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Filing # 185546810 E-Filed 11/06/2023 02:21:06 PM
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintiff(s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION.
Defendant(s).
/
DEFENDANT’S NOTICE OF PRODUCTION
FROM NON-PARTIES
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service, via
email, and if no objection is received, the undersigned will issue or apply to the clerk of this court
for issuance of the attached subpoenas with Exhibit “A” Declaration of Custodian of Records
directed to:
Akumin, Corp.
Alpha Medicine and Rehab
Blackfin Medical, LLC
Central Palm Beach Surgery Center
Department of Orthopaedic Surgery and Sports Medicine
Fyzical Therapy and Balance Center, LLC
INJURY PHARMACY SOLUTIONS LLC
Orthopaedics and Sports Medicine
PBO Spine and Orthopedic Specialists of South Florida
Punta Gorda Police Department
Radiology Regional Center, PA
RejuvenX Accident Medical Center
Tampa General Hospital
Tower Radiology Center
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 6, 2023, I electronically filed the foregoing with
the Clerk of the Court by using the Florida Courts E-filing Portal, which will send a Notice of
Service of Court Documents to James Moon, Esquire, at the following designated email address:
jmoon@forthepeople.com.
/s/ Raul Loredo
Raul Loredo, Esquire
Florida Bar Number: 571342
Email: NapCrtPleadings@wickersmith.com
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
EXHIBIT “A” DECLARATION OF CUSTODIAN OF RECORDS
NOTE TO RECORDS CUSTODIAN: THIS COMPLETED EXHIBIT ALONG WITH THE
SUBPOENA SERVED SHOULD BE INCLUDED WITH ANY AND ALL RESPONSES.
Records of: Fionnualah Ann Carroll DOB:
AKA SSN:
Medical @ pages attached Billing Records @ pages attached
Records Digital Records (CD) attached Digital Records (CD) attached
No record found/not a patient. No record found/not a patient.
Record destroyed. Record destroyed.
Radiology (@ films sheets attached Other Records @ pages attached
Records Digital Records (CD) attached Digital Records (CD) attached
No record found/not a patient. No record found/not a patient.
a Record destroyed. a Record destroyed.
I, the undersigned, hereby declare under penalty
of perjury that the following statement(s) is/are true to the best of my knowledge and
belief. I, the undersigned, am over the age of 18, and I am the duly authorized custodian of the records or other qualified witness and
have authority to certify the records. The copy is a true copy of ail the records described in the Subpoena Duces Tecum. The records
were delivered to the attorney, the attorneys’ representative, or deposition officer for copying at the custodian's or witness's place of
business, as the case may be. The records were prepared bythe personnel of the business in the ordinary course and scope of business.
Ihave delivered all of the records and/or items requested, or, have made a diligent search for the records and none were found, or,
Tam no longer the custodian of the records (the custodian is (name/address/telephone number)
Said records were prepared by me or another qualified witness testifying to its identity and the mode of its preparation during the
ordinary course and scope of business at or near the time of the act, condition or event.
Executed on:
Date Signature of Records Custodian
Print name:
STATE OF FLORIDA
COUNTY OF
The foregoing instrument was acknowledged before me by means of O physical presence or 1] online notarization this
day of , 2023 by
. who is personally known to me or who has produced
(Name of Person Acknowledging)
as identification.
(Type of Identification)
(Signature of person taking acknowledgement)
(Name typed, printed or stamped)
(Title or rank)
(Serial number, if any)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Akumin, Corp.
c/o Legaline Corporate Services, Inc. 10601 Clarence Dr., Suite 250
Frisco, tx 33966
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403.
BRO! IOMALL, PA 19008, and to have with you the following:
Please provide a copy of all medical records, billing records, insurance records and
payment records including itemized billing ledgers/payouts, intake reports or notes, charts,
diagrams, documents, papers, correspondence, memoranda, emergency room reports, all
films and/or radiological studies and all other records or reports in your possession, custody
r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide
complete radiolo: inventor if available) before sending any films or studies.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Alpha Medicine and Rehab
2915 Colonial Blvd. S, Suite 220 ,
Fort Myers, FL 33966
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403.
