpoena, you are entitled, at no cost to you, to the provision of certain a tance. Please contact FRANCESCA IPPOLITO-CRAVEN of Kubicki aper at (305) 982-6737 at least 7 days before your scheduled appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. For questions regarding this Subpoena Please contact Nicole Almeida (305) 982-6754 FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF RECORDS CUSTODIAN In accordance with Federal Rule of Evidence 902 Self-Authentication, I » Custodian of Records, do hereby produce the attached records of Barbara Gonzalez; DOB: Sg and do hereby certify that such records: a) Were made at or near the time of the occurrence of the matters set forth by, or from information transmitted by a person or persons with knowledge of the matters, acting within the course of the regularly conducted business activity; b) Were kept in the course of the regularly conducted business activity; 9) Were made as a regular practice in the course of the regularly conducted activity; qd) And are true and accurate copies of the original records. I have read every statement made in this certification, and each statement is true and correct. I understand that falsely making such a certification or declaration would subject me to criminal penalty under the laws of the foreign or domestic location in which the certification or declaration was signed. Records Custodian’s Signature Date Sworn to or affirmed and signed before me on this day of 2022. Notary Public My commission expires: IN THE CIRCUIT COURT FOR THE WENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 21000968CA Plaintiff, V. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS AND THINGS WITHOUT _DEPOSITIONS TO: Records Custodian (Medical, Billing, and Radiology) Bayfront Health Punta Gorda Attn: Bayfront Health Medical Records Department 701 6th Street S. St. Petersburg, FL 32701 YOU ARE HEREBY COMMANDED to produce without deposition and deliver to Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite 1800, Miami, Florida 33156, on May 22, 2023, copies of the following: As to Plaintiff: Barbara Gonzalez; D.O.B: Bag SS#: xxx-xx-y YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but not limited to any and all documents set forth below. All_medical, billing & radiology records requested FILE_are_all-inclusive_and_ should _be_in_no_way limited to_one_date_of incident. MEDICAL: a. office records and notes; b. doctors and nurses notes; Cc insurance records and claim forms; d letters of protection, personal injury agreements or any contract and/or agreement you have with Plamtiff and/or his/her attorney; consent forms; medical records with respect to any and all injuries or illnesses; medical history forms; intake forms; consultations; correspondence; charts; memoranda; narrative reports; treatment; patient questionnaires; progress notes; computer generated reports and printouts; laboratory reports; radiology reports; therapy notes; prescriptions; any hospital and/or emergency room records; reports of diagnostic and surgical procedures; any and all data pertaining to the diagnosis, treatment and care of the patient; and any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of plaintiff taken before and/or after plamntiffs mjury. BILLING: a. Assignment of Benefits forms; “Signature on File” forms; Doctor’s liens; Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim forms; Superbills; Statements of account; Correspondence; Memoranda; Invoices; Ledgers; Computerized billing; and Letters of Protection, Personal Injury Agreements or any contract and/or agreement you have with Plaintiff and/or his/her attorney; m. Itemized Bills RADIOLOGY: a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.); b. Written & computer generated reports. ¢. Intake Sheets and other diagnostic tests, together with reports of the results Before copying, please fax a detailed list of your complete inventory of films on this patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the dates taken and the costs involved in obtaining these copies. We would prefer to obtain _all films _on disc. All records requested are all-inclusive and should be in no way limited to one date of incident. The records should include any notations on the file jacket as well and any and all reports _or correspondence of other physicians or hospitals included in your file, as well as all correspondence or any other record of any kind of nature that you have in your possession regarding the treatment of the above-named person from the first date of treatment to the present. You have the right to make a legal objection to the production of these materials under Rule 1.351 of the Florida Rules of Civil Procedure. If you fail to comply, you may be held in contempt of Court. You may request reasonable costs for preparing these documents in advance by making written request within five (5) days. A copy of this Subpoena has been furnished to all counsel of record. Also, please complete, sign, and notarize the attached affidavit. COMPLIANCE WITH HIPAA DISCLOSURE Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the Florida Rules of Civil Procedure. Undersigned certifies that: 1) Written notice has been provided to the insurance and/or the individual’s attorney for