Preview
Filing # 168783100 E-Filed 03/15/2023 01:40:49 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR
OSCEOLA COUNTY, FLORIDA
CASE NO.: 2020-CA-002872
ASBEL ALEXANDER LLERENA,
Plaintiff,
v.
ADRIAN RODRIGUEZ CHAVEZ AND
GRANNY'S GARDEN II, INC.,
Defendants.
_______________________________/
DEFENDANTS’ MOTION FOR RULE TO SHOW CAUSE AS TO
ADVANCED DIAGNOSTIC GROUP
Defendants, ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC.,
by and through its undersigned counsel, respectfully files this Motion for Rule to Show
Cause as to why the Records Custodian of Advanced Diagnostic Group should not be
held in contempt of Court and/or subject to further other sanctions, and as grounds would
state as follows:
1. Plaintiff has alleged various personal injuries stemming from a motor vehicle
accident involving Defendants for which he has treated with various medical providers,
including Advanced Diagnostic Group. Defendants require Plaintiff’s medical records
from this provider to prepare their defense of Plaintiff’s claim.
2. On July 5, 2022, Defendant served the Records Custodian of Advanced
Diagnostic Group with a Subpoena Duces Tecum allowing for production of records in
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
2020-CA-002872
lieu of deposition or alternatively production at a designated time for deposition. (Please
see the subpoena and affidavit of service attached hereto as composite Exhibit “A”).
3. To date, Advanced Diagnostic Group has failed to comply with the
subpoena either through production of records or appearance at deposition.
4. On October 31, 2022 and March 6, 2023, Defendant sent a good faith
follow-up letters seeking compliance with the subpoena that has never been
acknowledged. (Please see letters seeking compliance with the subpoena, attached as
Exhibit “B”).
4. To date, Advanced Diagnostic Group has not contacted the undersigned to
request additional information or to state any objections to the Defendants’ subpoena for
Plaintiff’s medical records.
5. Defendant is prejudiced by Advanced Diagnostic Group’s failure to comply
with the subpoena for approximately eight months.
WHEREFORE, Defendants, ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S
GARDEN II, INC., move this Court for an Order requiring Advanced Diagnostic Group to
show cause as to why it should not be held in contempt of Court for its failure to produce
records or appear for deposition, and any other relief that this Court deems necessary
and proper, including attorney’s fees for the drafting of this Motion and to attend a hearing
on same.
[Certificate of Service on Following Page]
Page 2
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
2020-CA-002872
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th day of March, 2023, a true and correct copy
of the foregoing was filed with the Clerk of Osceola County by using the Florida Courts e-
Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: Melissa Alzate, Esq., Morgan & Morgan, P.A.,
malzate@forthepeople.com;imerlos@forthepeople.com, 198 Broadway Avenue,
Kissimmee, FL 34741, (407) 452-1597/(407) 452-1623 (F), Attorney for Plaintiff, Asbel
Alexander Llerena.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendants ADRIAN RODRIGUEZ
CHAVEZ AND GRANNY'S GARDEN II, INC.
Tower Place, Suite 400
1900 Summit Tower Boulevard
Orlando, Florida 32810
Telephone (321) 972-0029
Facsimile (321) 972-0099
Primary e-mail: melissa.crowley@csklegal.com
Secondary e-mail: harley.clement@csklegal.com
Alternate e-mail: gabrielle.porcaro@csklegal.com
By: /s/ Harley C. Clement
MELISSA D. CROWLEY
Florida Bar No.: 90984
HARLEY C. CLEMENT
Florida Bar No.: 1019181
0487.2384-00
Page 3
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR
OSCEOLA COUNTY, FLORIDA
CASE NO.: 2020-CA-002872
ASBEL ALEXANDER LLERENA,
Plaintiff,
v.
ADRIAN RODRIGUEZ CHAVEZ AND
GRANNY'S GARDEN II, INC.,
Defendants.
