Preview
61325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH
COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband, : 4
CASE NO. 50 2008 CA 002451XXXX MB A /
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS
CLUB CONDOMINIUM ASSOCIATION,
a Florida corporation,
Defendant.
/
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service is
by delivery, or 15 days from the date of service, if service is by mail, and 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:
Records Custodian of: Records Custodian of:
Bethesda Memorial Hospital Heartland Convalescent Center
2815 S. Seacrest Blvd 7225 Boca Del Mar Drive
Boynton Beach, Florida 33435 Boca Raton, Florida 33433
Records Custodian of: Records Custodian of:
Boca Raton Fire Rescue Seacrest Community Home Health Services
6500 Congress Avenue, Suite 200 2828 South Seacrest Blvd, Suite 212
Boca Raton, Florida 33487 Boynton Beach, Florida 33435
Records Custodian of: Records Custodian of:
Delray Hospital RAJ Rehab
5362 Linton Blvd 6200 W. Atlantic Avenue
Delray Beach, Florida 33484 Delray Beach, Florida 33484
Records Custodian of: Records Custodian of:
Peter Tuby, MD Dr. Jonathan Tarrash, MD
5258 Linton Blvd, Suite 291 Advanced Pain Medicine & Rehabilitation
Delray Beach, Florida 33484 14610 Military Trail Ste G2
Delray Beach, Florida 33484Records Custodian of:
Dr. Estrin
Rand Institute
5 West Sample Road
Deerfield Beach, Florida 33064
CASE NO. 50 2008 CA 002451XXXX MB
Records Custodian of:
Medicare
P.O. Box 1798
Jacksonville, Florida 32231
who are not parties and whose addresses are indicated on the attached subpoenas, to produce the
items listed at the time and place specified in the subpoena.
WE HEREBY CERTIFY that a true copy of the foregoing was mailed this ( ) day of
> 2008 to the attached service list.
Geri Sue Straus, Esq.
Jacobs & Straus, P.A.
1098 Northwest Boca Raton Boulevard
Boca Raton, FL 33432
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis Club
Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
By:
fe Florida Bar No. 241776
Service List61325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB At
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Bethesda Memorial Hospital
Attn: Medical Records Department
2815 S. Seacrest Blvd
Boynton Beach, Florida 33435
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 9:00 a.m., and to have with you at that time and place the following:
Any and all in-patient, out-patient and emergency room records including but not limited
to reports, charts, documents, microfilmed documents, radiology reports and radiology
studies including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills
for services (paid or unpaid), emergency room discharge instructions, correspondence,
laser copies of photographs, psychological records, requests for records, and any and all
other evidence relating to the examination, treatment care, diagnosis, physical and mental
condition of the person named below, from the inception of your records to the present.
NAME: Bette Verp
DOB: 03/31/1924
SS#: |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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena 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 attomey whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO
TESTIMONY WILL BE TAKEN.
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 may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attomey or the Court, you shall
tespond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Bethesda Memorial Hospital
Attn: Billing Department
2815 S. Seacrest Blvd
Boynton Beach, Florida 33435
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 9:15 a.m., and to have with you at that time and place the following:
Any and all itemized statements (paid or unpaid) of the billing charges pertaining to the
care and treatment of the patient, from the inception of your records to the present.
NAME: Bette Verp
DOB: 03/31/1924
SS#: a
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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena and thereby eliminate yourappearance 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:
qd) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E, Zloch
Florida Bar No. 24177661325-7/JEZ/cema
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Bethesda Memorial Hospital
Attn: Radiology Department
2815 S. Seacrest Blvd
Boynton Beach, Florida 33435
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 9:30 a.m., and to have with you at that time and place the following:
Any and all medical records, final reports, preliminary reports, requisition slips, patient
information sheets, bills, x-rays, CT scans, MRI’s, ultrasounds, mammograms and any
other diagnostic tests as well as all documents included within the x-ray jacket for all films
pertaining to the individual named below:
NAME: Bette Verp
DOB: 03/31/1924
SS#: |
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 giving 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 thepayment 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:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Bethesda Memorial Hospital
Attn: Pathology Department
2815 S. Seacrest Blvd
Boynton Beach, Florida 33435
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 9:45 a.m., and to have with you at that time and place the following:
Any and all records including pathology reports, notes, bills for services, and
correspondence as well as the original pathology slides and recuts of any tissue samples
available pertaining to the person named below.
