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Filing # 55768485 E-Filed 05/01/2017 09:11:29 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
Vv. CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
DEFENDANT'S NOTICE OF PRODUCTION FROM NON-PARTIES
YOU ARE HEREBY NOTIFIED that after fifteen (15) days from the date of
service hereof, if no objection is received from any party, the undersigned will issue or
apply to the Clerk of this Court for issuance of the attached Subpoenas directed to the
following non-parties, to produce the items listed at the time and place specified in the
Subpoena.
4
Bayshore Marine & Yacht Brokers, Inc.
2 Bayside Eye Center
Auto-Owners Insurance
Trover Solutions, Inc.
Cigna Healthcare of Florida, Inc.
Xerox Recovery Services
Charlotte County First & EMS
Lee Memorial Health System
JLR Anesthesia Associates, Inc.
10 Ameripath Southwest Florida
11. Aeromed/Air Methods
12. Tampa General Hospital
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the above and foregoing has
been electronically filed with the Clerk of Court using the E-Portal Filing System this
[= day of May, 2017, and a copy of the same will be furnished by electronic
mail service through the E-portal, to the following:
Michael M. Noone, Esquire
Florida Bar #: 0105139
Goldberg, Racila, D'Alessandro & Noone, P.A.
P.O. Box 190
Fort Myers, FL 33902-0190
(239) 461-5508
MikeNoone@goldberg-law.com
service@goldberg-law.com
ElizeteVelado@goldberg-law.com
Florida Bar #: 0099668
Attorneys for Plaintiffs
HENDERSON, FRANKLIN, STARNES & HOLT, P.A.
Attorneys for Defendants
Post Office Box 280
1715 Monroe Street
Fort Myers, FL 33902-0280
239.344.1299
239.344.1521 Facsimile
william. boltrek@henlaw.com
brenda sitar@henlaw.com
By
K, Hl
Florida t No. 100901
#2212026
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
v CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
Employment Records Custodian
Bayshore Marine & Yacht Brokers, Inc.
23269 Bayshore Road
Port Charloite, FL 33980
YOU ARE COMMANDED to appear at the Jaw offices of Henderson, Franklin, Starnes &
Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of
service hereof, and to have with you at that time and place the following: any and.all personnel
records including, but not limited to, employment applications, medical and hospital bills,
records and reports, workers’ compensation claims, Employment Eligibility Verification Form I-9,
W-2 forms, performance reviews, payroll records, correspondence, and all other tangible items
regarding employee or former employee, WILLIAM H. SCHMITZ. All records should be all
inclusive with no omissions.
PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003
STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25
pages and $.25 for each page thereafter.” $1.00 per page can be charged for all hospital
records. There is no provision for “document retrieval" fees in excess of the per page
copying charge. Please bill our firm for these records accordingly. If the cost of
reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with
Paralegal Monica E. Dusel for approval.
sexes] EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS******
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 attorneys at Henderson, Franklin, Starnes &
Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within
ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN..
IF YOU FAIL TO:
a appear as specified; or
b. furnish the records instead of appearing as provided above; or
Cc. object to this subpoena,
YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following
attorney and unless excused from this subpoena by this attorney or the Court, you shall respond
to this subpoena as directed.
HIPAA Certificate: This certifies that this subpoena has been issued in compliance with
the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901
and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and
1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide
written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the
taking of this deposition for which this subpoena has been issued and which included sufficient
information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or
administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c),
Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said
objections, if any, have been resolved.
DATED:
WILLIAM BOLTREK, Hl,
For the Court gy2 IRE
By: ¥.
Attorneys for Defendant
Henderson, Franklin, Starne: Sy PA.
Post Office Box 280
Fort Myers, Florida 33902-0280
239.344.1167 (phone)
239.344.1502 (facsimile)
Florida Bar No. 100901
#2212082
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
Vv. CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
Medical Records Custodian
Bayside Eye Center
314 N. Tamiami Trail, Suite 112
Punta Gorda, FL 33950
YOU ARE COMMANDEDto appear at the law offices of Henderson, Franklin, Starnes &
Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of
service hereof, and to have with you at that time and place the following: any and all medical,
radiology, and billing records or reports, office notes, nurse's notes, appointment cards, x-ray
reports, radiology films, clinical reports, questionnaire or patient information forms, ledgers,
invoices, billing statements showing total amount of bill paid and by whom, correspondence,
reports or correspondence prepared for attorneys by witness or received from attorneys, every
written piece of paper included within the patient's chart, including a copy of any notations on
the file jacket, etc., and all other tangible items pertaining to the diagnosis, care, treatment
and/or examination by the witness, or any other health provider that are in the possession of the
witness, regarding patient WILLIAM H. SCHMITZ. All records should be all inclusive of any
care and treatment ever provided, and should in no way be limited to one incident.
PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003
STATES: “Reasonable costs of copies shail not exceed $1.00 per page for the first 25
pages and $.25 for each page thereafter." $1.00 per page can be charged for all hospital
records. There is no provision for "document retrieval" fees in excess of the per page
copying charge. Please bill our firm for these records accordingly. If the cost of
reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with
Paralegal Monica E. Dusel for approval.