_______________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Advanced Diagnostic Group
8300 W. Sunrise Blvd.
Plantation, FL 33322
Attention: Records Custodian
YOU ARE HEREBY COMMANDED to produce without deposition and deliver the
following items, no later than TEN (10) days within receipt of this subpoena duces tecum,
to Cole, Scott & Kissane, P.A., Tower Place, Suite 400, 1900 Summit Tower Boulevard,
Orlando, Florida 32810:
A copy of your entire file related ASBEL ALEXANDER LLERENA,
, including but not limited to, all medical
records, admission reports, initial evaluations, consultation reports, interim
evaluations, final evaluations, discharge summaries, clinical charts, clinical
records, medical histories, chiropractic histories, patient questionnaire
forms, photographs, reports of physical examinations, reports of mental
examinations, narrative reports, x-rays, x-ray reports, thermograms, CT
scans, CT-scan reports, MRI films, MRI reports, notes on attendance,
charts, complete bills with records of payments, either partial or complete
payment, in any form such records are kept including, but not limited to,
Financial Transaction Listings, records of assignments of money owed for
treatment, either full or partial, including names and identity of the assignee
of such, all correspondence, letters, telephone messages, notes, claim
forms, lien letters, letters of protection “Doctor Liens” signed by the patient
A
CASE NO.: 2020-CA-002872
and/or the patient’s attorney, and diagnostic test results and studies. This
subpoena is in no way limited to any particular accident or condition.
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 payment in advance of reasonable cost of
preparation. You may mail or deliver the copies to the attorney whose name appears on
this subpoena and thereby eliminate your appearance at the time and place specified
above.
You may be in contempt of court if you fail to:
1. Appear as specified; or
2. Furnish the records instead of appearing as provided above; or
3. Object to this subpoena;
You are subpoenaed by the attorneys whose names appear on this subpoena, and
unless excused from this subpoena by these attorneys or the court, you shall respond to
this subpoena as directed.
WITNESS my hand and the seal on July 5, 2022.
If you have any questions or require prepayment, please contact
LaToya Myles at (407) 775-3536
By: /s/ Harley C. Clement
HARLEY C. CLEMENT
Florida Bar No.: 1019181
Page 2
Cole, Scott & Kissane
www.csklegal.com
Miami | Fort Lauderdale West | Fort Lauderdale East | West Palm Beach | Orlando | Jacksonville North
Jacksonville South | Tampa | Bonita Springs | Pensacola | Fort Myers | Tallahassee | Key West
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2020-CA-002872
NOTICE OF HIPAA COMPLIANCE
Pursuant to 45 CFR 164.512(e)(1)(iii) and Florida Rule of Civil Procedure 1.351,
the undersigned has given written notice to all parties of record, including the Plaintiff’s
attorney, of the intent to serve this Subpoena upon a non-party, directing the production
of documents or things without deposition. The time for any party to raise objections has
elapsed and no objections have been filed or all objections which have been filed have
been resolved by the court.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendants ADRIAN RODRIGUEZ
CHAVEZ AND GRANNY'S GARDEN II, INC.
Tower Place, Suite 400
1900 Summit Tower Boulevard
Orlando, Florida 32810
Telephone (321) 972-0094
Facsimile (321) 972-0099
Primary e-mail: melissa.crowley@csklegal.com
Secondary e-mail:harley.clement@csklegal.com
Alternate e-mail: ashley.minish@csklegal.com
By: /s/ Harley C. Clement
MELISSA D. CROWLEY
Florida Bar No.: 90984
HARLEY C. CLEMENT
Florida Bar No.: 1019181
0487.2384-00-1
Page 3
Cole, Scott & Kissane
www.csklegal.com
Miami | Fort Lauderdale West | Fort Lauderdale East | West Palm Beach | Orlando | Jacksonville North
Jacksonville South | Tampa | Bonita Springs | Pensacola | Fort Myers | Tallahassee | Key West
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
AFFIDAVIT OF SERVICE
State of Florida County of Osceola Circuit Court
Case Number: 2020-CA-002872
Plaintiff:
ASBEL ALEXANDER LLERENA
LIN2022021342
vs.
Defendant:
ADRIAN RODRIGUEZ CHAVEZ AND
GRANNY'S GARDEN II, INC.
For:
Harley C. Clement
Cole Scott & Kissane, P.A. - ORL
1900 Summit Tower Blvd.
Tower Place, Suite 400
Orlando, FL 32810
Received by Lynx Legal Services, LLC on the 5th day of July, 2022 at 2:12 pm to be served on Advanced Diagnostic Group Attention: Records
Custodian, 8300 West Sunrise Boulevard, Plantation, FL 33324.