NAME: Bette Verp
DOB: 03/31/1924
SS#: a
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 giving 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 copics upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copiesto 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:
qd) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: /____/2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O, Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**1TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Boca Raton Fire Rescue
6500 Congress Avenue, Suite 200
Boca Raton, Florida 33487
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 10:00 a.m., and to have with you at that time and place the following:
Any and all office records, transport record, office cards, written memoranda,
correspondence, x-rays, x-ray reports, bills, charges and any other records pertaining to
the care and treatment of the person named below, as well as your incident report, laser
copies of any photographs, memoranda, and all investigation notes and any and all other
reports and records in your custody.
NAME: Bette Verp
DOB: 03/31/1924
SS#: |
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 giving 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 thepayment 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:
qd) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc. i
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Delray Hospital
Attn: Medical Records Department
5362 Linton Blvd
Delray Beach, Florida 33484
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 10:15 a.m., and to have with you at that time and place the following:
Any and all in-patient, out-patient and emergency room records including but not limited
to reports, charts, documents, microfilmed documents, radiology reports and radiology
studies including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills
for services (paid or unpaid), emergency room discharge instructions, correspondence,
laser copies of photographs, psychological records, requests for records, and any and all
other evidence relating to the examination, treatment care, diagnosis, physical and mental
condition of the person named below, from the inception of your records to the present.
NAME: Bette Verp
DOB: 03/31/1924
SS#: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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena 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.
Tf 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 may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Delray Hospital
Attn: Billing Department
5362 Linton Blvd
Delray Beach, Florida 33484
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 10:30 a.m., and to have with you at that time and place the following:
Any and all itemized statements (paid or unpaid) of the billing charges pertaining to the
care and treatment of the patient, from the inception of your records to the present.
NAME: Bette Verp
DOB: 03/31/1924
SS#: a
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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena and thereby eliminate yourappearance 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:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: /___ 1/2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400 i
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No, 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Delray Hospital
Attn: Radiology Department
5362 Linton Blyd
Delray Beach, Florida 33484
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 10:45 a.m., and to have with you at that time and place the following:
Any and all medical records, final reports, preliminary reports, requisition slips, patient
information sheets, bills, x-rays, CT scans, MRI’s, ultrasounds, Mammograms and any
other diagnostic tests as well as all documents included within the x-ray jacket for all films
pertaining to the individual named below:
NAME: Bette Verp
DOB: 03/31/1924
SS#: Pe
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 giving 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 thepayment 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:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
‘WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E, Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E, Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
ys.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Delray Hospital
Attn: Pathology Department
5362 Linton Blvd
Delray Beach, Florida 33484
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 11:00 a.m., and to have with you at that time and place the following:
Any and all records including pathology reports, notes, bills for services, and
correspondence as well as the original pathology slides and recuts of any tissue samples
available pertaining to the person named below.
NAME: Bette Verp
DOB: 03/31/1924
SS#: Le
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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copiesto 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:
(1) appear as specified; or
(2) _ furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
tespond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attomey for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**]F REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Peter Tuby, MD
5258 Linton Blvd, Suite 291
Delray Beach, Florida 33484
‘YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 11:15 a.m., and to have with you at that time and place the following:
Any and all office records, office cards, written memoranda, correspondence, radiology
reports and radiology studies including x-rays, ultrasounds, MRI, CT and mammograms,
notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right,
charges, prescriptions, referral forms, phone messages, patient information forms, laser
copies of any photographs, and any other records pertaining to the care and treatment of
the person named below.
****PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN
‘YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES
AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS****
NAME: Bette Verp
DOB: 03/31/1924
SS#: aThese 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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena 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:
qd) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attormey whose name appears on
this subpoena and unless excused from this subpoena: by this attorney or the Court, you shall
respond to this subpoena as directed. i
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXXK MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Heartland Convalescent Center
7225 Boca Del Mar Drive
Boca Raton, Florida 33433
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 11:30 a.m., and to have'with you at that time and place the following:
Any and all records including but not limited to reports, charts, documents, microfilmed
documents, radiology reports and radiology studies including ultrasounds, x-rays, MRI,
CT and mammograms, pathology slides, bills for services (paid or unpaid), itemized
statements, instructions, correspondence, laser copies of photographs, psychological
records, requests for records, referral forms, prescriptions, discharge instructions and any
and all other evidence relating to the examination, treatment care, diagnosis, physical and
mental condition of the person named below, from the inception of your records to the
present.
