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Filing # 188785734 E-Filed 12/28/2023 03:01:17 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2023 CA 003739 MP
DARLENE DANIELA ESCALANTE,
Plaintiff,
vs.
ADVENTIST HEALTH SYSTEM/SUNBELT,
INC. D/B/A ADVENTHEALTH KISSIMMEE,
FLORIDA HOSPITAL MEDICAL GROUP,
INC. D/B/A RADIOLOGY SPECIALISTS OF
FLORIDA, FLORIDA RADIOLOGY IMAGING
AT LAKE MARY, LLC D/B/A
ADVENTHEALTH IMAGING LAKE NONA,
FLORIDA HOSPITAL MEDICAL GROUP,
INC. D/B/A ADVENTHEALTH MEDICAL
GROUP, AND CHRISTOPHER JOHN
SMITH, M.D.,
Defendant.
___________________________________/
NOTICE OF PRODUCTION FROM NON-PARTIES
TO: All Counsel of Record
YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice
of Production from Non-Parties by mail, and if no objection is received from any party, the
undersigned will issue the attached subpoenas directed to the Records Custodian for the
following entities:
Mindful Behavioral Healthcare
717 East Oak Street
Kissimmee, FL 34744
who are not parties to this lawsuit, to produce the items listed at the time and place
specified in the Subpoena.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on December 28, 2023, the foregoing was e-mailed to the
following: Mariano Garcia, Searcy, Denney, Scarola, Barnhart & Shipley, P.A.,2139 Palm
Beach Lakes Blvd., West Palm Beach, FL 33409, (mxg@searcylaw.com) Attorneys for
Plaintiff; Beytin, John W. Bocchino, McLaughlin, McLaughlin, O'Hara, Kinman &
Bocchino, P.A., 1063 Maitland Center Commons Blvd., Maitland, FL 32751, (jwb@law-
fla.com).
s/CRAIG S. FOELS
CRAIG S. FOELS
Florida Bar No.: 880868
Primary Email: csf@eifg-law.com
Secondary Email: dac@eifg-law.com
cf@eifg-law.com;
nld@eifg-law.com
ESTES, INGRAM, FOELS & GIBBS, P.A.
2600 Lake Lucien Drive, Suite 330
Maitland, FL 32751
(407) 481-9449
Attorneys for CHRISTOPHER JOHN SMITH,
M.D., ADVENTHEALTH MEDICAL GROUP,
FLORIDA RADIOLOGY IMAGING AT LAKE
MARY, LLC D/B/A ADVENTHEALTH
IMAGING LAKE NONA
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2023 CA 003739 MP
DARLENE DANIELA ESCALANTE ,
Plaintiff,
vs.
ADVENTIST HEALTH SYSTEM/SUNBELT,
INC. D/B/A ADVENTHEALTH KISSIMMEE,
FLORIDA HOSPITAL MEDICAL GROUP,
INC. D/B/A RADIOLOGY SPECIALISTS OF
FLORIDA, FLORIDA RADIOLOGY IMAGING
AT LAKE MARY, LLC D/B/A
ADVENTHEALTH IMAGING LAKE NONA,
FLORIDA HOSPITAL MEDICAL GROUP,
INC. D/B/A ADVENTHEALTH MEDICAL
GROUP, AND CHRISTOPHER JOHN
SMITH, M.D.,
Defendant.
___________________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
for records only
THE STATE OF FLORIDA:
TO: Records Custodian for
Mindful Behavioral Healthcare
717 East Oak Street
Kissimmee, FL 34744
YOU ARE COMMANDED to furnish to Dinelia A. Concepcion, Estes, Ingram,
Foels & Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32751, within ten
(10) days following receipt of this Subpoena, the following:
Any and all office notes, charts, doctors' reports, x-rays, records,
nurses' notes, admission and discharge summaries, and any and all
other medical, psychological, psychiatric, hospital or emergency
room records of any kind or nature whatsoever regarding DARLENE
ESCALANTE. (See attached correspondence for patient's date of birth
and Social Security number.)
These items will be inspected and may be copied at that time. You will not be
required to surrender the original items.
You may comply with this subpoena by providing legible copies of the items to be
produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the
copies to the attorney whose name appears on this subpoena. You have the right to
object to the production pursuant to this subpoena at any time before production by giving
written notice to the attorney whose name appears on this subpoena. THIS WILL NOT
BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
If you fail to:
(1) furnish the records as provided above; or
(2) object to this subpoena,
you may be in contempt of court. You are subpoenaed by the following attorney to
produce the above-requested records, and unless excused from this subpoena by this
attorney or the court, you shall respond to this subpoena as directed.
DATED this _____ day of ___________________, 20____.
Dinelia A. Concepcion
For the Court
Attorney for FLORIDA RADIOLOGY IMAGING AT LAKE MARY, LLC D/B/A
ADVENTHEALTH IMAGING LAKE NONA, FLORIDA HOSPITAL MEDICAL GROUP,
INC. D/B/A ADVENTHEALTH MEDICAL GROUP, AND CHRISTOPHER JOHN SMITH,
M.D.