whom the documents are sought, 2) The notice included sufficient information about the litigation and/or proceeding to permit the individual or his/her attorney to raise an objection to the production of the requested documents, 3) The time to raise an objection has elapsed and, 4) Neither the individual nor his/her attorney filed an objection to the above-listed subpoena. WITNESS my hand and seal on May 2, 2023. FRANCESCA A. IPPOLITO-CRAVEN For the Court 4s/ Francesca Ippolito-Craven Florida Bar Number 0145361 Francesca Ippolito-Craven, Esquire KUBICKI DRAPER 9100 S. Dadeland Blvd. Suite 1800 Miami, Florida 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 FIC-KD@kubickidraper.com *Issued by attorney of record per Rule 1.410 If you are a person with a disability who needs any accommodation in order to respond to thi subpoena, you are entitled, at no cost to you, to the provision of certain a! tance. Please contact FRANCESCA IPPOLITO-CRAVEN of Kubicki aper at (305) 982-6737 at least 7 days before your scheduled appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. For questions regarding this Subpoena Please contact Nicole Almeida (305) 982-6754 FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF RECORDS CUSTODIAN In accordance with Federal Rule of Evidence 902 Self-Authentication, I » Custodian of Records, do hereby produce the attached records of Barbara Gonzalez; DOB: Sg and do hereby certify that such records: a) Were made at or near the time of the occurrence of the matters set forth by, or from information transmitted by a person or persons with knowledge of the matters, acting within the course of the regularly conducted business activity; b) Were kept in the course of the regularly conducted business activity; 9) Were made as a regular practice in the course of the regularly conducted activity; qd) And are true and accurate copies of the original records. I have read every statement made in this certification, and each statement is true and correct. I understand that falsely making such a certification or declaration would subject me to criminal penalty under the laws of the foreign or domestic location in which the certification or declaration was signed. Records Custodian’s Signature Date Sworn to or affirmed and signed before me on this day of 2022. Notary Public My commission expires: IN THE CIRCUIT COURT FOR THE WENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 21000968CA Plaintiff, V. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS AND THINGS WITHOUT _DEPOSITIONS TO: Records Custodian (Medical, Billing, and Radiology) Mr. Connect 2701 Renaissance Blvd., Suite 200 PO Box 61570 Kind of Prussia, PA 19406 YOU ARE HEREBY COMMANDED to produce without deposition and deliver to Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite 1800, Miami, Florida 33156, on May 22, 2023, copies of the following: As to Plaintiff: Barbara Gonzalez; _D.O.B: Bag SS#: xxx-xx-y YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but not limited to any and all documents set forth below. All_medical, billing & radiology records requested FILE_are_all-inclusive_and_ should _be_in_no_way limited to_one_date_of incident. MEDICAL: a. office records and notes; b. doctors and nurses notes; Cc insurance records and claim forms; d letters of protection, personal injury agreements or any contract and/or agreement you have with Plamtiff and/or his/her attorney; consent forms; medical records with respect to any and all injuries or illnesses; medical history forms; intake forms; consultations; correspondence; charts; memoranda; narrative reports; treatment; patient questionnaires; progress notes; computer generated reports and printouts; laboratory reports; radiology reports; therapy notes; prescriptions; any hospital and/or emergency room records; reports of diagnostic and surgical procedures; any and all data pertaining to the diagnosis, treatment and care of the patient; and any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of plaintiff taken before and/or after plamntiffs mjury. BILLING: a. Assignment of Benefits forms; “Signature on File” forms; Doctor’s liens; Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim forms; Superbills; Statements of account; Correspondence; Memoranda; Invoices; Ledgers; Computerized billing; and Letters of Protection, Personal Injury Agreements or any contract and/or agreement you have with Plaintiff and/or his/her attorney; m. Itemized Bills RADIOLOGY: a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.); b. Written & computer generated reports. ¢. Intake Sheets and other diagnostic tests, together with reports of the results Before copying, please fax a detailed list of your complete inventory of films on this patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the dates taken and the costs involved in obtaining these copies. We would prefer to obtain _all films _on disc. All records requested are all-inclusive and should be in no way limited to one date of incident. The records should include any notations on the file jacket as well and any and all reports _or correspondence of other physicians or hospitals included in your file, as well as all correspondence or any other record of any kind of nature that you have in your