NAME: Bette Verp
DOB: 03/31/1924
ssThese 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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena 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:
(1) appear as specified; or
(2). furnish the records instead of appearing as provided above; or
(3) -object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
VS.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Seacrest Community Home Health Services
2828 South Seacrest Blvd, Suite 212
Boynton Beach, Florida 33435
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 9:15 a.m., and to have with you at that time and place the following:
Any and all records including but not limited to medical and psychological records, home
visit logs, reports, instructions, charts, documents, notes, progress notes, written
memoranda, correspondence, treatment plans, assessments, radiology reports and
radiology studies including ultrasounds, x-rays, MRI, CT scans, pathology slides, bills for
services (paid or unpaid), itemized statements, laser copies of photographs, requests for
records, and any and all other evidence relating to the examination, treatment care,
diagnosis, physical and mental condition of the person named below, from the inception of
your records to the present.
NAME: Bette Verp
DOB: 03/31/1924
SS#: LnThese 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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation, You may mail or deliver the copies
to the attorney whose name appears on this subpoena 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:
qd) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1460
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
RAJ Rehab
6200 W. Atlantic Avenue
Delray Beach, Florida 33484
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 9:30 a.m., and to have with you at that time and place the following:
Any and all medical, physical therapy, occupational/vocational records and treatment
plans, including but not limited to office records, written memoranda, phone messages,
reports, documents, instructions, charts, documents, patient information, forms, notes,
referral forms, prescriptions, assessments, logs, progress notes, evaluations, records of
physical examinations, radiology reports and radiology studies including ultrasounds, x-
rays, MRI, CT scans, bills for services (paid or unpaid), itemized statements, liens against
proceeds of lawsuits discharge instructions, correspondence, laser copies of photographs,
psychological records, requests for records, and any and all other evidence relating to the
examination, treatment care, diagnosis, physical and mental condition of the person named
below, from the inception of your records to the present.
NAME: Bette Verp
DOB: 03/31/1924
ssThese 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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena 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:
qd) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attomey for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/ema
IN THE CIRCUIT COURT.OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA;
TO: Records Custodian of:
Dr. Jonathan Tarrash, MD
Advanced Pain Medicine & Rehabilitation
14610 Military Trail Ste G2
Delray Beach, Florida 33484
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 9:45 a.m., and to have with you at that time and place the following:
Any and all office records, office cards, written memoranda, correspondence, radiology
reports and radiology studies including x-rays, ultrasounds, MRI, CT and mammograms,
notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right,
charges, prescriptions, referral forms, phone messages, patient information forms, laser
copies of any photographs, and any other records pertaining to the care and treatment of
the person named below.
****PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN
YOUR POSSESSION.. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES
AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS****NAME: Bette Verp
DOB: 03/31/1924
SS#: a
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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena 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:
qd) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attomey for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/ema
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Dr. Estrin
Rand Institute
5 West Sample Road
Deerfield Beach, Florida 33064
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 10:00 a.m., and to have with you at that time and place the following:
Any and all office records, office cards, written memoranda, correspondence, radiology
reports and radiology studies including x-rays, ultrasounds, MRI, CT and mammograms,
notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right,
charges, prescriptions, referral forms, phone messages, patient information forms, laser
copies of any photographs, and any other records pertaining to the care and treatment of
the person named below.
****PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN
YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES
AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS****NAME: Bette Verp
DOB: 03/31/1924
SS#: a
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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena 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:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attorney whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O.-Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 24177661325-7/JEZ/cma
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION
husband,
CASE NO. 50 2008 CA 002451XXXX MB
Plaintiffs,
vs.
PORTA BELLA YACHT & TENNIS CLUB
CONDOMINIUM ASSOCIATION, a Florida
corporation,
Defendant.
/
SUBPQENA DUCES TECUM WITHOUT DEPOSITION**
**TF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Medicare
P.O. Box 1798
Jacksonville, Florida 32231
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April
30, 2008, at 10:15 a.m., and to have with you at that time and place the following:
Any and all records, reports, correspondence, medical bills, medical reports, claim
information, payout information, referral requests and approvals regarding the person
named below, under your insurance policy.