I, Kenneth Chin, being duly sworn, depose and say that on the 6th day of July, 2022 at 11:31 am, I:
CORPORATE served by delivering a true copy of the Subpoena Duces Tecum Without Deposition in Regards to Asbel Alexander Llerena and
Defendants' Second Notice of Production from Non-Parties with the date and hour of service endorsed thereon by me, to: Karen T. as Authorized
Employee for Advanced Diagnostic Group, at the address of: 8300 West Sunrise Boulevard, Plantation, FL 33324, and informed said person of
the contents therein, in compliance with F.S. 48.081
Description of Person Served: Age: 45 to 50, Sex: F, Race/Skin Color: Caucasian, Height: 5'5" to 5'10", Weight: 135 to 140, Hair: Blonde, Glasses:
_, Other: undefined
I am over the age of 18, have no interest in the above action, and am a Certified Process Server, in good standing, in the judicial circuit in which the
process was served. Under the penalty of perjury, I declare that I have read the foregoing proof of service, and I attest that the facts stated in it are true.
Subscribed and Sworn to before me by means of [ ] Physical
Presence or [ ] Online Notarization on the _____ day of Kenneth Chin
_______________, _______ by the affiant who is personally Process Server
known to me.
Lynx Legal Services, LLC
____________________________ 201 E. Pine Street
NOTARY PUBLIC Suite 740
Orlando, FL 32801
(407) 872-0707
Our Job Serial Number: LIN-2022021342
Ref: 300-0036648-2020
Copyright © 1992-2022 DreamBuilt Software, Inc. - Process Server's Toolbox V8.2k
TOWER PLACE, SUITE 400 TELEPHONE (321) 972-0000
1900 SUMMIT TOWER BOULEVARD FACSIMILE (321) 972-0099
ORLANDO, FLORIDA 32810 DIRECT LINE (407) 775-3536
latoya.myles@csklegal.com
October 31, 2022
VIA CERTIFIED MAIL
Records Custodian
Advanced Diagnostic Group
8300 W. Sunrise Blvd
Plantation, FL 33322
Re: Name: Asbel Alexander Llerena
Date Birth:
Soc. Sec. No. :
Our File No. : 0487.2384-00
Dear Sir/Madam:
A review of our file indicates that we have not received a response to our Subpoena
Duces Tecum dated, July 5, 2022, with regard to Asbel Alexander Llerena. A copy of the
subject Subpoena is attached for you reference.
We have not heard from you and you are in default on the Subpoena and subject
to penalties. It would be appreciated if you could provide these documents to us within
the next fifteen days to avoid the necessity to file a motion to show cause and schedule
a hearing seeking sanctions against you. Should you require pre-payment, please contact
me at (407) 775-3536. You may fax your request for pre-payment or said documents to
my attention at (321) 972-0099, or email address: latoya.myles@csklegal.com.
I look forward to hearing from you at your earliest convenience. Thank you for your
anticipated cooperation with this matter.
Sincerely,
/s/ LaToya Myles
LaToya Myles
Paralegal
HCC/lm14
Enclosure
0487.2384-00/-1
Cole, Scott & Kissane
www.csklegal.com B
Miami | Fort Lauderdale West | Fort Lauderdale East | West Palm Beach | Orlando | Jacksonville North
Jacksonville South | Tampa | Bonita Springs | Pensacola | Fort Myers | Tallahassee | Key West
TOWER PLACE, SUITE 400 TELEPHONE (321) 972-0000
1900 SUMMIT TOWER BOULEVARD FACSIMILE (321) 972-0099
ORLANDO, FLORIDA 32810 DIRECT LINE (407) 775-3536
latoya.myles@csklegal.com
FINAL REQUEST FOR COMPLIANCE
March 6, 2023
VIA CERTIFIED MAIL
Records Custodian
Advanced Diagnostic Group
8300 W. Sunrise Blvd
Plantation, FL 33322
Re: Name: Asbel Alexander Llerena
Date Birth:
Soc. Sec. No. :
Our File No. : 0487.2384-00
Dear Sir/Madam:
A review of our file indicates that we have not received a response to our Subpoena
Duces Tecum dated, July 5, 2022, with regard to Asbel Llerena. A copy of the subject
Subpoena is attached for you reference.
We have not heard from you and you are in default on the Subpoena and subject
to penalties. It would be appreciated if you could provide these documents to us within
the next fifteen days to avoid the necessity to file a motion to show cause and schedule
a hearing seeking sanctions against you. Should you require pre-payment, please contact
me at (407) 775-3536. You may fax your request for pre-payment or said documents to
my attention at (321) 972-0099, or email address: latoya.myles@csklegal.com.