»s*PL EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS******
THESE ITEMS WILL BE inspected and may be copied at that time. You will not be
required items. You may comply with this subpoena by providing
to surrender the original
legible copies of the items to be produced to the attorneys at Henderson, Franklin, Starnes &
Holt, P.A., on-or before the scheduled date of production. This subpoena shall expire within
ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL SE TAKEN.
IF YOU FAIL TO:
d appear as specified; or
e furnish the records instead of appearing as provided above; or
f. object to this subpoena,
YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following
attorney and unless excused from this subpoena by this attorney or the Court, you shall respond
to this subpoena as directed.
HIPAA Certificate: This certifies that this subpoena has been issued in compliance with
the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901
and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to-Rules 1.410 and
1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide
written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the
taking of this deposition for which this subpoena has been issued and which included sufficient
information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or
administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c),
Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said
objections, if any, have been resolved.
DATED:
WILLIAM BOLTREK, III.
For the Court
Dre
By:
Attorneys for Defendant
%
Henderson, Franklin, Starn & Halt, P.A.
Post Office Box 280
Fort Myers, Florida 33902-0280
239.344.1167 (phone).
239-344-1502 (facsimile)
Florida Bar No. 100901
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
Vv. CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
Insurance Records Custodian
Auto Owners Insurance
6101 Anacapri Blvd.
Lansing, MI 48917
YOU ARE COMMANDED to appear at the law offices of Henderson, Franklin, Starnes &
Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of
service hereof, and to have with you at that time and place the following: Full and complete
insurance file for any and all insurance policies-and/or insurance claims made by or on behalf of
WILLIAM H. SCHMITZ, including but not limited to any and all applications for coverage,
applications for benefits, correspondence, memoranda, IME and other medical reports/records,
medical bills, PIP payment logs, etc. All records should be all inclusive of any care and
treatment ever provided, and should in no way be limited to one incident.
PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003
STATES: “Reasonable costs of copies shall not exceed $1.00 per page for the first 25
pages and $.25 for each page thereafter.” $1.00 per page can be charged for all hospital
records. There is no provision for "document retrieval" fees in excess of the per page
copying charge. Please bill our firm for these records accordingly. If the cost of
reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with
Paralegal Monica E. Dusel for approval.
woeeee**PL EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS*****
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 attorneys at Henderson, Franklin, Starnes &
Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within
ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
IF YOU FAIL TO:
d appear as specified; or
e. furnish the records instead of appearing as provided above; or
f. object to this subpoena,
YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following
attorney and unless excused from this subpoena by this attorney or the Court, you shall respond
to this subpoena as directed.
HIPAA Certificate: This certifies that this subpoena has been issued in compliance with
the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901
and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and
1.310, Fia.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide
written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the
taking of this deposition for which this subpoena has been issued and which included sufficient
information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or
administrative tribunal. The PlaintifffPatient may raise an objection pursuant to Rule 1.280(c),
Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said
objections, if any, have been resolved.
DATED:
WILLIAM BOLTREK, Ill,
For the Court
Gy E
By:
Attorneys for Defendant
Henderson, Franklin, Starn
Post Office Box 280
Fort Myers, Florida 33902-0280
239.344.1167 (phone)
239.344.1502 (facsimile)
Florida Bar No. 100901
#2212082
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIViL. ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
Vv. CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
Records Custodian
Trover Solutions, Inc.
P.O. Box 36220
Louisville, KY 40233-6220
YOU ARE COMMANDED to appear at the flaw offices-of Henderson, Franklin, Starnes &
Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of
service hereof, and to have with you at that time and place the following: Any and all records
related to claims made by or on behalf of WILLIAM H. SCHMITZ, including; but not
limited to, any and all correspondence, memoranda, payment ledgers, paid claims data,
subrogation liens, etc. All records should be all inclusive of any care and treatment ever
provided, and should in no way be limited to one incident.
PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003
STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25
pages and $.25 for each page thereafter." $1.00 per page can be charged for all hospital
records. There is no provision for "document retrieval" fees in excess of the per page
copying charge. Please bill our firm for these records accordingly. If the cost of
reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with
Paralegal Monica E. Dusel for approval.
+eeeeee2*D| FASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS*****
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 attorneys at Henderson, Franklin, Starnes &
Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within
ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
IF YOU FAIL TO:
a appear as specified; or
b furnish the records instead of appearing as provided above; or
C. object to this subpoena,
YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following
attorney and unless excused from this subpoena by this attorney or the Court, you shall respond
to this subpoena as directed.
HIPAA Certificate: This certifies that this subpoena has been issued in compliance with
the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901
and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and
1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide
written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the
taking of this deposition for which this subpoena has been issued and which included sufficient
information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or
administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c),
Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said
objections, if any, have been resolved.