NAME: Bette Verp
DOB: 03/31/1924
SS#:
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 giving legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena and thereby eliminate yourappearance 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:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena
you may be in contempt of court. You are subpoenaed by the attomey whose name appears on
this subpoena and unless excused from this subpoena by this attorney or the Court, you shall
respond to this subpoena as directed.
DATED: / /2008
WICKER, SMITH, O'HARA, MCCOY &
FORD, P.A.
Attorney for Porta Bella Yacht & Tennis
Club Condominium Association, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
P.O. Box 14460
Ft. Lauderdale, FL 33302
Phone: (954) 847-4800
Fax: (954) 760-9353
James E. Zloch
Florida Bar No. 241776
Preview
61325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, : 4 CASE NO. 50 2008 CA 002451XXXX MB A / Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service is by delivery, or 15 days from the date of service, if service is by mail, and 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: Records Custodian of: Records Custodian of: Bethesda Memorial Hospital Heartland Convalescent Center 2815 S. Seacrest Blvd 7225 Boca Del Mar Drive Boynton Beach, Florida 33435 Boca Raton, Florida 33433 Records Custodian of: Records Custodian of: Boca Raton Fire Rescue Seacrest Community Home Health Services 6500 Congress Avenue, Suite 200 2828 South Seacrest Blvd, Suite 212 Boca Raton, Florida 33487 Boynton Beach, Florida 33435 Records Custodian of: Records Custodian of: Delray Hospital RAJ Rehab 5362 Linton Blvd 6200 W. Atlantic Avenue Delray Beach, Florida 33484 Delray Beach, Florida 33484 Records Custodian of: Records Custodian of: Peter Tuby, MD Dr. Jonathan Tarrash, MD 5258 Linton Blvd, Suite 291 Advanced Pain Medicine & Rehabilitation Delray Beach, Florida 33484 14610 Military Trail Ste G2 Delray Beach, Florida 33484Records Custodian of: Dr. Estrin Rand Institute 5 West Sample Road Deerfield Beach, Florida 33064 CASE NO. 50 2008 CA 002451XXXX MB Records Custodian of: Medicare P.O. Box 1798 Jacksonville, Florida 32231 who are not parties and whose addresses are indicated on the attached subpoenas, to produce the items listed at the time and place specified in the subpoena. WE HEREBY CERTIFY that a true copy of the foregoing was mailed this ( ) day of > 2008 to the attached service list. Geri Sue Straus, Esq. Jacobs & Straus, P.A. 1098 Northwest Boca Raton Boulevard Boca Raton, FL 33432 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 By: fe Florida Bar No. 241776 Service List61325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB At Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Bethesda Memorial Hospital Attn: Medical Records Department 2815 S. Seacrest Blvd Boynton Beach, Florida 33435 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 9:00 a.m., and to have with you at that time and place the following: Any and all in-patient, out-patient and emergency room records including but not limited to reports, charts, documents, microfilmed documents, radiology reports and radiology studies including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services (paid or unpaid), emergency room discharge instructions, correspondence, laser copies of photographs, psychological records, requests for records, and any and all other evidence relating to the examination, treatment care, diagnosis, physical and mental condition of the person named below, from the inception of your records to the present. NAME: Bette Verp DOB: 03/31/1924 SS#: |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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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 attomey whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN. 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 may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attomey or the Court, you shall tespond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Bethesda Memorial Hospital Attn: Billing Department 2815 S. Seacrest Blvd Boynton Beach, Florida 33435 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 9:15 a.m., and to have with you at that time and place the following: Any and all itemized statements (paid or unpaid) of the billing charges pertaining to the care and treatment of the patient, from the inception of your records to the present. NAME: Bette Verp DOB: 03/31/1924 SS#: a 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate yourappearance 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: qd) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E, Zloch Florida Bar No. 24177661325-7/JEZ/cema IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Bethesda Memorial Hospital Attn: Radiology Department 2815 S. Seacrest Blvd Boynton Beach, Florida 33435 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 9:30 a.m., and to have with you at that time and place the following: Any and all medical records, final reports, preliminary reports, requisition slips, patient information sheets, bills, x-rays, CT scans, MRI’s, ultrasounds, mammograms and any other diagnostic tests as well as all documents included within the x-ray jacket for all films pertaining to the individual named below: NAME: Bette Verp DOB: 03/31/1924 SS#: | 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 giving 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 thepayment 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: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Bethesda Memorial Hospital Attn: Pathology Department 2815 S. Seacrest Blvd Boynton Beach, Florida 33435 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 9:45 a.m., and to have with you at that time and place the following: Any and all records including pathology reports, notes, bills for services, and correspondence as well as the original pathology slides and recuts of any tissue samples available pertaining to the person named below. NAME: Bette Verp DOB: 03/31/1924 SS#: a 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 giving 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 copics upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copiesto 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: qd) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: /____/2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O, Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **1TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Boca