I look forward to hearing from you at your earliest convenience. Thank you for your
anticipated cooperation with this matter.
Sincerely,
/s/ LaToya Myles
LaToya Myles
Paralegal
HCC/lm
Enclosure
0487.2384-00/-1
Cole, Scott & Kissane
www.csklegal.com
Miami | Fort Lauderdale West | Fort Lauderdale East | West Palm Beach | Orlando | Jacksonville North
Jacksonville South | Tampa | Bonita Springs | Pensacola | Fort Myers | Tallahassee | Key West
Preview
Filing # 168783100 E-Filed 03/15/2023 01:40:49 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2020-CA-002872 ASBEL ALEXANDER LLERENA, Plaintiff, v. ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC., Defendants. _______________________________/ DEFENDANTS’ MOTION FOR RULE TO SHOW CAUSE AS TO ADVANCED DIAGNOSTIC GROUP Defendants, ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC., by and through its undersigned counsel, respectfully files this Motion for Rule to Show Cause as to why the Records Custodian of Advanced Diagnostic Group should not be held in contempt of Court and/or subject to further other sanctions, and as grounds would state as follows: 1. Plaintiff has alleged various personal injuries stemming from a motor vehicle accident involving Defendants for which he has treated with various medical providers, including Advanced Diagnostic Group. Defendants require Plaintiff’s medical records from this provider to prepare their defense of Plaintiff’s claim. 2. On July 5, 2022, Defendant served the Records Custodian of Advanced Diagnostic Group with a Subpoena Duces Tecum allowing for production of records in COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX 2020-CA-002872 lieu of deposition or alternatively production at a designated time for deposition. (Please see the subpoena and affidavit of service attached hereto as composite Exhibit “A”). 3. To date, Advanced Diagnostic Group has failed to comply with the subpoena either through production of records or appearance at deposition. 4. On October 31, 2022 and March 6, 2023, Defendant sent a good faith follow-up letters seeking compliance with the subpoena that has never been acknowledged. (Please see letters seeking compliance with the subpoena, attached as Exhibit “B”). 4. To date, Advanced Diagnostic Group has not contacted the undersigned to request additional information or to state any objections to the Defendants’ subpoena for Plaintiff’s medical records. 5. Defendant is prejudiced by Advanced Diagnostic Group’s failure to comply with the subpoena for approximately eight months. WHEREFORE, Defendants, ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC., move this Court for an Order requiring Advanced Diagnostic Group to show cause as to why it should not be held in contempt of Court for its failure to produce records or appear for deposition, and any other relief that this Court deems necessary and proper, including attorney’s fees for the drafting of this Motion and to attend a hearing on same. [Certificate of Service on Following Page] Page 2 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX 2020-CA-002872 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 15th day of March, 2023, a true and correct copy of the foregoing was filed with the Clerk of Osceola County by using the Florida Courts e- Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Melissa Alzate, Esq., Morgan & Morgan, P.A., malzate@forthepeople.com;imerlos@forthepeople.com, 198 Broadway Avenue, Kissimmee, FL 34741, (407) 452-1597/(407) 452-1623 (F), Attorney for Plaintiff, Asbel Alexander Llerena. COLE, SCOTT & KISSANE, P.A. Counsel for Defendants ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC. Tower Place, Suite 400 1900 Summit Tower Boulevard Orlando, Florida 32810 Telephone (321) 972-0029 Facsimile (321) 972-0099 Primary e-mail: melissa.crowley@csklegal.com Secondary e-mail: harley.clement@csklegal.com Alternate e-mail: gabrielle.porcaro@csklegal.com By: /s/ Harley C. Clement MELISSA D. CROWLEY Florida Bar No.: 90984 HARLEY C. CLEMENT Florida Bar No.: 1019181 0487.2384-00 Page 3 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2020-CA-002872 ASBEL ALEXANDER LLERENA, Plaintiff, v. ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC., Defendants. _______________________________/ SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Advanced Diagnostic Group 8300 W. Sunrise Blvd. Plantation, FL 33322 Attention: Records Custodian YOU ARE HEREBY COMMANDED to produce without deposition and deliver the following items, no later than TEN (10) days within receipt of this subpoena duces tecum, to Cole, Scott & Kissane, P.A., Tower Place, Suite 400, 1900 Summit Tower Boulevard, Orlando, Florida 32810: A copy of your entire file related ASBEL ALEXANDER LLERENA, , including but not limited to, all medical records, admission reports, initial evaluations, consultation reports, interim evaluations, final evaluations, discharge summaries, clinical charts, clinical records, medical histories, chiropractic histories, patient questionnaire forms, photographs, reports of physical examinations, reports of mental examinations, narrative reports, x-rays, x-ray reports, thermograms, CT scans, CT-scan reports, MRI films, MRI reports, notes on attendance, charts, complete bills with records of payments, either partial or complete payment, in any form such records are kept including, but not limited to, Financial Transaction Listings, records of assignments of money owed for treatment, either full or partial, including names and identity of the assignee of such, all correspondence, letters, telephone messages, notes, claim forms, lien letters, letters of protection “Doctor Liens” signed by the patient A CASE NO.: 2020-CA-002872 and/or the patient’s attorney, and diagnostic test results and studies. This subpoena is in no way limited to any particular accident or condition. 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 payment in advance of reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You may be in contempt of court if you fail to: 1. Appear as specified; or 2. Furnish the records instead of appearing as provided above; or 3. Object to this subpoena; You are subpoenaed by the attorneys whose names appear on this subpoena, and unless excused from this subpoena by these attorneys or the court, you shall respond to this subpoena as directed. WITNESS my hand and the seal on July 5, 2022. If you have any questions or require prepayment, please contact LaToya Myles at (407) 775-3536 By: /s/ Harley C. Clement HARLEY C. CLEMENT Florida Bar No.: 1019181 Page 2 Cole, Scott & Kissane www.csklegal.com Miami | Fort Lauderdale West | Fort Lauderdale East | West Palm Beach | Orlando | Jacksonville North Jacksonville South | Tampa | Bonita Springs | Pensacola | Fort Myers | Tallahassee | Key West TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2020-CA-002872 NOTICE OF HIPAA COMPLIANCE Pursuant to 45 CFR 164.512(e)(1)(iii) and Florida Rule of Civil Procedure 1.351, the undersigned has given written notice to all parties of record, including the Plaintiff’s attorney, of the intent to serve this Subpoena upon a non-party, directing the production of documents or things without deposition. The time for any party to raise objections has elapsed and no objections have been filed or all objections which have been filed have been resolved by the court. COLE, SCOTT & KISSANE, P.A. Counsel for Defendants ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC. Tower Place, Suite 400 1900 Summit Tower Boulevard Orlando, Florida 32810 Telephone (321) 972-0094 Facsimile (321) 972-0099 Primary e-mail: melissa.crowley@csklegal.com Secondary e-mail:harley.clement@csklegal.com Alternate e-mail: ashley.minish@csklegal.com By: /s/ Harley C. Clement MELISSA D. CROWLEY Florida Bar No.: 90984 HARLEY C. CLEMENT Florida Bar No.: 1019181 0487.2384-00-1 Page 3 Cole, Scott & Kissane www.csklegal.com Miami | Fort Lauderdale West | Fort Lauderdale East | West Palm Beach | Orlando | Jacksonville North Jacksonville South | Tampa | Bonita Springs | Pensacola | Fort Myers | Tallahassee | Key West TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX AFFIDAVIT OF SERVICE State of Florida County of Osceola Circuit Court Case Number: 2020-CA-002872 Plaintiff: ASBEL ALEXANDER LLERENA LIN2022021342 vs. Defendant: ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC. For: Harley C. Clement Cole Scott & Kissane, P.A. - ORL 1900 Summit Tower Blvd. Tower Place, Suite 400 Orlando, FL 32810 Received by Lynx Legal Services, LLC on the 5th day of July, 2022 at 2:12 pm to be served on Advanced Diagnostic Group Attention: Records Custodian, 8300 West Sunrise Boulevard, Plantation, FL 33324. I, Kenneth Chin, being duly sworn, depose and say that on the 6th day of July, 2022 at 11:31 am, I: CORPORATE served by delivering a true copy of the Subpoena Duces Tecum Without Deposition in Regards to Asbel Alexander