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Filing # 148985320 E-Filed 05/04/2022 08:39:37 PM
RETURN OF SERVICE
State of Florida County of Osceola Circuit Court
Case Number: 2018-CA-993 Court Date: 5/9/2022 9:00 am
Plaintiff: FREDDIE LUCAS,
vs. LDK2022004880
Defendants: JOSE LAZARO PAEZ & TARMAC AMERICA, LLC,
For:
Daniel Morgan, Esq
Morgan & Morgan, P.A.*
20 N. Orange Avenue
Suite 1600
Orlando, FL 32801
Received by KNOPF INVESTIGATIONS,INC on the 2nd day of May, 2022 at 2:57 pm to be served on
Andrew Messer, M.D., c/o MCPB Orthopedics & Neurosurgery, 904 WEST MAGNOLIA STREET,
KISSIMMEE, FL 34741.
I, JAMES DON BARNES, do hereby affirm that on the 3rd day of May, 2022 at 8:38 am, I:
INDIVIDUALLY/PERSONALLY served by delivering a true copy of the SUBPOENA LETTER and
SUBPOENA FOR TRIAL (Duces Tecum) with EXHIBIT A with the date and hour of service endorsed
thereon by me, to: Andrew Messer, M.D. at the address of: 1310 GULF BLVD UNIT 2G, CLEARWATER
BEACH, FL 34767, and informed said person of the contents therein, in compliance with state statutes.
Military Status: Based upon inquiry of party served, Defendant is not in the military service of the
United States of America.
Marital Status: Based upon inquiry of party served, Defendant is married.
I certify that I am over the age of 18, have no interest in the above action, and am a Appointed Process
Server, in good standing, in the judicial circuit in which the process was served. Signed under the
penalties of perjury, I declare that I have read the foregoing return of service and that the facts stated in
it are true; NO NOTARY REQUIRED PURSUANT TO F.S. 92.525 (2)
JAMES DON BARNES
APS 26275
KNOPF INVESTIGATIONS,INC
P.O. BOX 560856
ROCKLEDGE, FL 32956-0856
(321) 373-1245
Our Job Serial Number: LDK-2022004880
Ref: 7761825
Copyright © 1992-2022 Database Services, Inc. - Process Server's Toolbox V8.2c
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2018-CA-993
FREDDIE LUCAS,
Plaintiff, 5/3/2022 8:38 AM
vs. JDB 26275
JOSE LAZARO PAEZ &
TARMAC AMERICA, LLC,
Defendants. /
SUBPOENA FOR TRIAL
(Duces Tecum)
TO: Andrew Messer, M.D.
c/o MCPB Orthopedics & Neurosurgery
904 West Magnolia Street
Kissimmee, FL 34741
YOU ARE HEREBY COMMANDED to appear before the Honorable Robert J. Egan,
Judge of the Circuit Court at OSCEOLA COUNTY COURTHOUSE, 2 COURTHOUSE
SQUARE, KISSIMMEE, FL 34741, on Monday, May 9, 2022, at 9:00 a.m., until Friday, May
27, 2022 to testify in this action. If you fail to appear, 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.
YOU ARE TO HAVE WITH YOU at the time, date and place aforesaid, the documents
outlined in Exhibit A, attached hereto.
IF YOU HAVE ANY QUESTIONS, PLEASE CALL BRITTNEY TORRES AT (407) 839-
4448 OR VIA EMAIL AT BTORRES@FORTHEPEOPLE.COM. HOWEVER, YOU
ARE EXPECTED TO APPEAR IN COURT AT THE OSCEOLA COUNTY
COURTHOUSE, 2 COURTHOUSE SQUARE, KISSIMMEE, FL 34741. AT THE ABOVE
DATE AND TIME TO PROVIDE TRIAL TESTIMONY.
