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Filing #78591813 E-Filed 09/28/2018 12:49:22 PM
VERIFIED RETURN OF SERVICE
State of Florida County of HILLSBOROUGH Circuit Court
Case Number: 18-CA-001480 Court Date: 10/10/2018 9:30 am
Plaintiff:
LYLAN NGUYEN
vs.
Defendant:
CITY OF TAMPA
For:
ROBIN HORTON SILVERMAN
OFFICE OF THE CITY ATTORNEY
315 E. KENNEDY BLVD
5TH FLOOR
Tampa, FL 33602
Received by CHOICE PROCESS - TAMPA on the 17th day of September, 2018 at 12:43 pm to be served
on AFO IMAGING A/K/A ADVANCED DIAGNOSTIC ATTN: RECORDS CUSTODIAN, 2700 UNIVERSITY
SQUARE DR, TAMPA, FL 33612.
|, NATHANIEL POWELL, do hereby affirm that on the 21st day of September, 2018 at 2:17 pm, I:
CORPORATE: served by delivering a true copy of the SUBPOENA DUCES TECUM WITHOUT
DEPOSITION with the date and hour of service endorsed thereon by me, to: S. HANDCOCK as
RECEPTIONIST for AFO IMAGING A/K/A ADVANCED DIAGNOSTIC ATTN: RECORDS CUSTODIAN,
at the address of. 3104 W, WATERS AVE, SUITE 106, TAMPA, FL 33614, and informed said person of
the contents therein, in compliance with state statutes.
Additional Information pertaining to this Service:
LOCATED AND SERVED AT ABOVE ADDRESS.
9/28/2018 12:49 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 1
VERIFIED RETURN OF SERVICE For 18-CA-001480
| certify that | am over the age of 18 and have no interest in the above action and | am in good standing in
the judicial circuit in which the process was served. Under penalty of perjury, | declare that | have read the
foregoing and that the facts stated in it are true.
NATH, IEL POWELL
CPS98-594510
CHOICE PROCESS - TAMPA
Attn: Process Accounting
P.O. Box 1215
Tampa, FL 33601
(813) 229-1444
Our Job Serial Number: CPS-2018011589
Copyright © 1992-2018 Detabase Services, Inc. - Process Server's Toolbox V7.2p
9/28/2018 12:49 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 2
ORIGINAL
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR THE STATE OF FLORIDA
GENERAL CIVIL DIVISION
LYLAN NGUYEN,
Plaintiff, CASE NO.: 18-CA-001480
vy, DIVISION: C
CITY OF TAMPA,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA
TO: AFO Imaging a/k/a Advanced Diagnostic
Attn: Records Custodian
2700 University Square Dr.
Tampa, Florida 33612
YOU ARE COMMANDED to appear at the Office of the City Attomey, 315 E, Kennedy Blvd., in
Tampa, Florida 33602, on October 10, 2018 at 9:30 a.m. and to bave with you at that time and place the
following:
Any and all records in your possession pertaining
cuding but not limited to the entire ‘chart, cover 10
cover, including any and all medical records, notes, bills, diagnostic films, MRI's, X-rays,
tests and reports, patient information sheets, lab reports, progress reports, work sheets,
insurance forms, statements, photographs, miscellaneous correspondence to attommeys or
miscellaneous. correspondence to physicians contained in your file.
‘These items will be inspected and may be copied at that time. You will not be required to surrender
the original items, You may comply with this Subpoena by providing legible copies of the items to be
produced to the attorney whose name appears on this Subpoena on or before the scheduled date of
production. You may condition the preparation of the copies upon payment in advance of the reasonable
cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this
Subpoena and thereby eliminate your appearance at the time and place specified above, You have the right
to object to the production pursuant to their 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.
Defendant, City of Tampa, as the requesting party has complied with Florida Rule of Civil
Procedure 1.351. This subpoena was issued Fifteen (15) days after the Plaintiff was served with notice
of the City’s intent to obtain these records via subpoena and the Plaintiff has not served any objection
thereto.
9/28/2018 12:49 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 3
Ifyou fail to:
(1) appear as specified;
2) furnish the records instead of appearing as provided above; or
@) 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.
