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  • Ronald Vohs Plaintiff vs. Josimars Cleaning Services Corp, et al Defendant Neg - Premises Liability Residential document preview
  • Ronald Vohs Plaintiff vs. Josimars Cleaning Services Corp, et al Defendant Neg - Premises Liability Residential document preview
  • Ronald Vohs Plaintiff vs. Josimars Cleaning Services Corp, et al Defendant Neg - Premises Liability Residential document preview
  • Ronald Vohs Plaintiff vs. Josimars Cleaning Services Corp, et al Defendant Neg - Premises Liability Residential document preview
  • Ronald Vohs Plaintiff vs. Josimars Cleaning Services Corp, et al Defendant Neg - Premises Liability Residential document preview
  • Ronald Vohs Plaintiff vs. Josimars Cleaning Services Corp, et al Defendant Neg - Premises Liability Residential document preview
  • Ronald Vohs Plaintiff vs. Josimars Cleaning Services Corp, et al Defendant Neg - Premises Liability Residential document preview
  • Ronald Vohs Plaintiff vs. Josimars Cleaning Services Corp, et al Defendant Neg - Premises Liability Residential document preview
						
                                

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Filing # 58121444 E-Filed 06/22/2017 01:15:01 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, Plaintiff, CASE NO.: CACE-17-007673 DIVISION: 05 vs. JOSIMAR’S CLEANING SERVICES CORP., USA BR GENERAL SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES INC., AND COMCAST CORPORATION, Defendants. / NOTICE OF PRODUCTION FROM N RTY YOU ARE HEREBY NOTIFIED that after 15 days from the date of service of this Notice, the undersigned will issue subpoenas duces tecum directed to the Records Custodians of the below- listed entities, who are not parties to this action, for the production of the items specified on the subpoenas. Production shall be made on the dates and at the times and places specified. Copies of the subpoenas are attached hereto and have been served with this Notice to counsel of record. Record Custodian Vision works 805 S University Dr Plantation, FL 33324 Record Custodian Richard A. Norman — Optometrist 4671 S University Drive Davie FL 33328 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/22/2017 1:15:00 PM.****Record Custodian Florida United Radiology 1613 NW 136th Ave #200, Sunrise, FL 33323 Record Custodian Dr. Craig Uecker 3449 Johnson Street Hollywood, FL 33021 Record Custodian South Florida ENT Dr. Jonathon Cooper 601 N Flamingo Rd, Pembroke Pines, FL 33028 Record Custodian Aran Eye Associates Dr. Aran 14201 W Sunrise Blvd Sunrise, FL 33323 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 22™ day of June, 2017 a true copy of the foregoing was sent via Eservice to Yeemee Chan, Esq., Steinger, Iscoe & Greene, P.A., 2400 E. Commercial Blvd., Suite 900, Fort Lauderdale, FL 33308 @ ychan@injurylawyers.com and ganselmo@injurylawyers.com; Armando P. Rubio, Esq. and Kevin D. Pardifias, Esq., Fields Howell LLP, 9155 So. _Dadeland__Blvd., Suite 1012, Miami, FL 33156, _at arubio@fieldshowell.com; _aduarte@fieldshowell.com;__ ghauza@fieldshowell.com: __and kpardinas@fieldshowell.com; Peter Diamond, Esq. and Michael P. Rudd, Esq., Rudd & Diamond, P.A., 4000 Hollywood Blvd., Presidential Circle, Suite 120-N, Hollywood, FL 33021 at service@rudddiamond.com; Pdiamond@rudddiamond.com; and hcamejo@rudddiamond.com.COVan~ Connolly C. McArthur, Esquire FBN: 111244 FUDGE & McARTHUR, P.A. 650 16th Street North St. Petersburg, FL 33705 Phone: 727-490-3100/Fax: 727-490-3101 Primary: Eservice@fudgemcarthur,com Attorneys for DefendantIN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, Plaintiff, CASE NO.: CACE-17-007673 DIVISION: 05 vs. JOSIMAR’S CLEANING SERVICES CORP., USA BR GENERAL SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES INC., AND COMCAST CORPORATION, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Record Custodian Vision works 805 S University Dr Plantation, FL 33324 YOU ARE COMMANDED to appear at Fudge & McArthur, P.A., 650 16" Street North, St. Petersburg, Florida 33705 in Pinellas