ESTES, INGRAM, FOELS & GIBBS, P.A.
2600 Lake Lucien Drive, Suite 330
Maitland, FL 32751
(407) 481-9449
Florida Bar No. 104953
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Filing # 188785734 E-Filed 12/28/2023 03:01:17 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2023 CA 003739 MP DARLENE DANIELA ESCALANTE, Plaintiff, vs. ADVENTIST HEALTH SYSTEM/SUNBELT, INC. D/B/A ADVENTHEALTH KISSIMMEE, FLORIDA HOSPITAL MEDICAL GROUP, INC. D/B/A RADIOLOGY SPECIALISTS OF FLORIDA, FLORIDA RADIOLOGY IMAGING AT LAKE MARY, LLC D/B/A ADVENTHEALTH IMAGING LAKE NONA, FLORIDA HOSPITAL MEDICAL GROUP, INC. D/B/A ADVENTHEALTH MEDICAL GROUP, AND CHRISTOPHER JOHN SMITH, M.D., Defendant. ___________________________________/ NOTICE OF PRODUCTION FROM NON-PARTIES TO: All Counsel of Record YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice of Production from Non-Parties by mail, and if no objection is received from any party, the undersigned will issue the attached subpoenas directed to the Records Custodian for the following entities: Mindful Behavioral Healthcare 717 East Oak Street Kissimmee, FL 34744 who are not parties to this lawsuit, to produce the items listed at the time and place specified in the Subpoena. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 28, 2023, the foregoing was e-mailed to the following: Mariano Garcia, Searcy, Denney, Scarola, Barnhart & Shipley, P.A.,2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, (mxg@searcylaw.com) Attorneys for Plaintiff; Beytin, John W. Bocchino, McLaughlin, McLaughlin, O'Hara, Kinman & Bocchino, P.A., 1063 Maitland Center Commons Blvd., Maitland, FL 32751, (jwb@law- fla.com). s/CRAIG S. FOELS CRAIG S. FOELS Florida Bar No.: 880868 Primary Email: csf@eifg-law.com Secondary Email: dac@eifg-law.com cf@eifg-law.com; nld@eifg-law.com ESTES, INGRAM, FOELS & GIBBS, P.A. 2600 Lake Lucien Drive, Suite 330 Maitland, FL 32751 (407) 481-9449 Attorneys for CHRISTOPHER JOHN SMITH, M.D., ADVENTHEALTH MEDICAL GROUP, FLORIDA RADIOLOGY IMAGING AT LAKE MARY, LLC D/B/A ADVENTHEALTH IMAGING LAKE NONA IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2023 CA 003739 MP DARLENE DANIELA ESCALANTE , Plaintiff, vs. ADVENTIST HEALTH SYSTEM/SUNBELT, INC. D/B/A ADVENTHEALTH KISSIMMEE, FLORIDA HOSPITAL MEDICAL GROUP, INC. D/B/A RADIOLOGY SPECIALISTS OF FLORIDA, FLORIDA RADIOLOGY IMAGING AT LAKE MARY, LLC D/B/A ADVENTHEALTH IMAGING LAKE NONA, FLORIDA HOSPITAL MEDICAL GROUP, INC. D/B/A ADVENTHEALTH MEDICAL GROUP, AND CHRISTOPHER JOHN SMITH, M.D., Defendant. ___________________________________/ SUBPOENA DUCES TECUM WITHOUT DEPOSITION for records only THE STATE OF FLORIDA: TO: Records Custodian for Mindful Behavioral Healthcare 717 East Oak Street Kissimmee, FL 34744 YOU ARE COMMANDED to furnish to Dinelia A. Concepcion, Estes, Ingram, Foels & Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32751, within ten (10) days following receipt of this Subpoena, the following: Any and all office notes, charts, doctors' reports, x-rays, records, nurses' notes, admission and discharge summaries, and any and all other medical, psychological, psychiatric, hospital or emergency room records of any kind or nature whatsoever regarding DARLENE ESCALANTE. (See attached correspondence for patient's date of birth and Social Security number.) These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: (1) furnish the records as provided above; or (2) object to this subpoena, you may be in contempt of court. You are subpoenaed by the following attorney to produce the above-requested records, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this _____ day of ___________________, 20____. Dinelia A. Concepcion For the Court Attorney for FLORIDA RADIOLOGY IMAGING AT LAKE MARY, LLC D/B/A ADVENTHEALTH IMAGING LAKE NONA, FLORIDA HOSPITAL MEDICAL GROUP, INC. D/B/A ADVENTHEALTH MEDICAL GROUP, AND CHRISTOPHER JOHN SMITH, M.D. ESTES, INGRAM, FOELS & GIBBS, P.A. 2600 Lake Lucien Drive, Suite 330 Maitland, FL 32751 (407) 481-9449 Florida Bar No. 104953