DATED:
WILLIAM BOLTREK, III,
For the Court 22 IRE
By
Attomeys for Defendant
Henderson, Franklin, Starnes. It, PLA.
Post Office Box 280
Fort Myers, Florida 33902-0280
239.344.1167 (phone)
239.344.1502 (facsimile)
Florida Bar No. 100901
#2212082
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
Vv. CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
Insurance Records Custodian
Cigna Healthcare of Florida, Inc.
900 Cottage Grove Road
Bloomington, CT 06002
YOU ARE COMMANDED to appear at the law offices of Henderson, Franklin, Starnes &
Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of
service hereof, and to have with you at that time and place the following: Full and complete
insurance file for any and all insurance policies and/or insurance claims made by or on behalf of
WILLIAM H. SCHMITZ, including but not limited to any and all applications for coverage,
applications for benefits, correspondence, memoranda, IME and other medical reports/records,
medical bills, PIP payment logs, etc. All records should be all inclusive of any care and
treatment ever provided, and should in no way be timited to one incident.
PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003
STATES: “Reasonable costs of copies shall not exceed $1,00 per page for the first 25
pages and $.25 for each page thereafter." $1.00 per page can be charged for all hospital
records, There is no provision for "document retrieval" fees in excess of the per page
copying charge. Please bill our firm for these records accordingly. If the cost of
reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with
Paralegal Monica E. Dusel for approval.
*+04+4*P] EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS*****
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 attorneys at Henderson, Franklin, Starnes &
Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within
ninety (90) days from the date of service. 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 and thereby eliminate your
appearance at the time and piace 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
IF YOU FAIL TO:
a. appear as specified; or
b furnish the records instead of appearing as provided above; or
Cc. object to this subpoena,
YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following
attorney and unless excused from this subpoena by this attorney or the Court, you shall respond
to this subpoena as directed.
HIPAA Certificate: This certifies that this subpoena has been issued in compliance with
the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901
and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and
1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide
written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the
taking of this deposition for which this subpoena has been issued and which included sufficient
information about the litigation to permit the Plaintiff7Patient to-raise an objection to the court or
administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c),
Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said
objections, if any, have been resolved.
B Ye
DATED:
WILLIAM BOLTREK, It UIRE
For the Court
By:
Attorneys for Defendant
Henderson, Franklin, Starn ‘& Holt, P.A.
Post Office Box 280
Fort Myers, Florida 33902-0280
239.344.1167 (phone)
239.344.1502 (facsimile)
Florida Bar No. 100901
#2212082
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
Vv. CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
Records Custodian
Xerox Recovery Services
5500 Pearl Street
Suite 100, Room 120
Rosemont, IL 60018
YOU ARE COMMANDED to appear at the law offices of Henderson, Franklin, Starnes &
Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of
service hereof, and*to have with you at that time and place the following: Any and all records
telated to claims made by or on behalf of WILLIAM H. SCHMITZ including, but not limited
to, any and all correspondence, memoranda, payment ledgers, paid claims data,
subrogation liens, etc. All records should be all inclusive of any care and treatment ever
provided, and should in no way be limited to one incident.
PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003
STATES: “Reasonable costs of copies shall not exceed $1.00 per page for the first 25
pages and $.25 for each page thereafter." $1:00 per page can be charged for all hospital
records. There is no provision for “document retrieval" fees in excess of the per page
copying charge. Please bill our firm for these records accordingly. If the cost of
reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with
Paralegal Monica E. Dusel for approval.
+xL EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS******
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 attorneys at Henderson, Franklin, Starnes &
Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within
ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
IF YOU FAIL TO:
a appear as specified; or
b furnish the records instead of appearing as provided above; or
Cc. object to this subpoena,
YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following
attorney and unless excused from this subpoena by this attorney or the Court, you shall respond
to this subpoena as directed.
HIPAA Certificate: This certifies that this subpoena has been issued in compliance with
the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901
and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and
4.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide
written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the
taking of this deposition for which this subpoena has been issued and which included sufficient
information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or
administrative tribunal. The Plaintiff/Patient may raise ar objection pursuant to Rule 1.280(c),
Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said
objections, if any, have been resolved.
DATED:
WILLIAM BOLTREX, III, a7.
For the Court
By:
Attorneys for Defendant Le.
Henderson, Franklin, Starnes Olt, P.A.
Post Office Box 280
Fort Myers, Florida 33902-0280
239.344.1167 (phone)
239.344.1502 (facsimile)
Florida Bar No. 100901
#2212082
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
Vv CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
Medical Records Custodian
Charlotte County Fire & EMS
26571 Airport Road
Punta Gorda, FL 33928
YOU ARE COMMANDED
-to appear at the law offices of Henderson, Franklin, Starnes &
Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of
service hereof, and to have with you at that time and place the following: any and all medical,
radiology, and billing records-or reports, office notes, nurse's notes, appointment cards, x-ray
reports, radiology films, clinical reports, questionnaire or patient information forms, ledgers,
invoices, billing statements showing total amount of bill paid and by whom, correspondence,
reports or correspondence prepared for attorneys by witness or received from attorneys, every
written piece of paper included within the patient's chart, including a copy of any notations on
the file jacket, etc., and all other tangible items pertaining to the diagnosis, care, treatment
and/or examination by the witness, or any other health provider that are in the possession of the
witness, regarding patient WILLIAM H. SCHMITZ. All records should be all inclusive of any
care and treatment ever provided, and should in no way be limited to one incident.
PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003
STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25
pages and $.25 for each page thereafter.” $1.00 per page can be charged for all hospital
records. There is no provision for "document retrieval” fees in excess of the per page
copying charge. Please bill our firm for these records accordingly. If the cost of
reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with
Paralegal Monica E. Dusel for approval.
see PLEASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS******
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 attorneys at Henderson, Franklin, Starnes &
Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within
ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
IF YOU FAIL TO:
a. appear as specified; or
b. furnish the records instead of appearing as provided above; or
C. object to this subpoena,
YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following
attorney and unless excused from this subpoena by this attorney or the Court, you shall respond
to this subpoena as directed.
HIPAA Certificate: This certifies that this subpoena has been issued in compliance with
the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901
and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and
1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide
written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the
taking of this deposition for which this subpoena has been issued and which included sufficient
information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or
administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c),
Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said
objections, if any, have been resolved.
DATED:
WILLIAM BOLTREK, a
For the Court
By:
Attorneys for ant
Henderson, Franklin, St & Holt, P.A.
Post Office Box 280
Fort Myers, Florida 33902-0280
239.344.1167 (phone)
239-344-1502 (facsimile)
Florida Bar No. 100901
#2212082
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
Vv. CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
Medical Records Custodian
Lee Memorial Health System
2776 Cleveland Avenue
Fort Myers, FL 33901
YOU ARE COMMANDED to appear at the jaw offices of Henderson, Franklin, Starnes &
Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of
service hereof, and to have with you at that time and place the following: any and all medical,
radiology, and ‘billing records or reports, office notes, nurse's notes, appointment cards, x-ray
reports, radiology films, clinical reports, questionnaire or patient information forms, ledgers,
invoices, billing statements showing total amount of bill paid and by whom, correspondence,
reports or correspondence prepared for attorneys by witness or received from attorneys, every
written piece of paper included within the patient's chart, including a copy of any notations on
the file jacket, etc., and all other tangible items pertaining to the diagnosis, care, treatment
and/or examination by the witness, or any other health provider that are in the possession of the
witness, regarding patient WILLIAM H. SCHMITZ. All records should be all inclusive of any
care and treatment ever provided, and should in no way be limited to one incident.
PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003
STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25
pages and $.25 for each page thereafter." $1.00 per page can be charged for all hospital
records. There is no provision for "document retrieval" fees in excess of the per page
copying charge. Please bill our firm for these records accordingly. If the cost of
reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with
Paralegal Monica E. Dusel for approval.
seeeeeP] EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS******
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 atiorneys at Henderson, Franklin, Starnes &
Holi, P.A., on or before the scheduled date of production. This subpoena shall expire within
ninety (9C)-days from the date-of service. 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 and thereby eliminate your
appearance at the time and place specified above.
You have the right to objeci 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:
a appear as specified; or
b. furnish the records instead of appearing as provided above; or
C. object to this subpoena,
YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following
attorney and unless excused from this subpoena by this attorney or the Court, you shall respond
to this subpoena as directed.
HIPAA Certificate: This certifies that this subpoena has been issued in compliance with
the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901
and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and
1.310, Fia.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide
written notice to the PlaintifffPatient listed above by sending his/her attorney a notice of the
taking of this deposition for which this subpoena has been issued and which included sufficient
information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or
administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c),
Fla.R.Civ.P. and no- testimony will be taken nor will documents be produced until said
objections, if any, have been resolved.
DATED:
WILLIAM BOLTREK, Ja ESQUIRE
?
For the Court
By:
Atiorneys for Defendai
Henderson, Franklin, S'
Post Office Box 280
Ay & Holt, P.A.
Fort Myers, Fiorida 33902-0280
239.344.1167 (phone)
239-344-1502 (facsimile)
Florida Bar No. 100901
#2212082
IN THE CIRCUIT COURTOF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K.
SCHMITZ, as Husband and wife,
Plaintiffs,
v. CASE NO. 16001754CA
ALEXMAR PIMIENTA GARRIDO, JLL
LOGISTIC INC and ROBERTO LI,
Defendants.
/
‘SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA, TO:
Medical Records Custodian
JLR Anesthesia Associates, inc.