BRO! IOMALL, PA 19008, and to have with you the following:
Please provide a copy of all medical records, billing records, insurance records and
payment records including itemized billing ledgers/payouts, intake reports or notes, charts,
diagrams, documents, papers, correspondence, memoranda, emergency room reports, all
films and/or radiological studies and all other records or reports in your possession, custody
r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide
complete radiolo: inventor if available) before sending any films or studies.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Blackfin Medical, LLC
6415 Lake Worth Rd, #102
Lake Worth, FL 33463
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403.
BRO! IOMALL, PA 19008, and to have with you the following:
Please provide a copy of all medical records, billing records, insurance records and
payment records including itemized billing ledgers/payouts, intake reports or notes, charts,
diagrams, documents, papers, correspondence, memoranda, emergency room reports, all
films and/or radiological studies and all other records or reports in your possession, custody
r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide
complete radiolo: inventor if available) before sending any films or studies.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Central Palm Beach Surgery Center
2047 Palm Beach Lakes Boulevard Suite 100
West Palm Beach, FL 33409
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403.
BRO! IOMALL, PA 19008, and to have with you the following:
Please provide a copy of all medical records, billing records, insurance records and
payment records including itemized billing ledgers/payouts, intake reports or notes, charts,
diagrams, documents, papers, correspondence, memoranda, emergency room reports, all
films and/or radiological studies and all other records or reports in your possession, custody
r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide
complete radiolo: inventor if available) before sending any films or studies.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Department of Orthopaedic Surgery and Sports Medicine
3450 Hull Road
Gainesville, FL 32607
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403.
BRO! IOMALL, PA 19008, and to have with you the following:
Please provide a copy of all medical records, billing records, insurance records and
payment records including itemized billing ledgers/payouts, intake reports or notes, charts,
diagrams, documents, papers, correspondence, memoranda, emergency room reports, all
films and/or radiological studies and all other records or reports in your possession, custody
r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide
complete radiolo: inventor if available) before sending any films or studies.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Fyzical Therapy and Balance Center, LLC
257 North Orlando Avenue
Cocoa Beach, FL 32931
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403.
BRO! IOMALL, PA 19008, and to have with you the following:
Please provide a copy of all medical records, billing records, insurance records and
payment records including itemized billing ledgers/payouts, intake reports or notes, charts,
diagrams, documents, papers, correspondence, memoranda, emergency room reports, all
films and/or radiological studies and all other records or reports in your possession, custody
r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide
complete radiolo: inventor if available) before sending any films or studies.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: INJURY PHARMACY SOLUTIONS LLC
11352 West State Road 84
Davie, FL 33325
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403.
BRO! IOMALL, PA 19008, and to have with you the following:
Please_provide_a_copy_of_all_pharmacy_records, medical_bills, prescriptions,
instructions and doctor's orders pertaining to Fionnualah Ann Carroll from xx/xx/1957 to
present.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Orthopaedics and Sports Medicine
13330 USF Laurel Drive
Tampa, FL 33612
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403.
BRO! IOMALL, PA 19008, and to have with you the following:
Please provide a copy of all medical records, billing records, insurance records and
payment records including itemized billing ledgers/payouts, intake reports or notes, charts,
diagrams, documents, papers, correspondence, memoranda, emergency room reports, all
films and/or radiological studies and all other records or reports in your possession, custody
r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide
complete radiolo: inventor if available) before sending any films or studies.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: PBO Spine and Orthopedic Specialists of South Florida
2047 Palm Beach Lakes Boulevard Suite 100
West Palm Beach, FL 33409
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403.
BRO! IOMALL, PA 19008, and to have with you the following:
Please provide a copy of all medical records, billing records, insurance records and
payment records including itemized billing ledgers/payouts, intake reports or notes, charts,
diagrams, documents, papers, correspondence, memoranda, emergency room reports, all
films and/or radiological studies and all other records or reports in your possession, custody
r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide
complete radiolo: inventor if available) before sending any films or studies.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Punta Gorda Police Department
1410 Tamiami Trail
Punta Gorda, FL 33950
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403
BRO! IOMALL, PA 19008, and to have with you the following:
Any and all records, police report, laser copies of photographs, memoranda, and all
investigation notes and any and all other reports and records regarding Fionnualah Ann
Carroll: XX/XX/1963.
Fionnualah Ann Carroll
DATE OF BIRTH: **/**/1957
These items will be inspected and may be copied at that time. You will not be
required to surrender the original items. **You may condition the preparation of the copies upon
the payment in advance of the reasonable cost of preparation.** YOU may comply with this
subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL
RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008;
(888) 519-8565, the agent of the attorney whose name appears on this subpoena on or before the
scheduled date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall respond to this subpoena as directed.