possession regarding the treatment of the above-named person from the first date of treatment to the present. You have the right to make a legal objection to the production of these materials under Rule 1.351 of the Florida Rules of Civil Procedure. If you fail to comply, you may be held in contempt of Court. You may request reasonable costs for preparing these documents in advance by making written request within five (5) days. A copy of this Subpoena has been furnished to all counsel of record. Also, please complete, sign, and notarize the attached affidavit. COMPLIANCE WITH HIPAA DISCLOSURE Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the Florida Rules of Civil Procedure. Undersigned certifies that: 1) Written notice has been provided to the insurance and/or the individual’s attorney for whom the documents are sought, 2) The notice included sufficient information about the litigation and/or proceeding to permit the individual or his/her attorney to raise an objection to the production of the requested documents, 3) The time to raise an objection has elapsed and, 4) Neither the individual nor his/her attorney filed an objection to the above-listed subpoena. WITNESS my hand and seal on May 2, 2023. FRANCESCA A. IPPOLITO-CRAVEN For the Court 4s/ Francesca Ippolito-Craven Florida Bar Number 0145361 Francesca Ippolito-Craven, Esquire KUBICKI DRAPER 9100 S. Dadeland Blvd. Suite 1800 Miami, Florida 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 FIC-KD@kubickidraper.com *Issued by attorney of record per Rule 1.410 If you are a person with a disability who needs any accommodation in order to respond to this subpoena, you are entitled, at no cost to you, to the provision of certain a! tance. Please contact FRANCESCA IPPOLITO-CRAVEN of Kubicki aper at (305) 982-6737 at least 7 days before your scheduled appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. For questions regarding this Subpoena Please contact Nicole Almeida (305) 982-6754 FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF RECORDS CUSTODIAN In accordance with Federal Rule of Evidence 902 Self-Authentication, I » Custodian of Records, do hereby produce the attached records of Barbara Gonzalez; DOB: Sg and do hereby certify that such records: a) Were made at or near the time of the occurrence of the matters set forth by, or from information transmitted by a person or persons with knowledge of the matters, acting within the course of the regularly conducted business activity; b) Were kept in the course of the regularly conducted business activity; 9) Were made as a regular practice in the course of the regularly conducted activity; qd) And are true and accurate copies of the original records. I have read every statement made in this certification, and each statement is true and correct. I understand that falsely making such a certification or declaration would subject me to criminal penalty under the laws of the foreign or domestic location in which the certification or declaration was signed. Records Custodian’s Signature Date Sworn to or affirmed and signed before me on this day of 2022. Notary Public My commission expires: IN THE CIRCUIT COURT FOR THE WENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 21000968CA Plaintiff, V. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS AND THINGS WITHOUT _DEPOSITIONS TO: Records Custodian (Medical, Billing, and Radiology) Ortho Specialists of SW Florida 2531 Cleveland Ave, Suite 1 Fort Myers, FL 33901 YOU ARE HEREBY COMMANDED to produce without deposition and deliver to Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite 1800, Miami, Florida 33156, on May 22, 2023, copies of the following: As to Plaintiff: Barbara Gonzalez; _D.O.B: By SS#: xxx-xx-y YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but not limited to any and all documents set forth below. All_medical, billing & radiology records requested FILE are all-inclusive and should be in no way limited to one date of incident. MEDICAL: a. office records and notes; b, doctors and nurses notes; Cc insurance records and claim forms; d letters of protection, personal injury agreements or any contract and/or agreement you have with Plamtiff and/or his/her attorney; consent forms; medical records with respect to any and all injuries or illnesses; medical history forms; intake forms; consultations; correspondence; charts; memoranda; narrative reports; treatment; patient questionnaires; progress notes; computer generated reports and printouts; laboratory reports; radiology reports; therapy notes; prescriptions; any hospital and/or emergency room records; reports of diagnostic and surgical procedures; any and all data pertaining to the diagnosis, treatment and care of the patient; and any and all x-rays and x-ray reports, MRI films and reports, any and all photographs of plaintiff taken before and/or after plamntiffs mjury. BILLING: a. Assignment of Benefits forms; “Signature on File” forms; Doctor’s liens; Health Insurance Claim Forms (HCFA) / CMS-1500 and /or UB-92 / UB-O4 claim forms; Superbills; Statements of account; Correspondence; Memoranda; Invoices; Ledgers; Computerized billing; and Letters of Protection, Personal Injury Agreements or any contract and/or agreement you have with Plamtiff and/or