851 Trafalgar Court, Suite 200E
Maitland, FL 32751
YOU ARE COMMANDED to appear at the law offices of Henderson, Franklin, Starnes &
Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of
service hereof, and to have with you at that time and place the following: any and all medical,
radiology, and billing records or reports, office notes, nurse's notes, appointment cards, x-ray
reports, radiology films, clinical reports, questionnaire or patient information forms, ledgers,
invoices, billing statements showing total amount of bill paid and by whom, correspondence,
reports or correspondence prepared for attorneys by witness or received from attomeys, every
written piece of paper included within the patient's chart, including a copy of any notations on
the file jacket, etc., and all other tangible items pertaining to the diagnosis, care, treatment
and/or examination by the witness, or any other health provider that are in the possession of the
witness, regarding patient WILLIAM H. SCHMITZ. All records should be all inclusive of any
care and treatment ever provided, and should in no way be limited to one incident.
PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003
STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25
pages and $.25 for each page thereafter." $1.00 per page can be charged for alt hospital
records. There is no provision for “document retrieval" fees in excess of the per page
copying charge. Please bill our firm for these records accordingly. If the cost of
reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with
Paralegal Monica E. Dusel for approval.
ween FASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS******
THESE ITEMS WILL BE inspected and may be copied at that time. You will not be
fequired to surr
Preview
Filing # 55768485 E-Filed 05/01/2017 09:11:29 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, Vv. CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. DEFENDANT'S NOTICE OF PRODUCTION FROM NON-PARTIES YOU ARE HEREBY NOTIFIED that after fifteen (15) days from the date of service hereof, if no objection is received from any party, the undersigned will issue or apply to the Clerk of this Court for issuance of the attached Subpoenas directed to the following non-parties, to produce the items listed at the time and place specified in the Subpoena. 4 Bayshore Marine & Yacht Brokers, Inc. 2 Bayside Eye Center Auto-Owners Insurance Trover Solutions, Inc. Cigna Healthcare of Florida, Inc. Xerox Recovery Services Charlotte County First & EMS Lee Memorial Health System JLR Anesthesia Associates, Inc. 10 Ameripath Southwest Florida 11. Aeromed/Air Methods 12. Tampa General Hospital CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the above and foregoing has been electronically filed with the Clerk of Court using the E-Portal Filing System this [= day of May, 2017, and a copy of the same will be furnished by electronic mail service through the E-portal, to the following: Michael M. Noone, Esquire Florida Bar #: 0105139 Goldberg, Racila, D'Alessandro & Noone, P.A. P.O. Box 190 Fort Myers, FL 33902-0190 (239) 461-5508 MikeNoone@goldberg-law.com service@goldberg-law.com ElizeteVelado@goldberg-law.com Florida Bar #: 0099668 Attorneys for Plaintiffs HENDERSON, FRANKLIN, STARNES & HOLT, P.A. Attorneys for Defendants Post Office Box 280 1715 Monroe Street Fort Myers, FL 33902-0280 239.344.1299 239.344.1521 Facsimile william. boltrek@henlaw.com brenda sitar@henlaw.com By K, Hl Florida t No. 100901 #2212026 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, v CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: Employment Records Custodian Bayshore Marine & Yacht Brokers, Inc. 23269 Bayshore Road Port Charloite, FL 33980 YOU ARE COMMANDED to appear at the Jaw offices of Henderson, Franklin, Starnes & Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of service hereof, and to have with you at that time and place the following: any and.all personnel records including, but not limited to, employment applications, medical and hospital bills, records and reports, workers’ compensation claims, Employment Eligibility Verification Form I-9, W-2 forms, performance reviews, payroll records, correspondence, and all other tangible items regarding employee or former employee, WILLIAM H. SCHMITZ. All records should be all inclusive with no omissions. PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003 STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25 pages and $.25 for each page thereafter.” $1.00 per page can be charged for all hospital records. There is no provision for “document retrieval" fees in excess of the per page copying charge. Please bill our firm for these records accordingly. If the cost of reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with Paralegal Monica E. Dusel for approval. sexes] EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS****** 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 attorneys at Henderson, Franklin, Starnes & Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.. IF YOU FAIL TO: a appear as specified; or b. furnish the records instead of appearing as provided above; or Cc. object to this subpoena, YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. HIPAA Certificate: This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the taking of this deposition for which this subpoena has been issued and which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c), Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said objections, if any, have been resolved. DATED: WILLIAM BOLTREK, Hl, For the Court gy2 IRE By: ¥. Attorneys for Defendant Henderson, Franklin, Starne: Sy PA. Post Office Box 280 Fort Myers, Florida 33902-0280 239.344.1167 (phone) 239.344.1502 (facsimile) Florida Bar No. 100901 #2212082 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, Vv. CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: Medical Records Custodian Bayside Eye Center 314 N. Tamiami Trail, Suite 112 Punta Gorda, FL 33950 YOU ARE COMMANDEDto appear at the law offices of Henderson, Franklin, Starnes & Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of service hereof, and to have with you at that time and place the following: any and all medical, radiology, and billing records or reports, office notes, nurse's notes, appointment cards, x-ray reports, radiology films, clinical reports, questionnaire or patient information forms, ledgers, invoices, billing statements showing total amount of bill paid and by whom, correspondence, reports or correspondence prepared for attorneys by witness or received from attorneys, every written piece of paper included within the patient's chart, including a copy of any notations on the file jacket, etc., and all other tangible items pertaining to the diagnosis, care, treatment