Pursuant to the Health Insurance Portability and Accountability Act, Sections 164.512(a)(1) and
164,512(e)(1)(ii)(A), of the Code of Federal Regulations, you are advised that the individual who is the
subject of the requested records has been given notice of this request for the information described herein,
the notice included sufficient information about the litigation in which this information is required to
permit the individual to raise an. objection to the court, and the time for the individual to raise any
objection to this request has elapsed and no objection was filed.
DATED on
SEP 13 2018
SALVATORE TERRITO, CITY ATTORNEY
CITY OF TAMPA
/sf Robin Horton Silverman
Robin Horton Silverman
Assistant City Attorney
Florida Bar No. 0027934
5th Floor, Old City Hall
315 E. Kennedy Blvd.
Tampa, Florida 33602
Telephone: (813) 274-8996
Facsimile: (813) 274-8894
E-Mail: Robin.Horton-Silverman@tampagov.net
Attorney for Defendant, City of Tampa
THIS SUBPOENA IS VALID THROUGHOUT THE DURATION OF THIS LITIGATION. WE RESERVE THE
RIGHT TO REQUEST SUPPLEMENTAL/UPDATED RECORDS THROUGHOUT THIS LITIGATION
PURSUANT TO THIS SUBPOENA.
IMPORTANT NOTE TO THE WITNESS REGARDING COPYING COST:
IN THE EVENT THAT PHOTOCOPYING COSTS ARE EXPECTED TO EXCEED $50.00, PLEASE CONTACT
THE OFFICE OF THE UNDERSIGNED ATTORNEY AT (813) 274-8996 AND ADVISE OF SAME PRIOR TO
COMPLYING WITH THIS SUBPOENA. SAID ATTORNEY RESERVES THE RIGHT TO CONTEST ANY
BILLINGS FOR RECORDS SENT IN EXCESS OF $50.00 IF PRIOR APPROVAL NOT AUTHORIZED.
If you are a person with a disability who needs any accommodation in order to respond to this subpoena, you
moay request such assistance by contacting the attorney at the address and number above upon the receipt of this
subpoena; if you are hearing impaired, call 711.
9/28/2018 12:49 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 4
Preview
Filing #78591813 E-Filed 09/28/2018 12:49:22 PM VERIFIED RETURN OF SERVICE State of Florida County of HILLSBOROUGH Circuit Court Case Number: 18-CA-001480 Court Date: 10/10/2018 9:30 am Plaintiff: LYLAN NGUYEN vs. Defendant: CITY OF TAMPA For: ROBIN HORTON SILVERMAN OFFICE OF THE CITY ATTORNEY 315 E. KENNEDY BLVD 5TH FLOOR Tampa, FL 33602 Received by CHOICE PROCESS - TAMPA on the 17th day of September, 2018 at 12:43 pm to be served on AFO IMAGING A/K/A ADVANCED DIAGNOSTIC ATTN: RECORDS CUSTODIAN, 2700 UNIVERSITY SQUARE DR, TAMPA, FL 33612. |, NATHANIEL POWELL, do hereby affirm that on the 21st day of September, 2018 at 2:17 pm, I: CORPORATE: served by delivering a true copy of the SUBPOENA DUCES TECUM WITHOUT DEPOSITION with the date and hour of service endorsed thereon by me, to: S. HANDCOCK as RECEPTIONIST for AFO IMAGING A/K/A ADVANCED DIAGNOSTIC ATTN: RECORDS CUSTODIAN, at the address of. 3104 W, WATERS AVE, SUITE 106, TAMPA, FL 33614, and informed said person of the contents therein, in compliance with state statutes. Additional Information pertaining to this Service: LOCATED AND SERVED AT ABOVE ADDRESS. 9/28/2018 12:49 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 1 VERIFIED RETURN OF SERVICE For 18-CA-001480 | certify that | am over the age of 18 and have no interest in the above action and | am in good standing in the judicial circuit in which the process was served. Under penalty of perjury, | declare that | have read the foregoing and that the facts stated in it are true. NATH, IEL POWELL CPS98-594510 CHOICE PROCESS - TAMPA Attn: Process Accounting P.O. Box 1215 Tampa, FL 33601 (813) 229-1444 Our Job Serial Number: CPS-2018011589 Copyright © 1992-2018 Detabase Services, Inc. - Process Server's Toolbox V7.2p 9/28/2018 12:49 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 2 ORIGINAL IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR THE STATE OF FLORIDA GENERAL CIVIL DIVISION LYLAN NGUYEN, Plaintiff, CASE NO.: 18-CA-001480 vy, DIVISION: C CITY OF TAMPA, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA TO: AFO Imaging a/k/a Advanced Diagnostic Attn: Records Custodian 2700 University Square Dr. Tampa, Florida 33612 YOU ARE COMMANDED to appear at the Office of the City Attomey, 315 E, Kennedy Blvd., in Tampa, Florida 33602, on October 10, 2018 at 9:30 a.m. and to bave with you at that time and place the following: Any and all records in your possession pertaining cuding but not limited to the entire ‘chart, cover 10 cover, including any and all medical records, notes, bills, diagnostic films, MRI's, X-rays, tests and reports, patient information sheets, lab reports, progress reports, work sheets, insurance forms, statements, photographs, miscellaneous correspondence to attommeys or miscellaneous. correspondence to physicians contained in your file. ‘These items will be inspected and may be copied at that time. You will not be required to surrender the original items, You may comply with this Subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this Subpoena and thereby eliminate your appearance at the time and place specified above, You have the right to object to the production pursuant to their 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. Defendant, City of Tampa, as the requesting party has complied with Florida Rule of Civil Procedure 1.351. This subpoena was issued Fifteen (15) days after the Plaintiff was served with notice of the City’s intent to obtain these records via subpoena and the Plaintiff has not served any objection thereto. 9/28/2018 12:49 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 3 Ifyou fail to: (1) appear as specified; 2) furnish the records instead of appearing as provided above; or @) 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. Pursuant to the Health Insurance Portability and Accountability Act, Sections 164.512(a)(1) and 164,512(e)(1)(ii)(A), of the Code of Federal Regulations, you are advised that the individual who is the subject of the requested records has been given notice of this request for the information described herein, the notice included sufficient information about the litigation in which this information is required to permit the individual to raise an. objection to the court, and the time for the individual to raise any objection to this request has elapsed and no objection was filed. DATED on SEP 13 2018 SALVATORE TERRITO, CITY ATTORNEY CITY OF TAMPA /sf Robin Horton Silverman Robin Horton Silverman Assistant City Attorney Florida Bar No. 0027934 5th Floor, Old City Hall 315 E. Kennedy Blvd. Tampa, Florida 33602 Telephone: (813) 274-8996 Facsimile: (813) 274-8894 E-Mail: Robin.Horton-Silverman@tampagov.net Attorney for Defendant, City of Tampa THIS SUBPOENA IS VALID THROUGHOUT THE DURATION OF THIS LITIGATION. WE RESERVE THE RIGHT TO REQUEST SUPPLEMENTAL/UPDATED RECORDS THROUGHOUT THIS LITIGATION PURSUANT TO THIS SUBPOENA. IMPORTANT NOTE TO THE WITNESS REGARDING COPYING COST: IN THE EVENT THAT PHOTOCOPYING COSTS ARE EXPECTED TO EXCEED $50.00, PLEASE CONTACT THE OFFICE OF THE UNDERSIGNED ATTORNEY AT (813) 274-8996 AND ADVISE OF SAME PRIOR TO COMPLYING WITH THIS SUBPOENA. SAID ATTORNEY RESERVES THE RIGHT TO CONTEST ANY BILLINGS FOR RECORDS SENT IN EXCESS OF $50.00 IF PRIOR APPROVAL NOT AUTHORIZED. If you are a person with a disability who needs any accommodation in order to respond to this subpoena, you moay request such assistance by contacting the attorney at the address and number above upon the receipt of this subpoena; if you are hearing impaired, call 711. 9/28/2018 12:49 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 4