If the subpoena is complied with by delivery or mailing of copies as provided, the
undersigned attorney shall furnish a legible copy of each item furnished to any other party who
requests it upon the payment of the reasonable cost of preparing the copies.
HIPAA NOTICE
This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) &
(iii), a part of the federal regulations governing the administration of the Federal Health Insurance
Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has
provided written notice to the patient in question by e-mail to the patient’s attorney, along with a
copy of this subpoena at least ten (10) days before its service upon you. The time for objection to
this subpoena (10 days) has elapsed and no objections have been filed.
DATED on this day of » 2023.
Raul Loredo, Esquire
Florida Bar Number: 571342
Email:
Wicker Smith O'Hara McCoy & Ford, PA - Naples
9132 Strada Place
Naples, FL 34108
Phone: (239) 552-5357
Fax: (239) 552-5399
Attorneys for Defendant(s)
IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
SEAN EDWARD CARROLL and Case No. 23000568CA
FIONNUALAH ANN CARROLL,
Plaintifi{s),
V.
RICHARD W. NORTON and UNITED
SERVICES AUTOMOBILE ASSOCIATION,
Defendant(s).
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Punta Gorda Police Department
1410 Tamiami Trail
Punta Gorda, FL 33950
YOU ARE HEREBY COMMANDED to appear at or mail the below requested records
to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403
BRO! IOMALL, PA 19008, and to have with you the following:
Any and all records, police report, laser copies of photographs, memoranda, and all
investigation notes and any and all other reports and records regarding Sean Edward Carroll
DOB: XX/XX/1963.
You must produce a complete set of documents, including, but not limited to, items
such as insurance documents, log sheets, “Explanation of Benefits” from insurance
companies, payment sheets, and any and all information that is stored electronically and
registration forms. Literally copy your entire file from cover to cover.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. ** You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by
providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS,
LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-
8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled
date of production, and thereby eliminating your 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.
**Tf the cost of copies exceeds $150.00, please contact American Legal Records before
preparing the copies.
If you fail to comply, you may be in contempt of Court. You are subpoenaed by the
attorneys whose names appear on this subpoena and unless excused from this subpoena by the
attorneys or the Court, you shall
Preview
Filing # 185546810 E-Filed 11/06/2023 02:21:06 PM IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintiff(s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION. Defendant(s). / DEFENDANT’S NOTICE OF PRODUCTION FROM NON-PARTIES YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service, via email, and if no objection is received, the undersigned will issue or apply to the clerk of this court for issuance of the attached subpoenas with Exhibit “A” Declaration of Custodian of Records directed to: Akumin, Corp. Alpha Medicine and Rehab Blackfin Medical, LLC Central Palm Beach Surgery Center Department of Orthopaedic Surgery and Sports Medicine Fyzical Therapy and Balance Center, LLC INJURY PHARMACY SOLUTIONS LLC Orthopaedics and Sports Medicine PBO Spine and Orthopedic Specialists of South Florida Punta Gorda Police Department Radiology Regional Center, PA RejuvenX Accident Medical Center Tampa General Hospital Tower Radiology Center CERTIFICATE OF SERVICE I HEREBY CERTIFY that on November 6, 2023, I electronically filed the foregoing with the Clerk of the Court by using the Florida Courts E-filing Portal, which will send a Notice of Service of Court Documents to James Moon, Esquire, at the following designated email address: jmoon@forthepeople.com. /s/ Raul Loredo Raul Loredo, Esquire Florida Bar Number: 571342 Email: NapCrtPleadings@wickersmith.com Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) EXHIBIT “A” DECLARATION OF CUSTODIAN OF RECORDS NOTE TO RECORDS CUSTODIAN: THIS COMPLETED EXHIBIT ALONG WITH THE SUBPOENA SERVED SHOULD BE INCLUDED WITH ANY AND ALL RESPONSES. Records of: Fionnualah Ann Carroll DOB: AKA SSN: Medical @ pages attached Billing Records @ pages attached Records Digital Records (CD) attached Digital Records (CD) attached No record found/not a patient. No record found/not a patient. Record destroyed. Record destroyed. Radiology (@ films sheets attached Other Records @ pages attached Records Digital Records (CD) attached Digital Records (CD) attached No record found/not a patient. No record found/not a patient. a Record destroyed. a Record destroyed. I, the undersigned, hereby declare under penalty of perjury that the following statement(s) is/are true to the best of my knowledge and belief. I, the undersigned, am over the age of 18, and I am the duly authorized custodian of the records or other qualified witness and have authority to certify the records. The copy is a true copy of ail the records described in the Subpoena Duces Tecum. The records were delivered to the attorney, the attorneys’ representative, or deposition officer for copying at the custodian's or witness's place of business, as the case may be. The