Preview
Filing # 64944100 E-Filed 12/04/2017 07:31:24 PM
IN THE CIRCUIT COURT OF THE 15™
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 2016CA009367
UWADIAE B. OMOREGIE,
Plaintiff,
vs.
YEFIM KOZA &
EFN INVESTMENTS LLC,
a Florida Limited Liability Company,
PY
Defendant(s).
_________________________________________ /
NOTICE OF INTENT TO SERVE SUBPOENA PURSUANT TO FLORIDA RULE OF
CO
CIVIL PROCEDURE 1.351 FOR DOCUMENTS AND THINGS WITHOUT
DEPOSITION
YOU ARE HEREBY NOTIFIED that after 15 days from the date of service of this Notice, and if
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no objection is received from any party, the undersigned will issue or apply to the Clerk of this Court for
issuance of the attached subpoena directed to:
IE
IF
1. Coca Cola
RT
who is not a party to this action, to produce the items at the time and place specified in the attached
subpoenas.
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CERTIFICATE OF SERVICE
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I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E-mail
on December 4, 2017, to Joseph Cichowski, Esq., Abellon, P.A., 2119 South Dixie Highway, Building II,
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West Palm Beach, FL 33401, Court@abellonlaw.com: clerk@abellonlaw.com.
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KELLEY KRONENBERG, P.A.
Counsel for Defendants, Yefim Koza and EFN
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Investments, LLC
8201 Peters Road, Suite 4000
Fort Lauderdale, FL 33324
Tel: (954) 370-9970
Fax: (954)382-1988
Email: sosber@kelleykronenberg.com
Email: SHOservice@kelleykronenberg.com
By: /s/ Steven H. Osber
Steven H. Osber, Esq.
Florida Bar No.: 086088
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/04/2017 07:31:24 PM
IN THE CIRCUIT COURT OF THE 15™
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 2016CA009367
UWADIAE B. OMOREGIE,
Plaintiff,
vs.
YEFIM KOZA &
PY
EFN INVESTMENTS LLC,
a Florida Limited Liability Company,
Defendant(s).
CO
___________________________________ /
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
(MAIL IN RECORDS ONLY)
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THE STATE OF FLORIDA:
TO: Records Custodian
Coca Cola
IE
IF
6555 Garden Road
Riviera Beach, FL 33404
RT
YOU ARE HEREBY COMMANDED to produce to STEVEN H. OSBER ESQ., KELLEY
KRONENBERG, P.A., 8201 Peters Road, Suite 4000 Fort Lauderdale, FL 33324 within ten (10) days from
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the date of service.
Said documents and/or materials to be produced are as follows:
A
ANY AND ALL PERSONNEL RECORDS, including, but not limited to, your entire
personnel file; workers’ compensation file, employment applications; health tests;
T
documentation of on-the-job injuries; wage information; employment evaluations;
O
documents of sick days; W-2's; handwritten or typed notes, memos,
correspondence, telephone messages; resumes, any and all other documents in
N
any way related to said person, from the inception of your records to the present
pertaining to: UWADIAE OMOREGIE.
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 legal 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 the payment in advance of the reasonable cost of
preparation. You may mail or deliver copies to the attorney whose name appears on this subpoena and
thereby eliminate you appearance at the time and place specified above. You have the right to object to the
production pursuant to this subpoena at any time before production by giving written notice to the attorney
whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
IF YOU DO NOT HAVE RECORDS PLEASE ADVISE IN WRITTING
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If you fail to:
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(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
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you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless
excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed.
DATED this day of December 2017.
IE
IF
KELLEY KRONENBERG, P.A.
Counselfor Defendants
RT
8201 Peters Road, Suite 4000
Fort Lauderdale, FL 33324
Tel: (954) 370-9970
CE
Fax: (954)382-1988
By: /s/Steven II. Osber
Steven H. Osber, Esquire
A
Florida Bar No.: 086088
T
O
HIPAA COMPLIANCE
The issuer of the attached Subpoena Duces Tecum Without Deposition (the "Subpoena") provides the following written statement
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and documentation pursuant to Chapter 45, Section 164.512(e), Code ofFederal Regulations:
1. The individual whose records are subject to the Subpoena has been given notice by service of a Notice of Production from
Non-Party (or Non-Parties) to the persons indicated on the "Certificate of Service" contained therein on the date indicated (the "Notice"),
which date is at least fifteen (15) days before the issue date ofthe Subpoena.