his/her attorney; m. Itemized Bills RADIOLOGY: a. Raw data (X-Rays, CT Scans, MRI films, wave forms, wet reads, etc.); b. Written & computer generated reports. C. Intake Sheets and other diagnostic tests, together with reports of the results Before copying, please fax _a detailed list of your complete inventory of films _on this patient _to_ the attention of Nicole Almeida at (305) 374-7846 listing additionally the dates taken and the costs involved in obtaining these copies. We would prefer to obtain _all films _on disc. All records requested are all-inclusive and should be in no way limited to one date of incident. The records should include any notations on the file jacket as well and any and all reports _or correspondence of other physicians or hospitals included in your file, as well as all correspondence or any other record of any kind of nature that you have in your possession regarding the treatment of the above-named person from the first date of treatment to the present. You have the right to make a legal objection to the production of these materials under Rule 1.351 of the Florida Rules of Civil Procedure. If you fail to comply, you may be held in contempt of Court. You may request reasonable costs for preparing these documents in advance by making written request within five (5) days. A copy of this Subpoena has been furnished to all counsel of record. Also, please complete, sign, and notarize the attached affidavit. COMPLIANCE WITH HIPAA DISCLOSURE Defendant has complied with 45 C.F.R., Section 164.512(e) and Rule 1.351 of the Florida Rules of Civil Procedure. Undersigned certifies that: 1) Written notice has been provided to the insurance and/or the individual’s attorney for whom the documents are sought, 2) The notice included sufficient information about the litigation and/or proceeding to permit the individual or his/her attorney to raise an objection to the production of the requested documents, 3) The time to raise an objection has elapsed and, 4) Neither the individual nor his/her attorney filed an objection to the above-listed subpoena. WITNESS my hand and seal on May 2, 2023. FRANCESCA A. IPPOLITO-CRAVEN For the Court 4s/ Francesca Ippolito-Craven Florida Bar Number 0145361 Francesca Ippolito-Craven, Esquire KUBICKI DRAPER 9100 S. Dadeland Blvd. Suite 1800 Miami, Florida 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 FIC-KD@kubickidraper.com *Issued by attorney of record per Rule 1.410 If you are a person with a disability who needs any accommodation in order to respond to this subpoena, you are entitled, at no cost to you, to the provision of certain a tance. Please contact FRANCESCA IPPOLITO-CRAVEN of Kubicki aper at (305) 982-6737 at least 7 days before your scheduled appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. For questions regarding this Subpoena Please contact Nicole Almeida (305) 982-6754 FEDERAL RULE OF EVIDENCE 902 CERTIFICATION/DECLARATION_ OF RECORDS CUSTODIAN In accordance with Federal Rule of Evidence 902 Self-Authentication, I » Custodian of Records, do hereby produce the attached records of Barbara Gonzalez; DOB: Sg and do hereby certify that such records: a) Were made at or near the time of the occurrence of the matters set forth by, or from information transmitted by a person or persons with knowledge of the matters, acting within the course of the regularly conducted business activity; b) Were kept in the course of the regularly conducted business activity; 9) Were made as a regular practice in the course of the regularly conducted activity; qd) And are true and accurate copies of the original records. I have read every statement made in this certification, and each statement is true and correct. I understand that falsely making such a certification or declaration would subject me to criminal penalty under the laws of the foreign or domestic location in which the certification or declaration was signed. Records Custodian’s Signature Date Sworn to or affirmed and signed before me on this day of 2022. Notary Public My commission expires: IN THE CIRCUIT COURT FOR THE WENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 21000968CA Plaintiff, V. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / SUBPOENA DUCES TECUM FOR THE PRODUCTION OF DOCUMENTS AND THINGS WITHOUT _DEPOSITIONS TO: Records Custodian (Medical, Billing, and Radiology) Pulmonary Associates of Charlotte County 2400 Harbor Blvd, Unit 2 Port Charlotte, FL 33952 Phone: (941) 205-5864 YOU ARE HEREBY COMMANDED to produce without deposition and deliver to Francesca Ippolito-Craven, Esquire, at KUBICKI DRAPER, 9100 S. Dadeland Boulevard, Suite 1800, Miami, Florida 33156, on May 22, 2023, copies of the following: As to Plaintiff: Barbara Gonzalez; D.O.B: Mg SS#: xxx-xx- ay YOUR ENTIRE from February 1, 2022-present time, cover to cover, including but not limited to any and all documents set forth below. All_medical, billing & radiology records requested FILE_are_all-inclusive_and_ should _be_in_no_way limited to_one_date_of incident. MEDICAL: a. office records and notes; b. doctors and nurses notes; Cc insurance records and claim forms; d letters of protection, personal injury agreements or any contract and/or agreement you have with Plamtiff and/or his/her attorney;