Llerena and Defendants' Second Notice of Production from Non-Parties with the date and hour of service endorsed thereon by me, to: Karen T. as Authorized Employee for Advanced Diagnostic Group, at the address of: 8300 West Sunrise Boulevard, Plantation, FL 33324, and informed said person of the contents therein, in compliance with F.S. 48.081 Description of Person Served: Age: 45 to 50, Sex: F, Race/Skin Color: Caucasian, Height: 5'5" to 5'10", Weight: 135 to 140, Hair: Blonde, Glasses: _, Other: undefined I am over the age of 18, have no interest in the above action, and am a Certified Process Server, in good standing, in the judicial circuit in which the process was served. Under the penalty of perjury, I declare that I have read the foregoing proof of service, and I attest that the facts stated in it are true. Subscribed and Sworn to before me by means of [ ] Physical Presence or [ ] Online Notarization on the _____ day of Kenneth Chin _______________, _______ by the affiant who is personally Process Server known to me. Lynx Legal Services, LLC ____________________________ 201 E. Pine Street NOTARY PUBLIC Suite 740 Orlando, FL 32801 (407) 872-0707 Our Job Serial Number: LIN-2022021342 Ref: 300-0036648-2020 Copyright © 1992-2022 DreamBuilt Software, Inc. - Process Server's Toolbox V8.2k TOWER PLACE, SUITE 400 TELEPHONE (321) 972-0000 1900 SUMMIT TOWER BOULEVARD FACSIMILE (321) 972-0099 ORLANDO, FLORIDA 32810 DIRECT LINE (407) 775-3536 latoya.myles@csklegal.com October 31, 2022 VIA CERTIFIED MAIL Records Custodian Advanced Diagnostic Group 8300 W. Sunrise Blvd Plantation, FL 33322 Re: Name: Asbel Alexander Llerena Date Birth: Soc. Sec. No. : Our File No. : 0487.2384-00 Dear Sir/Madam: A review of our file indicates that we have not received a response to our Subpoena Duces Tecum dated, July 5, 2022, with regard to Asbel Alexander Llerena. A copy of the subject Subpoena is attached for you reference. We have not heard from you and you are in default on the Subpoena and subject to penalties. It would be appreciated if you could provide these documents to us within the next fifteen days to avoid the necessity to file a motion to show cause and schedule a hearing seeking sanctions against you. Should you require pre-payment, please contact me at (407) 775-3536. You may fax your request for pre-payment or said documents to my attention at (321) 972-0099, or email address: latoya.myles@csklegal.com. I look forward to hearing from you at your earliest convenience. Thank you for your anticipated cooperation with this matter. Sincerely, /s/ LaToya Myles LaToya Myles Paralegal HCC/lm14 Enclosure 0487.2384-00/-1 Cole, Scott & Kissane www.csklegal.com B Miami | Fort Lauderdale West | Fort Lauderdale East | West Palm Beach | Orlando | Jacksonville North Jacksonville South | Tampa | Bonita Springs | Pensacola | Fort Myers | Tallahassee | Key West TOWER PLACE, SUITE 400 TELEPHONE (321) 972-0000 1900 SUMMIT TOWER BOULEVARD FACSIMILE (321) 972-0099 ORLANDO, FLORIDA 32810 DIRECT LINE (407) 775-3536 latoya.myles@csklegal.com FINAL REQUEST FOR COMPLIANCE March 6, 2023 VIA CERTIFIED MAIL Records Custodian Advanced Diagnostic Group 8300 W. Sunrise Blvd Plantation, FL 33322 Re: Name: Asbel Alexander Llerena Date Birth: Soc. Sec. No. : Our File No. : 0487.2384-00 Dear Sir/Madam: A review of our file indicates that we have not received a response to our Subpoena Duces Tecum dated, July 5, 2022, with regard to Asbel Llerena. A copy of the subject Subpoena is attached for you reference. We have not heard from you and you are in default on the Subpoena and subject to penalties. It would be appreciated if you could provide these documents to us within the next fifteen days to avoid the necessity to file a motion to show cause and schedule a hearing seeking sanctions against you. Should you require pre-payment, please contact me at (407) 775-3536. You may fax your request for pre-payment or said documents to my attention at (321) 972-0099, or email address: latoya.myles@csklegal.com. I look forward to hearing from you at your earliest convenience. Thank you for your anticipated cooperation with this matter. Sincerely, /s/ LaToya Myles LaToya Myles Paralegal HCC/lm Enclosure 0487.2384-00/-1 Cole, Scott & Kissane www.csklegal.com Miami | Fort Lauderdale West | Fort Lauderdale East | West Palm Beach | Orlando | Jacksonville North Jacksonville South | Tampa | Bonita Springs | Pensacola | Fort Myers | Tallahassee | Key West