and/or examination by the witness, or any other health provider that are in the possession of the witness, regarding patient WILLIAM H. SCHMITZ. All records should be all inclusive of any care and treatment ever provided, and should in no way be limited to one incident. PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003 STATES: “Reasonable costs of copies shail not exceed $1.00 per page for the first 25 pages and $.25 for each page thereafter." $1.00 per page can be charged for all hospital records. There is no provision for "document retrieval" fees in excess of the per page copying charge. Please bill our firm for these records accordingly. If the cost of reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with Paralegal Monica E. Dusel for approval. »s*PL EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS****** THESE ITEMS WILL BE inspected and may be copied at that time. You will not be required items. You may comply with this subpoena by providing to surrender the original legible copies of the items to be produced to the attorneys at Henderson, Franklin, Starnes & Holt, P.A., on-or before the scheduled date of production. This subpoena shall expire within ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL SE TAKEN. IF YOU FAIL TO: d appear as specified; or e furnish the records instead of appearing as provided above; or f. object to this subpoena, YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. HIPAA Certificate: This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to-Rules 1.410 and 1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the taking of this deposition for which this subpoena has been issued and which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c), Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said objections, if any, have been resolved. DATED: WILLIAM BOLTREK, III. For the Court Dre By: Attorneys for Defendant % Henderson, Franklin, Starn & Halt, P.A. Post Office Box 280 Fort Myers, Florida 33902-0280 239.344.1167 (phone). 239-344-1502 (facsimile) Florida Bar No. 100901 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, Vv. CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: Insurance Records Custodian Auto Owners Insurance 6101 Anacapri Blvd. Lansing, MI 48917 YOU ARE COMMANDED to appear at the law offices of Henderson, Franklin, Starnes & Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of service hereof, and to have with you at that time and place the following: Full and complete insurance file for any and all insurance policies-and/or insurance claims made by or on behalf of WILLIAM H. SCHMITZ, including but not limited to any and all applications for coverage, applications for benefits, correspondence, memoranda, IME and other medical reports/records, medical bills, PIP payment logs, etc. All records should be all inclusive of any care and treatment ever provided, and should in no way be limited to one incident. PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003 STATES: “Reasonable costs of copies shall not exceed $1.00 per page for the first 25 pages and $.25 for each page thereafter.” $1.00 per page can be charged for all hospital records. There is no provision for "document retrieval" fees in excess of the per page copying charge. Please bill our firm for these records accordingly. If the cost of reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with Paralegal Monica E. Dusel for approval. woeeee**PL EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS***** 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 attorneys at Henderson, Franklin, Starnes & Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. IF YOU FAIL TO: d appear as specified; or e. furnish the records instead of appearing as provided above; or f. object to this subpoena, YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. HIPAA Certificate: This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.310, Fia.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the taking of this deposition for which this subpoena has been issued and which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The PlaintifffPatient may raise an objection pursuant to Rule 1.280(c), Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said objections, if any, have been resolved. DATED: WILLIAM BOLTREK, Ill, For the Court Gy E By: Attorneys for Defendant Henderson, Franklin, Starn Post Office Box 280 Fort Myers, Florida 33902-0280 239.344.1167 (phone) 239.344.1502 (facsimile) Florida Bar No. 100901 #2212082 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIViL. ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, Vv. CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: Records Custodian Trover Solutions, Inc. P.O. Box 36220 Louisville, KY 40233-6220 YOU ARE COMMANDED to appear at the flaw offices-of Henderson, Franklin, Starnes & Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of service hereof, and to have with you at that time and place the following: Any and all records related to claims made by or on behalf of WILLIAM H. SCHMITZ, including; but not limited to, any and all correspondence, memoranda, payment ledgers, paid claims data, subrogation liens, etc. All records should be all inclusive of any care and treatment ever provided, and should in no way be limited to one incident. PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003 STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25 pages and $.25 for each page thereafter." $1.00 per page can be charged for all hospital records. There is no provision for "document retrieval" fees in excess of the per page copying charge. Please bill our firm for these records accordingly. If the cost of reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with Paralegal Monica E. Dusel for approval. +eeeeee2*D| FASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS***** 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 attorneys at Henderson, Franklin, Starnes & Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. IF YOU FAIL TO: a appear as specified; or b furnish the records instead of appearing as provided above; or C. object to this subpoena, YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. HIPAA Certificate: This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the taking of this deposition for which this subpoena has been issued and which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c), Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said objections, if any, have been resolved. DATED: WILLIAM BOLTREK, III, For the Court 22 IRE By Attomeys for Defendant Henderson, Franklin, Starnes. It, PLA. Post Office Box 280 Fort Myers, Florida 33902-0280 239.344.1167 (phone) 239.344.1502 (facsimile) Florida Bar No. 100901 #2212082 