Raton Fire Rescue 6500 Congress Avenue, Suite 200 Boca Raton, Florida 33487 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 10:00 a.m., and to have with you at that time and place the following: Any and all office records, transport record, office cards, written memoranda, correspondence, x-rays, x-ray reports, bills, charges and any other records pertaining to the care and treatment of the person named below, as well as your incident report, laser copies of any photographs, memoranda, and all investigation notes and any and all other reports and records in your custody. NAME: Bette Verp DOB: 03/31/1924 SS#: | 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 giving 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 thepayment 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: qd) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. i 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Delray Hospital Attn: Medical Records Department 5362 Linton Blvd Delray Beach, Florida 33484 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 10:15 a.m., and to have with you at that time and place the following: Any and all in-patient, out-patient and emergency room records including but not limited to reports, charts, documents, microfilmed documents, radiology reports and radiology studies including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services (paid or unpaid), emergency room discharge instructions, correspondence, laser copies of photographs, psychological records, requests for records, and any and all other evidence relating to the examination, treatment care, diagnosis, physical and mental condition of the person named below, from the inception of your records to the present. NAME: Bette Verp DOB: 03/31/1924 SS#: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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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. Tf 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 may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Delray Hospital Attn: Billing Department 5362 Linton Blvd Delray Beach, Florida 33484 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 10:30 a.m., and to have with you at that time and place the following: Any and all itemized statements (paid or unpaid) of the billing charges pertaining to the care and treatment of the patient, from the inception of your records to the present. NAME: Bette Verp DOB: 03/31/1924 SS#: a 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate yourappearance 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: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: /___ 1/2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 i P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No, 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Delray Hospital Attn: Radiology Department 5362 Linton Blyd Delray Beach, Florida 33484 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 10:45 a.m., and to have with you at that time and place the following: Any and all medical records, final reports, preliminary reports, requisition slips, patient information sheets, bills, x-rays, CT scans, MRI’s, ultrasounds, Mammograms and any other diagnostic tests as well as all documents included within the x-ray jacket for all films pertaining to the individual named below: NAME: Bette Verp DOB: 03/31/1924 SS#: Pe 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 giving 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 thepayment 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: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 ‘WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E, Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E, Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, ys. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Delray Hospital Attn: Pathology Department 5362 Linton Blvd Delray Beach, Florida 33484 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 11:00 a.m., and to have with you at that time and place the following: Any and all records including pathology reports, notes, bills for services, and correspondence as well as the original pathology slides and recuts of any tissue samples available pertaining to the person named below. NAME: Bette Verp DOB: 03/31/1924 SS#: Le 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copiesto 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: (1) appear as specified; or (2) _ furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall tespond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attomey for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **]F REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Peter Tuby, MD 5258 Linton Blvd, Suite 291 Delray Beach, Florida 33484 ‘YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 11:15 a.m., and to have with you at that time and place the following: Any and all office records, office cards, written memoranda, correspondence, radiology reports and radiology studies including x-rays, ultrasounds, MRI, CT and mammograms, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. ****PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN ‘YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS**** NAME: Bette Verp DOB: 03/31/1924 SS#: aThese 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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: qd) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attormey whose name appears on this subpoena and unless excused from this subpoena: by this attorney or the Court, you shall respond to this subpoena as directed. i DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXXK MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Heartland Convalescent Center 7225 Boca Del Mar Drive Boca Raton, Florida 33433 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 11:30 a.m., and to have'with you at that time and place the following: Any and all records including but not limited to reports, charts, documents, microfilmed documents, radiology reports and radiology studies including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services (paid or unpaid), itemized statements, instructions, correspondence, laser copies of photographs, psychological records, requests for records, referral forms, prescriptions, discharge instructions and any and all other evidence relating to the examination, treatment care, diagnosis, physical and mental condition of the person named below, from the inception of your records to the present. NAME: Bette Verp DOB: 03/31/1924 ssThese 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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: (1) appear as specified; or (2). furnish the records instead of appearing as provided above; or (3) -object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, VS. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Seacrest Community Home Health Services 2828 South Seacrest Blvd, Suite 212 Boynton Beach, Florida 33435 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 9:15 a.m., and to have with you at that time and place the following: Any and all records including but not limited to medical and psychological records, home visit logs, reports, instructions, charts, documents, notes, progress notes, written memoranda, correspondence, treatment plans, assessments, radiology reports and radiology studies including ultrasounds, x-rays, MRI, CT scans, pathology slides, bills for services (paid or unpaid), itemized statements, laser copies of photographs, requests for records, and any and all other evidence relating to the examination, treatment care, diagnosis, physical and mental condition of the person named below, from the inception of your records to the present. NAME: Bette Verp DOB: 03/31/1924 SS#: LnThese 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation, You may mail or deliver the copies to the attorney whose name appears on this subpoena 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: qd) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1460 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: RAJ Rehab 6200 W. Atlantic Avenue Delray Beach, Florida 33484 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 9:30 a.m., and to have with you at that time and place the following: Any and all medical, physical therapy, occupational/vocational records and treatment plans, including but not limited to office records, written memoranda, phone messages, reports, documents, instructions, charts, documents, patient information, forms, notes, referral forms, prescriptions, assessments, logs, progress notes, evaluations, records of physical examinations, radiology reports and radiology studies including ultrasounds, x- rays, MRI, CT scans, bills for services (paid or unpaid), itemized statements, liens against proceeds of lawsuits discharge instructions, correspondence, laser copies of photographs, psychological records, requests for records, and any and all other evidence relating to the examination, treatment care, diagnosis, physical and mental condition of the person named below, from the inception of your records to the present. NAME: Bette Verp DOB: 03/31/1924 ssThese 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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: qd) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attomey for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/ema IN THE CIRCUIT COURT.OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA; TO: Records Custodian of: Dr. Jonathan Tarrash, MD Advanced Pain Medicine & Rehabilitation 14610 Military Trail Ste G2 Delray Beach, Florida 33484 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 9:45 a.m., and to have with you at that time and place the following: Any and all office records, office cards, written memoranda, correspondence, radiology reports and radiology studies including x-rays, ultrasounds, MRI, CT and mammograms, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. ****PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN YOUR POSSESSION.. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS****NAME: Bette Verp DOB: 03/31/1924 SS#: a 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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: qd) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attomey for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/ema IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Dr. Estrin Rand Institute 5 West Sample Road Deerfield Beach, Florida 33064 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 10:00 a.m., and to have with you at that time and place the following: Any and all office records, office cards, written memoranda, correspondence, radiology reports and radiology studies including x-rays, ultrasounds, MRI, CT and mammograms, notes, bills, guarantee of payment, liens against proceeds of lawsuits, assignment of right, charges, prescriptions, referral forms, phone messages, patient information forms, laser copies of any photographs, and any other records pertaining to the care and treatment of the person named below. ****PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS****NAME: Bette Verp DOB: 03/31/1924 SS#: a 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O.-Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 24177661325-7/JEZ/cma IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA BETTE VERP and MARTIN VERP, her GENERAL JURISDICTION DIVISION husband, CASE NO. 50 2008 CA 002451XXXX MB Plaintiffs, vs. PORTA BELLA YACHT & TENNIS CLUB CONDOMINIUM ASSOCIATION, a Florida corporation, Defendant. / SUBPQENA DUCES TECUM WITHOUT DEPOSITION** **TF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Medicare P.O. Box 1798 Jacksonville, Florida 32231 YOU ARE COMMANDED to appear at the offices of the undersigned counsel on April 30, 2008, at 10:15 a.m., and to have with you at that time and place the following: Any and all records, reports, correspondence, medical bills, medical reports, claim information, payout information, referral requests and approvals regarding the person named below, under your insurance policy. NAME: Bette Verp DOB: 03/31/1924 SS#: 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 giving legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate yourappearance 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: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena you may be in contempt of court. You are subpoenaed by the attomey whose name appears on this subpoena and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED: / /2008 WICKER, SMITH, O'HARA, MCCOY & FORD, P.A. Attorney for Porta Bella Yacht & Tennis Club Condominium Association, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 P.O. Box 14460 Ft. Lauderdale, FL 33302 Phone: (954) 847-4800 Fax: (954) 760-9353 James E. Zloch Florida Bar No. 241776