1
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REQUESTS FOR ACCOMMODATIONS BY PERSONS WITH DISABILITIES
If you are a person with a disability who needs any accommodation in order to participate in
this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please
contact the ADA Coordinator, Human Resources, OSCEOLA COUNTY COURTHOUSE, 2
COURTHOUSE SQUARE, KISSIMMEE, FL 34741, at least 7 days before your scheduled court
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.
WITNESS my hand and seal of said Court.
DATED this 27th day of April, 2022.
________________________________________
FBN 0121412
Morgan & Morgan, P.A.
20 N. Orange Avenue, Suite 1600
Telephone: (407) 420-1414
Facsimile: (407) 641-5846
dmorgan@forthepeople.com
vvazquez@forthepeople.com
btorres@forthepeople.com
Counsel for Plaintiff
2
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EXHIBIT A
1. Any and all documents, records and papers generated by you, received by you, or in your
possession pertaining to the claims or defenses asserted in this lawsuit.
2. Your current C.V. or resume.
3. All documents, materials and reference sources upon which you relied in rendering any
expert opinion in this lawsuit.
4. All documents and materials and reference sources which you considered, but did not
rely on, in reaching any expert opinion in this lawsuit.
5. All notes and calculations that support any expert opinions you have developed in this
lawsuit.
6. Your current fee schedule.
7. Your entire file in this case, including any communication that defines or outlines the
requested task or service you were to perform in this case.
8. Your current Rule 26 disclosures including, but not limited to, a list of all cases in which
you testified as an expert either at trial or at deposition in the last two years.
9. Your documents and records reflecting your scope of employment in this lawsuit and
your compensation for such service, including but not limited to engagement letters or
contracts, time records, billing records, and income and expense records.
10. All records reflecting your general litigation experience, including the percentage of work
performed for plaintiffs and for defendants.
11. All records of contact between you (and any or your agents or employees) and
Defendants’ attorneys of record, their law firms (and those law firms’ agents or
employees), for the past three years.
12. All records reflecting the extent of your work as an expert witness (as opposed to all
other professional endeavors) whether based on number of hours, percentage of hours, or
percentage of earned income derived from serving as an expert witness.
3
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Filing # 148985320 E-Filed 05/04/2022 08:39:37 PM RETURN OF SERVICE State of Florida County of Osceola Circuit Court Case Number: 2018-CA-993 Court Date: 5/9/2022 9:00 am Plaintiff: FREDDIE LUCAS, vs. LDK2022004880 Defendants: JOSE LAZARO PAEZ & TARMAC AMERICA, LLC, For: Daniel Morgan, Esq Morgan & Morgan, P.A.* 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 Received by KNOPF INVESTIGATIONS,INC on the 2nd day of May, 2022 at 2:57 pm to be served on Andrew Messer, M.D., c/o MCPB Orthopedics & Neurosurgery, 904 WEST MAGNOLIA STREET, KISSIMMEE, FL 34741. I, JAMES DON BARNES, do hereby affirm that on the 3rd day of May, 2022 at 8:38 am, I: INDIVIDUALLY/PERSONALLY served by delivering a true copy of the SUBPOENA LETTER and SUBPOENA FOR TRIAL (Duces Tecum) with EXHIBIT A with the date and hour of service endorsed thereon by me, to: Andrew Messer, M.D. at the address of: 1310 GULF BLVD UNIT 2G, CLEARWATER BEACH, FL 34767, and informed said person of the contents therein, in compliance with state statutes. Military Status: Based upon inquiry of party served, Defendant is not in the military service of the United States of America. Marital Status: Based upon inquiry of party served, Defendant is married. I certify that I am over the age of 18, have no interest in the above action, and am a Appointed Process Server, in good standing, in the judicial circuit in which the process was