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, Vv. CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: Insurance Records Custodian Cigna Healthcare of Florida, Inc. 900 Cottage Grove Road Bloomington, CT 06002 YOU ARE COMMANDED to appear at the law offices of Henderson, Franklin, Starnes & Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of service hereof, and to have with you at that time and place the following: Full and complete insurance file for any and all insurance policies and/or insurance claims made by or on behalf of WILLIAM H. SCHMITZ, including but not limited to any and all applications for coverage, applications for benefits, correspondence, memoranda, IME and other medical reports/records, medical bills, PIP payment logs, etc. All records should be all inclusive of any care and treatment ever provided, and should in no way be timited to one incident. PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003 STATES: “Reasonable costs of copies shall not exceed $1,00 per page for the first 25 pages and $.25 for each page thereafter." $1.00 per page can be charged for all hospital records, There is no provision for "document retrieval" fees in excess of the per page copying charge. Please bill our firm for these records accordingly. If the cost of reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with Paralegal Monica E. Dusel for approval. *+04+4*P] EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS***** 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 attorneys at Henderson, Franklin, Starnes & Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within ninety (90) days from the date of service. 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 and thereby eliminate your appearance at the time and piace 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. IF YOU FAIL TO: a. appear as specified; or b furnish the records instead of appearing as provided above; or Cc. object to this subpoena, YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. HIPAA Certificate: This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the taking of this deposition for which this subpoena has been issued and which included sufficient information about the litigation to permit the Plaintiff7Patient to-raise an objection to the court or administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c), Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said objections, if any, have been resolved. B Ye DATED: WILLIAM BOLTREK, It UIRE For the Court By: Attorneys for Defendant Henderson, Franklin, Starn ‘& Holt, P.A. Post Office Box 280 Fort Myers, Florida 33902-0280 239.344.1167 (phone) 239.344.1502 (facsimile) Florida Bar No. 100901 #2212082 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, Vv. CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: Records Custodian Xerox Recovery Services 5500 Pearl Street Suite 100, Room 120 Rosemont, IL 60018 YOU ARE COMMANDED to appear at the law offices of Henderson, Franklin, Starnes & Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of service hereof, and*to have with you at that time and place the following: Any and all records telated to claims made by or on behalf of WILLIAM H. SCHMITZ including, but not limited to, any and all correspondence, memoranda, payment ledgers, paid claims data, subrogation liens, etc. All records should be all inclusive of any care and treatment ever provided, and should in no way be limited to one incident. PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003 STATES: “Reasonable costs of copies shall not exceed $1.00 per page for the first 25 pages and $.25 for each page thereafter." $1:00 per page can be charged for all hospital records. There is no provision for “document retrieval" fees in excess of the per page copying charge. Please bill our firm for these records accordingly. If the cost of reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with Paralegal Monica E. Dusel for approval. +xL EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS****** 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 attorneys at Henderson, Franklin, Starnes & Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. IF YOU FAIL TO: a appear as specified; or b furnish the records instead of appearing as provided above; or Cc. object to this subpoena, YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. HIPAA Certificate: This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 4.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the taking of this deposition for which this subpoena has been issued and which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The Plaintiff/Patient may raise ar objection pursuant to Rule 1.280(c), Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said objections, if any, have been resolved. DATED: WILLIAM BOLTREX, III, a7. For the Court By: Attorneys for Defendant Le. Henderson, Franklin, Starnes Olt, P.A. Post Office Box 280 Fort Myers, Florida 33902-0280 239.344.1167 (phone) 239.344.1502 (facsimile) Florida Bar No. 100901 #2212082 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, Vv CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: Medical Records Custodian Charlotte County Fire & EMS 26571 Airport Road Punta Gorda, FL 33928 YOU ARE COMMANDED -to appear at the law offices of Henderson, Franklin, Starnes & Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of service hereof, and to have with you at that time and place the following: any and all medical, radiology, and billing records-or reports, office notes, nurse's notes, appointment cards, x-ray reports, radiology films, clinical reports, questionnaire or patient information forms, ledgers, invoices, billing statements showing total amount of bill paid and by whom, correspondence, reports or correspondence prepared for attorneys by witness or received from attorneys, every written piece of paper included within the patient's chart, including a copy of any notations on the file jacket, etc., and all other tangible items pertaining to the diagnosis, care, treatment and/or examination by the witness, or any other health provider that are in the possession of the witness, regarding patient WILLIAM H. SCHMITZ. All records should be all inclusive of any care and treatment ever provided, and should in no way be limited to one incident. PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003 STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25 pages and $.25 for each page thereafter.” $1.00 per page can be charged for all hospital records. There is no provision for "document retrieval” fees in excess of the per page copying charge. Please bill our firm for these records accordingly. If the cost of reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with Paralegal Monica E. Dusel for approval. see PLEASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS****** 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 attorneys at Henderson, Franklin, Starnes & Holt, P.A., on or before the scheduled date of production. This subpoena shall expire within ninety (90) days from the date of service. 