Preview
Filing # 82595609 E-Filed 12/27/2018 01:10:09 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.
PY
YEFIM KOZA &
EFN INVESTMENTS LLC,
a Florida Limited Liability Company,
CO
Defendant(s).
________________________ I
D
NOTICE OF INTENT TO SERVE SUBPOENA PURSUANT TO FLORIDA RULE OF
IE
CIVIL PROCEDURE 1.351 FOR DOCUMENTS AND THINGS WITHOUT
DEPOSITION
IF
RT
YOU ARE HEREBY NOTIFIED that after 10 days from the date of service of this Notice,
and if no objection is received from any party, the undersigned will issue or apply to the Clerk of
CE
this Court for issuance of the attached subpoena directed to:
1. Sedgwick Claims Management Services, Inc.
A
who is not a party to this action, to produce the items at the time and place specified in the attached
T
subpoenas.
O
N
[CERTIFICATE OF SERVICE ON FOLLOWING PAGE]
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/27/2018 01:10:09 PM
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
E-mail on December 27, 2018, to Maria Abellon, Esquire, 2119 South Dixie Highway, Building
II, West Palm Beach, FL 33401, Maria@abellonlaw.com, Court@abellonlaw.com;
clerk@abellonlaw.com and J. Freddy Rhoads, Esquire, 6701 S. Dixie Highway, West Palm Beach,
FL 33405; freddy@rhoadslawgroup.com; assistant! @rhoadslawgroup.com
PY
CONRAD & SCHERER, LLP
CO
Counselfor Defendants
633 South Federal Highway
Fort Lauderdale, FL 33301
Tel: (954) 847-3305
D
Fax: (954) 463-9244
Email: sosber@conradscherer.com
IE
Email: Lmananzan@conradscherer.com
By: /s/ Steven H. Osber
IF
Steven H. Osber, Esq.
Fla. Bar No.: 086088
RT
CE
A
T
O
N
IN THE CIRCUIT COURT OF THE 15™
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 2016CA009367
UWADIAE B. OMOREGIE,
Plaintiff,
vs.
PY
YEFIM KOZA & EFN INVESTMENTS LLC,
a Florida Limited Liability Company,
CO
Defendant(s).
_________________________ I
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
D
(MAIL IN RECORDS ONLY)
THE STATE OF FLORIDA: IE
IF
TO: RECORDS CUSTODIAN
Sedgwick Claims Management Services, Inc.
c/o C T Corporation System, Registered Agent
RT
1200 South Pine Island Road
Plantation, FL 33324
CE
YOU ARE HEREBY COMMANDED to produce to STEVEN H. OSBER ESQ., CONRAD &
SCHERER, LLP, 633 South Federal Highway, 8th Floor, Fort Lauderdale, FL 33301 within 10
days of receipt of this Subpoena and to have with you at that time and place the following regarding
the named individual:
A
Provide your complete WORKERS’ COMPENSATION FILE, including but not limited
T
to electronic records, any and all records for any and all dates, statements, industrial commission
filings and documents, notes, memoranda, telephone call slips or records, letters and other
O
correspondence, accounting sheets and ledgers, vouchers, canceled checks or check copies, and
N
medical records and reports, payroll and payout sheets and ledgers, relating to any and all
accidents, injuries, bodily injury claims and WORKERS COMPENSATION CLAIMS. Include
all documents specifically referenced in any attachment. Include all records from all departments,
including CD and/or DVD files pertaining to: UWADIAE B. OMOREGIE, DOB: xx/xx/1985,
SSN: Employer: Coca Cola.
*YOU NEED NOT APPEAR IF REQUESTED RECORDS ARE MAILED IN PRIOR TO
THE DEPOSITION DATE.
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 giving 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 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 may
condition the preparation of the copies upon the payment in advance of the reasonable cost of
preparation. You have the right to object to the production pursuant to this subpoena at any time
before production by giving written notice to the attorney whose name appears on this subpoena.
If you fail to appear as specified; or 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
PY
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.
CO
DATED this day of January 2019
CONRAD & SCHERER, LLP
D
Counselfor Defendants
633 South Federal Highway
IE
Fort Lauderdale, FL 33301
Tel: (954) 847-3305
IF
Fax: (954) 463-9244
Email: sosber@conradscherer.com
RT
Email: Lmananzan@conradscherer.com
By: /s/ Steven H. Osber
Steven H. Osber, Esq.
CE
Fla. Bar No.: 086088
A
T
O
N
Preview
Filing # 82595609 E-Filed 12/27/2018 01:10:09 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. PY YEFIM KOZA & EFN INVESTMENTS LLC, a Florida Limited Liability Company, CO Defendant(s). ________________________ I D NOTICE OF INTENT TO SERVE SUBPOENA PURSUANT TO FLORIDA RULE OF IE CIVIL PROCEDURE 1.351 FOR DOCUMENTS AND THINGS WITHOUT DEPOSITION IF RT YOU ARE HEREBY NOTIFIED that after 10 days from the date of service of this Notice, and if no objection is received from any party, the undersigned will issue or apply to the Clerk of CE this Court for issuance of the attached subpoena directed to: 1. Sedgwick Claims Management Services, Inc. A who is not a party to this action, to produce the items at the time and place specified in the attached T subpoenas. O N [CERTIFICATE OF SERVICE ON FOLLOWING PAGE] FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/27/2018 01:10:09 PM CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E-mail on December 27, 2018, to Maria Abellon, Esquire, 2119 South Dixie Highway, Building II, West Palm Beach, FL 33401, Maria@abellonlaw.com, Court@abellonlaw.com; clerk@abellonlaw.com and J. Freddy Rhoads, Esquire, 6701 S. Dixie Highway, West Palm Beach, FL 33405; freddy@rhoadslawgroup.com; assistant! @rhoadslawgroup.com PY CONRAD & SCHERER, LLP CO Counselfor Defendants 633 South Federal Highway Fort Lauderdale, FL 33301 Tel: (954) 847-3305 D Fax: (954) 463-9244 Email: sosber@conradscherer.com IE Email: Lmananzan@conradscherer.com By: /s/ Steven H. Osber IF Steven H. Osber, Esq. Fla. Bar No.: 086088 RT CE A T O N IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2016CA009367 UWADIAE B. OMOREGIE, Plaintiff, vs. PY YEFIM KOZA & EFN INVESTMENTS LLC, a Florida Limited Liability Company, CO Defendant(s). _________________________ I SUBPOENA DUCES TECUM WITHOUT DEPOSITION D (MAIL IN RECORDS ONLY) THE STATE OF FLORIDA: IE IF TO: RECORDS CUSTODIAN Sedgwick Claims Management Services, Inc. c/o C T Corporation System, Registered Agent RT 1200 South Pine Island Road Plantation, FL 33324 CE YOU ARE HEREBY COMMANDED to produce to STEVEN H. OSBER ESQ., CONRAD & SCHERER, LLP, 633 South Federal Highway, 8th Floor, Fort Lauderdale, FL 33301 within 10 days of receipt of this Subpoena and to have with you at that time and place the following regarding the named individual: A Provide your complete WORKERS’ COMPENSATION FILE, including but not limited T to electronic records, any and all records for any and all dates, statements, industrial commission filings and documents, notes, memoranda, telephone call slips or records, letters and other O correspondence, accounting sheets and ledgers, vouchers, canceled checks or check copies, and N medical records and reports, payroll and payout sheets and ledgers, relating to any and all accidents, injuries, bodily injury claims and WORKERS COMPENSATION CLAIMS. Include all documents specifically referenced in any attachment. Include all records from all departments, including CD and/or DVD files pertaining to: UWADIAE B. OMOREGIE, DOB: xx/xx/1985, SSN: Employer: Coca Cola. *YOU NEED NOT APPEAR IF REQUESTED RECORDS ARE MAILED IN PRIOR TO THE DEPOSITION DATE. 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 giving 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 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 may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. If you fail to appear as specified; or 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 PY 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. CO DATED this day of January 2019 CONRAD & SCHERER, LLP D Counselfor Defendants 633 South Federal Highway IE Fort Lauderdale, FL 33301 Tel: (954) 847-3305 IF Fax: (954) 463-9244 Email: sosber@conradscherer.com RT Email: Lmananzan@conradscherer.com By: /s/ Steven H. Osber Steven H. Osber, Esq. CE Fla. Bar No.: 086088 A T O N