records were prepared bythe personnel of the business in the ordinary course and scope of business. Ihave delivered all of the records and/or items requested, or, have made a diligent search for the records and none were found, or, Tam no longer the custodian of the records (the custodian is (name/address/telephone number) Said records were prepared by me or another qualified witness testifying to its identity and the mode of its preparation during the ordinary course and scope of business at or near the time of the act, condition or event. Executed on: Date Signature of Records Custodian Print name: STATE OF FLORIDA COUNTY OF The foregoing instrument was acknowledged before me by means of O physical presence or 1] online notarization this day of , 2023 by . who is personally known to me or who has produced (Name of Person Acknowledging) as identification. (Type of Identification) (Signature of person taking acknowledgement) (Name typed, printed or stamped) (Title or rank) (Serial number, if any) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Akumin, Corp. c/o Legaline Corporate Services, Inc. 10601 Clarence Dr., Suite 250 Frisco, tx 33966 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403. BRO! IOMALL, PA 19008, and to have with you the following: Please provide a copy of all medical records, billing records, insurance records and payment records including itemized billing ledgers/payouts, intake reports or notes, charts, diagrams, documents, papers, correspondence, memoranda, emergency room reports, all films and/or radiological studies and all other records or reports in your possession, custody r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide complete radiolo: inventor if available) before sending any films or studies. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Alpha Medicine and Rehab 2915 Colonial Blvd. S, Suite 220 , Fort Myers, FL 33966 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403. BRO! IOMALL, PA 19008, and to have with you the following: Please provide a copy of all medical records, billing records, insurance records and payment records including itemized billing ledgers/payouts, intake reports or notes, charts, diagrams, documents, papers, correspondence, memoranda, emergency room reports, all films and/or radiological studies and all other records or reports in your possession, custody r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide complete radiolo: inventor if available) before sending any films or studies. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Blackfin Medical, LLC 6415 Lake Worth Rd, #102 Lake Worth, FL 33463 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403. BRO! IOMALL, PA 19008, and to have with you the following: Please provide a copy of all medical records, billing records, insurance records and payment records including itemized billing ledgers/payouts, intake reports or notes, charts, diagrams, documents, papers, correspondence, memoranda, emergency room reports, all films and/or radiological studies and all other records or reports in your possession, custody r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide complete radiolo: inventor if available) before sending any films or studies. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Central Palm Beach Surgery Center 2047 Palm Beach Lakes Boulevard Suite 100 West Palm Beach, FL 33409 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403. BRO! IOMALL, PA 19008, and to have with you the following: Please provide a copy of all medical records, billing records, insurance records and payment records including itemized billing ledgers/payouts, intake reports or notes, charts, diagrams, documents, papers, correspondence, memoranda, emergency room reports, all films and/or radiological studies and all other records or reports in your possession, custody r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide complete radiolo: inventor if available) before sending any films or studies. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Department of Orthopaedic Surgery and Sports Medicine 3450 Hull Road Gainesville, FL 32607 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403. BRO! IOMALL, PA 19008, and to have with you the following: Please provide a copy of all medical records, billing records, insurance records and payment records including itemized billing ledgers/payouts, intake reports or notes, charts, diagrams, documents, papers, correspondence, memoranda, emergency room reports, all films and/or radiological studies and all other records or reports in your possession, custody r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide complete radiolo: inventor if available) before sending any films or studies. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Fyzical Therapy and Balance Center, LLC 257 North Orlando Avenue Cocoa Beach, FL 32931 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403. BRO! IOMALL, PA 19008, and to have with you the following: Please provide a copy of all medical records, billing records, insurance records and payment records including itemized billing ledgers/payouts, intake reports or notes, charts, diagrams, documents, papers, correspondence, memoranda, emergency room reports, all films and/or radiological studies and all other records or reports in your possession, custody r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide complete radiolo: inventor if available) before sending any films or studies. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: INJURY PHARMACY SOLUTIONS LLC 11352 West State Road 84 Davie, FL 33325 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403. BRO! IOMALL, PA 19008, and to have with you the following: Please_provide_a_copy_of_all_pharmacy_records, medical_bills, prescriptions, instructions and doctor's orders pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Orthopaedics and Sports Medicine 13330 USF Laurel Drive Tampa, FL 33612 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403. BRO! IOMALL, PA 19008, and to have with you the following: Please provide a copy of all medical records, billing records, insurance records and payment records including itemized billing ledgers/payouts, intake reports or notes, charts, diagrams, documents, papers, correspondence, memoranda, emergency room reports, all films and/or radiological studies and all other records or reports in your possession, custody r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide complete radiolo: inventor if available) before sending any films or studies. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: PBO Spine and Orthopedic Specialists of South Florida 2047 Palm Beach Lakes Boulevard Suite 100 West Palm Beach, FL 33409 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403. BRO! IOMALL, PA 19008, and to have with you the following: Please provide a copy of all medical records, billing records, insurance records and payment records including itemized billing ledgers/payouts, intake reports or notes, charts, diagrams, documents, papers, correspondence, memoranda, emergency room reports, all films and/or radiological studies and all other records or reports in your possession, custody r control pertaining to Fionnualah Ann Carroll from xx/xx/1957 to present. Please provide complete radiolo: inventor if available) before sending any films or studies. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Punta Gorda Police Department 1410 Tamiami Trail Punta Gorda, FL 33950 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403 BRO! IOMALL, PA 19008, and to have with you the following: Any and all records, police report, laser copies of photographs, memoranda, and all investigation notes and any and all other reports and records regarding Fionnualah Ann Carroll: XX/XX/1963. Fionnualah Ann Carroll DATE OF BIRTH: **/**/1957 These items will be inspected and may be copied at that time. You will not be required to surrender the original items. **You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519-8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. If the subpoena is complied with by delivery or mailing of copies as provided, the undersigned attorney shall furnish a legible copy of each item furnished to any other party who requests it upon the payment of the reasonable cost of preparing the copies. HIPAA NOTICE This notice is provided pursuant to 45 Code of Federal Regulations, §164.512(e)(1)(ii) & (iii), a part of the federal regulations governing the administration of the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA). The attorney who issued this subpoena has provided written notice to the patient in question by e-mail to the patient’s attorney, along with a copy of this subpoena at least ten (10) days before its service upon you. The time for objection to this subpoena (10 days) has elapsed and no objections have been filed. DATED on this day of » 2023. Raul Loredo, Esquire Florida Bar Number: 571342 Email: Wicker Smith O'Hara McCoy & Ford, PA - Naples 9132 Strada Place Naples, FL 34108 Phone: (239) 552-5357 Fax: (239) 552-5399 Attorneys for Defendant(s) IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION SEAN EDWARD CARROLL and Case No. 23000568CA FIONNUALAH ANN CARROLL, Plaintifi{s), V. RICHARD W. NORTON and UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant(s). / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Punta Gorda Police Department 1410 Tamiami Trail Punta Gorda, FL 33950 YOU ARE HEREBY COMMANDED to appear at or mail the below requested records to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403 BRO! IOMALL, PA 19008, and to have with you the following: Any and all records, police report, laser copies of photographs, memoranda, and all investigation notes and any and all other reports and records regarding Sean Edward Carroll DOB: XX/XX/1963. You must produce a complete set of documents, including, but not limited to, items such as insurance documents, log sheets, “Explanation of Benefits” from insurance companies, payment sheets, and any and all information that is stored electronically and registration forms. Literally copy your entire file from cover to cover. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. ** You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation.** YOU may comply with this subpoena by providing legible copies of the items to be produced to AMERICAN LEGAL RECORDS, LOCATED AT 1974 SPROUL ROAD, SUITE 403, BROOMALL, PA 19008; (888) 519- 8565, the agent of the attorney whose name appears on this subpoena on or before the scheduled date of production, and thereby eliminating your 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. **Tf the cost of copies exceeds $150.00, please contact American Legal Records before preparing the copies. If you fail to comply, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall