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. IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 50 2005 CA 012194 XX hh
RALPH C. SMITH, SR. & ADELE SMITH, ET AL,
Plaintiff{s),
vs.
OAKWOOD CENTER OF THE PALM. BEACHES, INC.,
Defendant(s),
nat
im
/
ee
NOTICE OF PRODUCTION FROM NON-PARTY
ER ME RRUOUPUC TION FROM NON-PARTY
TO ALL PARTIES:
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
subpoena(s) directed to:
1) DR. BURTON GREENBERG
2) MICHAEL DAVID MILLSTEIN, DO
who are not parties, to produce the items listed at the time and place specified in the subpoena(s).
THEREBY CERTIFY that.a copy of the foregoing Notice of Production from Non-Party was
mailed this day of » 2008, to: WILLIAM W. PRICE, ESQUIRE, WILLIAM W.
PRICE, P.A., 320 FERN STREET, WEST PALM BEACH, FL 33401 (561) 659-3212
SONNEBORN, RUTTER, ET AL
Attorney for Defendant
154
By: f
79MITH, ESQUIRE
Floriga’Bar Nof 604143
R2.82S 507-H Co52-002921 83190-C00, IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 50 2005 CA 012194 XX
RALPH C. SMITH, SR. & ADELE SMITH, ET AL,
Plaintiff(s),
vs.
OAKWOOD CENTER OF THE PALM BEACHES, INC.,
Defendant(s),
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
(RECORDS MAIL IN ONLY)
THE STATE OF FLORIDA:
To: The Records Custodian for
DR. BURTON GREENBERG
600 UNIVERSITY BLVD.
SUITE 200
JUPITER, FL 33458
YOU ARE COMMANDED to furnish via U.S. Mail delivery to MCS, 7925 NW 12TH STREET,
SUITE 129, MIAMI, FL 33126 on 06/23/2008 at 9:00a.m., and to have with you at that time and
place the following:
Any and all medical records, billing records, reports, copies of reports from
consualting physicians, x-rays, EKG/EEGs, MRIs, Cat Scans, clinical records,
patient cards, memoranda, correspondence and all other information concerning the
physical examinations, treatment of and consultations.
RALPH C. SMITH JR., SSN OB: 11/07/1963
Copies of the jacket cover, every document from cover to cover and any and all
computer entries regarding this individual are to be produced in response to this subpoena.
R2.82S 507-H su14-016669 83190-L12These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to THE MCS GROUP INC., on behalf of 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 MCS GROUP INC., at 7925 NW 12TH STREET
Suite 129, MIAMI, FL 33126 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 MCS GROUP, INC. 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 to appear by the following attorney, and
unless excused from this subpoena by this attorney or the court, you shall respond to this
subpoena as directed.
DATED ON.
MICHAEL S. SMITH, ESQUIRE
Florida Bar No. 604143
SONNEBORN, RUTTER, ET AL
Attorney for Defendant
c/o THE MCS GROUP INC.
7925 NW 12TH STREET, SUITE 129
MIAMI, FL 33126
(305) 374-1166
CLAIM NO/ MHG02079-260
R2.82S 507-H su14-016669 83190-L12. IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 50 2005 CA 012194 XX
RALPH C. SMITH, SR. & ADELE SMITH, ET AL,
Plaintiff(s),
vs.
OAKWOOD CENTER OF THE PALM BEACHES, INC.,
Defendant(s),
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
(RECORDS MAIL IN ONLY)
THE STATE OF FLORIDA:
To: The Records Custodian for
MICHAEL DAVID MILLSTEIN, DO
210 JUPITER LAKES BLVD
BLDG 3000, SUITE 205
JUPITER, FL 33458
YOU ARE COMMANDED to furnish via U.S. Mail delivery to MCS, 7925 NW 12TH STREET,
SUITE 129, MIAMI, FL 33126 on 06/23/2008 at 9:00 a.m., and to have with you at that time and
place the following:
Any and all medical records, billing records, reports, copies of reports from
consualting physicians, x-rays, EKG/EEGs, MRIs, Cat Scans, clinical records,
patient cards, memoranda, correspondence and all other information concerning the
physical examinations, treatment of and consultations.
RALPH C. SMITH JR., SSN OB: 11/07/1963
Copies of the jacket cover, every document from cover to cover and any and all
computer entries regarding this individual are to be produced in response to this subpoena.
R2.82S 507-H svu14-016670 83190-L13These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to THE MCS GROUP INC., on behalf of 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 MCS GROUP INC., at 7925 NW 12TH STREET
Suite 129, MIAMI, FL 33126 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 MCS GROUP, INC. 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 to appear by the following attorney, and
unless excused from this subpoena by this attorney or the court, you shall respond to this
subpoena as directed.
DATED ON.
MICHAEL S. SMITH, ESQUIRE
Florida Bar No. 604143
SONNEBORN, RUTTER, ET AL
Attorney for Defendant
c/o THE MCS GROUP INC.