served. Signed under the penalties of perjury, I declare that I have read the foregoing return of service and that the facts stated in it are true; NO NOTARY REQUIRED PURSUANT TO F.S. 92.525 (2) JAMES DON BARNES APS 26275 KNOPF INVESTIGATIONS,INC P.O. BOX 560856 ROCKLEDGE, FL 32956-0856 (321) 373-1245 Our Job Serial Number: LDK-2022004880 Ref: 7761825 Copyright © 1992-2022 Database Services, Inc. - Process Server's Toolbox V8.2c IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2018-CA-993 FREDDIE LUCAS, Plaintiff, 5/3/2022 8:38 AM vs. JDB 26275 JOSE LAZARO PAEZ & TARMAC AMERICA, LLC, Defendants. / SUBPOENA FOR TRIAL (Duces Tecum) TO: Andrew Messer, M.D. c/o MCPB Orthopedics & Neurosurgery 904 West Magnolia Street Kissimmee, FL 34741 YOU ARE HEREBY COMMANDED to appear before the Honorable Robert J. Egan, Judge of the Circuit Court at OSCEOLA COUNTY COURTHOUSE, 2 COURTHOUSE SQUARE, KISSIMMEE, FL 34741, on Monday, May 9, 2022, at 9:00 a.m., until Friday, May 27, 2022 to testify in this action. If you fail to appear, 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. YOU ARE TO HAVE WITH YOU at the time, date and place aforesaid, the documents outlined in Exhibit A, attached hereto. IF YOU HAVE ANY QUESTIONS, PLEASE CALL BRITTNEY TORRES AT (407) 839- 4448 OR VIA EMAIL AT BTORRES@FORTHEPEOPLE.COM. HOWEVER, YOU ARE EXPECTED TO APPEAR IN COURT AT THE OSCEOLA COUNTY COURTHOUSE, 2 COURTHOUSE SQUARE, KISSIMMEE, FL 34741. AT THE ABOVE DATE AND TIME TO PROVIDE TRIAL TESTIMONY. 1 You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdf.com) REQUESTS FOR ACCOMMODATIONS BY PERSONS WITH DISABILITIES If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator, Human Resources, OSCEOLA COUNTY COURTHOUSE, 2 COURTHOUSE SQUARE, KISSIMMEE, FL 34741, at least 7 days before your scheduled court 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. WITNESS my hand and seal of said Court. DATED this 27th day of April, 2022. ________________________________________ FBN 0121412 Morgan & Morgan, P.A. 20 N. Orange Avenue, Suite 1600 Telephone: (407) 420-1414 Facsimile: (407) 641-5846 dmorgan@forthepeople.com vvazquez@forthepeople.com btorres@forthepeople.com Counsel for Plaintiff 2 You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdf.com) EXHIBIT A 1. Any and all documents, records and papers generated by you, received by you, or in your possession pertaining to the claims or defenses asserted in this lawsuit. 2. Your current C.V. or resume. 3. All documents, materials and reference sources upon which you relied in rendering any expert opinion in this lawsuit. 4. All documents and materials and reference sources which you considered, but did not rely on, in reaching any expert opinion in this lawsuit. 5. All notes and calculations that support any expert opinions you have developed in this lawsuit. 6. Your current fee schedule. 7. Your entire file in this case, including any communication that defines or outlines the requested task or service you were to perform in this case. 8. Your current Rule 26 disclosures including, but not limited to, a list of all cases in which you testified as an expert either at trial or at deposition in the last two years. 9. Your documents and records reflecting your scope of employment in this lawsuit and your compensation for such service, including but not limited to engagement letters or contracts, time records, billing records, and income and expense records. 10. All records reflecting your general litigation experience, including the percentage of work performed for plaintiffs and for defendants. 11. All records of contact between you (and any or your agents or employees) and Defendants’ attorneys of record, their law firms (and those law firms’ agents or employees), for the past three years. 12. All records reflecting the extent of your work as an expert witness (as opposed to all other professional endeavors) whether based on number of hours, percentage of hours, or percentage of earned income derived from serving as an expert witness. 3 You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdf.com)