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 and thereby eliminate 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. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. IF YOU FAIL TO: a. appear as specified; or b. furnish the records instead of appearing as provided above; or C. object to this subpoena, YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. HIPAA Certificate: This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.310, Fla.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney a notice of the taking of this deposition for which this subpoena has been issued and which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c), Fla.R.Civ.P. and no testimony will be taken nor will documents be produced until said objections, if any, have been resolved. DATED: WILLIAM BOLTREK, a For the Court By: Attorneys for ant Henderson, Franklin, St & Holt, P.A. Post Office Box 280 Fort Myers, Florida 33902-0280 239.344.1167 (phone) 239-344-1502 (facsimile) Florida Bar No. 100901 #2212082 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, Vv. CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: Medical Records Custodian Lee Memorial Health System 2776 Cleveland Avenue Fort Myers, FL 33901 YOU ARE COMMANDED to appear at the jaw offices of Henderson, Franklin, Starnes & Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of service hereof, and to have with you at that time and place the following: any and all medical, radiology, and ‘billing records or reports, office notes, nurse's notes, appointment cards, x-ray reports, radiology films, clinical reports, questionnaire or patient information forms, ledgers, invoices, billing statements showing total amount of bill paid and by whom, correspondence, reports or correspondence prepared for attorneys by witness or received from attorneys, every written piece of paper included within the patient's chart, including a copy of any notations on the file jacket, etc., and all other tangible items pertaining to the diagnosis, care, treatment and/or examination by the witness, or any other health provider that are in the possession of the witness, regarding patient WILLIAM H. SCHMITZ. All records should be all inclusive of any care and treatment ever provided, and should in no way be limited to one incident. PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003 STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25 pages and $.25 for each page thereafter." $1.00 per page can be charged for all hospital records. There is no provision for "document retrieval" fees in excess of the per page copying charge. Please bill our firm for these records accordingly. If the cost of reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with Paralegal Monica E. Dusel for approval. seeeeeP] EASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS****** 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 atiorneys at Henderson, Franklin, Starnes & Holi, P.A., on or before the scheduled date of production. This subpoena shall expire within ninety (9C)-days from the date-of service. 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 and thereby eliminate your appearance at the time and place specified above. You have the right to objeci 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: a appear as specified; or b. furnish the records instead of appearing as provided above; or C. object to this subpoena, YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the following attorney and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. HIPAA Certificate: This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.310, Fia.R.Civ.P. The Party issuing this subpoena has made a good faith attempt to provide written notice to the PlaintifffPatient listed above by sending his/her attorney a notice of the taking of this deposition for which this subpoena has been issued and which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The Plaintiff/Patient may raise an objection pursuant to Rule 1.280(c), Fla.R.Civ.P. and no- testimony will be taken nor will documents be produced until said objections, if any, have been resolved. DATED: WILLIAM BOLTREK, Ja ESQUIRE ? For the Court By: Atiorneys for Defendai Henderson, Franklin, S' Post Office Box 280 Ay & Holt, P.A. Fort Myers, Fiorida 33902-0280 239.344.1167 (phone) 239-344-1502 (facsimile) Florida Bar No. 100901 #2212082 IN THE CIRCUIT COURTOF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and wife, Plaintiffs, v. CASE NO. 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / ‘SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA, TO: Medical Records Custodian JLR Anesthesia Associates, inc. 851 Trafalgar Court, Suite 200E Maitland, FL 32751 YOU ARE COMMANDED to appear at the law offices of Henderson, Franklin, Starnes & Holt, P.A., 1715 Monroe Street, Fort Myers, Florida 33901, within 10 days from the date of service hereof, and to have with you at that time and place the following: any and all medical, radiology, and billing records or reports, office notes, nurse's notes, appointment cards, x-ray reports, radiology films, clinical reports, questionnaire or patient information forms, ledgers, invoices, billing statements showing total amount of bill paid and by whom, correspondence, reports or correspondence prepared for attorneys by witness or received from attomeys, every written piece of paper included within the patient's chart, including a copy of any notations on the file jacket, etc., and all other tangible items pertaining to the diagnosis, care, treatment and/or examination by the witness, or any other health provider that are in the possession of the witness, regarding patient WILLIAM H. SCHMITZ. All records should be all inclusive of any care and treatment ever provided, and should in no way be limited to one incident. PLEASE NOTE THAT FLORIDA ADMINISTRATIVE CODE, CHAPTER 64B8-10.003 STATES: "Reasonable costs of copies shall not exceed $1.00 per page for the first 25 pages and $.25 for each page thereafter." $1.00 per page can be charged for alt hospital records. There is no provision for “document retrieval" fees in excess of the per page copying charge. Please bill our firm for these records accordingly. If the cost of reproduction exceeds $50.00, please contact our office at (239) 344-1167 and speak with Paralegal Monica E. Dusel for approval. ween FASE ATTACH A COPY OF THIS SUBPOENA TO YOUR RECORDS****** THESE ITEMS WILL BE inspected and may be copied at that time. You will not be fequired to surr