7925 NW 12TH STREET, SUITE 129
MIAMI, FL 33126
(305) 374-1166
CLAIM NO/ MHG02079-260
R2.82S 507-H su14-016670 83190-L13
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. IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2005 CA 012194 XX hh RALPH C. SMITH, SR. & ADELE SMITH, ET AL, Plaintiff{s), vs. OAKWOOD CENTER OF THE PALM. BEACHES, INC., Defendant(s), nat im / ee NOTICE OF PRODUCTION FROM NON-PARTY ER ME RRUOUPUC TION FROM NON-PARTY TO ALL PARTIES: 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 subpoena(s) directed to: 1) DR. BURTON GREENBERG 2) MICHAEL DAVID MILLSTEIN, DO who are not parties, to produce the items listed at the time and place specified in the subpoena(s). THEREBY CERTIFY that.a copy of the foregoing Notice of Production from Non-Party was mailed this day of » 2008, to: WILLIAM W. PRICE, ESQUIRE, WILLIAM W. PRICE, P.A., 320 FERN STREET, WEST PALM BEACH, FL 33401 (561) 659-3212 SONNEBORN, RUTTER, ET AL Attorney for Defendant 154 By: f 79MITH, ESQUIRE Floriga’Bar Nof 604143 R2.82S 507-H Co52-002921 83190-C00, IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2005 CA 012194 XX RALPH C. SMITH, SR. & ADELE SMITH, ET AL, Plaintiff(s), vs. OAKWOOD CENTER OF THE PALM BEACHES, INC., Defendant(s), SUBPOENA DUCES TECUM WITHOUT DEPOSITION (RECORDS MAIL IN ONLY) THE STATE OF FLORIDA: To: The Records Custodian for DR. BURTON GREENBERG 600 UNIVERSITY BLVD. SUITE 200 JUPITER, FL 33458 YOU ARE COMMANDED to furnish via U.S. Mail delivery to MCS, 7925 NW 12TH STREET, SUITE 129, MIAMI, FL 33126 on 06/23/2008 at 9:00a.m., and to have with you at that time and place the following: Any and all medical records, billing records, reports, copies of reports from consualting physicians, x-rays, EKG/EEGs, MRIs, Cat Scans, clinical records, patient cards, memoranda, correspondence and all other information concerning the physical examinations, treatment of and consultations. RALPH C. SMITH JR., SSN OB: 11/07/1963 Copies of the jacket cover, every document from cover to cover and any and all computer entries regarding this individual are to be produced in response to this subpoena. R2.82S 507-H su14-016669 83190-L12These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to THE MCS GROUP INC., on behalf of 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 MCS GROUP INC., at 7925 NW 12TH STREET Suite 129, MIAMI, FL 33126 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 MCS GROUP, INC. 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED ON. MICHAEL S. SMITH, ESQUIRE Florida Bar No. 604143 SONNEBORN, RUTTER, ET AL Attorney for Defendant c/o THE MCS GROUP INC. 7925 NW 12TH STREET, SUITE 129 MIAMI, FL 33126 (305) 374-1166 CLAIM NO/ MHG02079-260 R2.82S 507-H su14-016669 83190-L12. IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2005 CA 012194 XX RALPH C. SMITH, SR. & ADELE SMITH, ET AL, Plaintiff(s), vs. OAKWOOD CENTER OF THE PALM BEACHES, INC., Defendant(s), SUBPOENA DUCES TECUM WITHOUT DEPOSITION (RECORDS MAIL IN ONLY) THE STATE OF FLORIDA: To: The Records Custodian for MICHAEL DAVID MILLSTEIN, DO 210 JUPITER LAKES BLVD BLDG 3000, SUITE 205 JUPITER, FL 33458 YOU ARE COMMANDED to furnish via U.S. Mail delivery to MCS, 7925 NW 12TH STREET, SUITE 129, MIAMI, FL 33126 on 06/23/2008 at 9:00 a.m., and to have with you at that time and place the following: Any and all medical records, billing records, reports, copies of reports from consualting physicians, x-rays, EKG/EEGs, MRIs, Cat Scans, clinical records, patient cards, memoranda, correspondence and all other information concerning the physical examinations, treatment of and consultations. RALPH C. SMITH JR., SSN OB: 11/07/1963 Copies of the jacket cover, every document from cover to cover and any and all computer entries regarding this individual are to be produced in response to this subpoena. R2.82S 507-H svu14-016670 83190-L13These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to THE MCS GROUP INC., on behalf of 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 MCS GROUP INC., at 7925 NW 12TH STREET Suite 129, MIAMI, FL 33126 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 MCS GROUP, INC. 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED ON. MICHAEL S. SMITH, ESQUIRE Florida Bar No. 604143 SONNEBORN, RUTTER, ET AL Attorney for Defendant c/o THE MCS GROUP INC. 7925 NW 12TH STREET, SUITE 129 MIAMI, FL 33126 (305) 374-1166 CLAIM NO/ MHG02079-260 R2.82S 507-H su14-016670 83190-L13