2. Pursuant to Rule 1.351, Florida Rules of Civil Procedure, an objection to the Subpoena could have been made within fifteen (15)
days of tire date ofthe service of tire Notice.
3. The time for tire individual to raise an objection to tire Subpoena has elapsed.
Preview
Filing # 64944100 E-Filed 12/04/2017 07:31:24 PM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2016CA009367 UWADIAE B. OMOREGIE, Plaintiff, vs. YEFIM KOZA & EFN INVESTMENTS LLC, a Florida Limited Liability Company, PY Defendant(s). _________________________________________ / NOTICE OF INTENT TO SERVE SUBPOENA PURSUANT TO FLORIDA RULE OF CO CIVIL PROCEDURE 1.351 FOR DOCUMENTS AND THINGS WITHOUT DEPOSITION YOU ARE HEREBY NOTIFIED that after 15 days from the date of service of this Notice, and if D no objection is received from any party, the undersigned will issue or apply to the Clerk of this Court for issuance of the attached subpoena directed to: IE IF 1. Coca Cola RT who is not a party to this action, to produce the items at the time and place specified in the attached subpoenas. CE CERTIFICATE OF SERVICE A I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E-mail on December 4, 2017, to Joseph Cichowski, Esq., Abellon, P.A., 2119 South Dixie Highway, Building II, T West Palm Beach, FL 33401, Court@abellonlaw.com: clerk@abellonlaw.com. O KELLEY KRONENBERG, P.A. Counsel for Defendants, Yefim Koza and EFN N Investments, LLC 8201 Peters Road, Suite 4000 Fort Lauderdale, FL 33324 Tel: (954) 370-9970 Fax: (954)382-1988 Email: sosber@kelleykronenberg.com Email: SHOservice@kelleykronenberg.com By: /s/ Steven H. Osber Steven H. Osber, Esq. Florida Bar No.: 086088 FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/04/2017 07:31:24 PM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2016CA009367 UWADIAE B. OMOREGIE, Plaintiff, vs. YEFIM KOZA & PY EFN INVESTMENTS LLC, a Florida Limited Liability Company, Defendant(s). CO ___________________________________ / SUBPOENA DUCES TECUM WITHOUT DEPOSITION (MAIL IN RECORDS ONLY) D THE STATE OF FLORIDA: TO: Records Custodian Coca Cola IE IF 6555 Garden Road Riviera Beach, FL 33404 RT YOU ARE HEREBY COMMANDED to produce to STEVEN H. OSBER ESQ., KELLEY KRONENBERG, P.A., 8201 Peters Road, Suite 4000 Fort Lauderdale, FL 33324 within ten (10) days from CE the date of service. Said documents and/or materials to be produced are as follows: A ANY AND ALL PERSONNEL RECORDS, including, but not limited to, your entire personnel file; workers’ compensation file, employment applications; health tests; T documentation of on-the-job injuries; wage information; employment evaluations; O documents of sick days; W-2's; handwritten or typed notes, memos, correspondence, telephone messages; resumes, any and all other documents in N any way related to said person, from the inception of your records to the present pertaining to: UWADIAE OMOREGIE. 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 legal 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 the payment in advance of the reasonable cost of preparation. You may mail or deliver copies to the attorney whose name appears on this subpoena and thereby eliminate you appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. IF YOU DO NOT HAVE RECORDS PLEASE ADVISE IN WRITTING PY If you fail to: CO (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, D you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this day of December 2017. IE IF KELLEY KRONENBERG, P.A. Counselfor Defendants RT 8201 Peters Road, Suite 4000 Fort Lauderdale, FL 33324 Tel: (954) 370-9970 CE Fax: (954)382-1988 By: /s/Steven II. Osber Steven H. Osber, Esquire A Florida Bar No.: 086088 T O HIPAA COMPLIANCE The issuer of the attached Subpoena Duces Tecum Without Deposition (the "Subpoena") provides the following written statement N and documentation pursuant to Chapter 45, Section 164.512(e), Code ofFederal Regulations: 1. The individual whose records are subject to the Subpoena has been given notice by service of a Notice of Production from Non-Party (or Non-Parties) to the persons indicated on the "Certificate of Service" contained therein on the date indicated (the "Notice"), which date is at least fifteen (15) days before the issue date ofthe Subpoena. 2. Pursuant to Rule 1.351, Florida Rules of Civil Procedure, an objection to the Subpoena could have been made within fifteen (15) days of tire date ofthe service of tire Notice. 3. The time for tire individual to raise an objection to tire Subpoena has elapsed.