County, Florida, within fifteen (15) days from the date of service of this Subpoena and to have with you at that time and place the following: Re: RONALD VOHS ANY AND ALL PATIENT RECORDS WHETHER FOR MEDICAL, OSTEOPATHIC, CHIROPRACTIC, DENTAL, PHYSICAL THERAPY, REHABILITATION, ACUPUNCTURE, INCLUDING BUT NOT LIMITED TO DOCTORS' AND NURSES' OFFICE NOTES, HISTORIES AND PHYSICAL EXAMS, QUESTIONNAIRES COMPLETED BY PATIENT, HOSPITAL RECORDS WITH ADMISSION/DISCHARGE SUMMARIES, EMERGENCY ROOM RECORDS AND OPERATIVE REPORTS, CONSULTATIONS AND REFERRALS, TESTS AND TEST RESULTS, PRESCRIPTION RECORDS, TELEPHONE NOTATIONS, X- RAYS, CT-SCANS, MRI'S AND OTHER RADIOLOGY FILMS AND REPORTS, BILLING INVOICES AND STATEMENTS, INSURANCE CLAIM FORMS, CORRESPONDENCE,ETC., INCLUDING COMPUTER AND ANY OTHER ELECTRONIC DATA STORAGE FILES PERTAINING TO RONALD VOHS. THIS REQUEST DOES NOT SEEK RECORDS DEEMED PROTECTED UNDER THE PSYCHOTHERAPIST-PATIENT PRIVILEGE. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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 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 2017. Connolly C. McArthur, Esquire FBN: 111244 FUDGE & McARTHUR, P.A. 650 16th Street North St. Petersburg, FL 33705 Phone: 727-490-3100/Fax: 727-490-3101 Primary: Eservice@fudgemcarthur,com Secondary: Cmearthur@fudgemcarthur.com Attorneys for DefendantIN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, Plaintiff, CASE NO.: CACE-17-007673 DIVISION: 05 vs. JOSIMAR’S CLEANING SERVICES CORP., USA BR GENERAL SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES INC., AND COMCAST CORPORATION, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Record Custodian Richard A. Norman — Optometrist 4671 S University Drive Davie FL 33328 YOU ARE COMMANDED to appear at Fudge & McArthur, P.A., 650 16" Street North, St. Petersburg, Florida 33705 in Pinellas County, Florida, within fifteen (15) days from the date of service of this Subpoena and to have with you at that time and place the following: Re: RONALD VOHS ANY AND ALL PATIENT RECORDS WHETHER FOR MEDICAL, OSTEOPATHIC, CHIROPRACTIC, DENTAL, PHYSICAL THERAPY, REHABILITATION, ACUPUNCTURE, INCLUDING BUT NOT LIMITED TO DOCTORS' AND NURSES' OFFICE NOTES, HISTORIES AND PHYSICAL EXAMS, QUESTIONNAIRES COMPLETED BY PATIENT, HOSPITAL RECORDS WITH ADMISSION/DISCHARGE SUMMARIES, EMERGENCY ROOM RECORDS AND OPERATIVE REPORTS, CONSULTATIONS AND REFERRALS, TESTS AND TEST RESULTS, PRESCRIPTION RECORDS, TELEPHONE NOTATIONS, X- RAYS, CT-SCANS, MRI'S AND OTHER RADIOLOGY FILMS AND REPORTS, BILLING INVOICES AND STATEMENTS, INSURANCE CLAIM FORMS, CORRESPONDENCE,ETC., INCLUDING COMPUTER AND ANY OTHER ELECTRONIC DATA STORAGE FILES PERTAINING TO RONALD VOHS. THIS REQUEST DOES NOT SEEK RECORDS DEEMED PROTECTED UNDER THE PSYCHOTHERAPIST-PATIENT PRIVILEGE. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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 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 2017. Connolly C. McArthur, Esquire FBN: 111244 FUDGE & McARTHUR, P.A. 650 16th Street North St. Petersburg, FL 33705 Phone: 727-490-3100/Fax: 727-490-3101 Primary: Eservice@fudgemcarthur.com Secondary: Cmearthur@fudgemearthur.com Attorneys for DefendantIN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, Plaintiff, CASE NO.: CACE-17-007673 DIVISION: 05 vs. JOSIMAR’S CLEANING SERVICES CORP., USA BR GENERAL SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES INC., AND COMCAST CORPORATION, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Record Custodian Florida United Radiology 1613 NW 136th Ave #200, Sunrise, FL 33323 YOU ARE COMMANDED to appear at Fudge & McArthur, P.A., 650 16" Street North, St. Petersburg, Florida 33705 in Pinellas County, Florida, within fifteen (15) days from the date of service of this Subpoena and to have with you at that time and place the following: Re: RONALD VOHS ANY AND ALL PATIENT RECORDS WHETHER FOR MEDICAL, OSTEOPATHIC, CHIROPRACTIC, DENTAL, PHYSICAL THERAPY, REHABILITATION, ACUPUNCTURE, INCLUDING BUT NOT LIMITED TO DOCTORS' AND NURSES' OFFICE NOTES, HISTORIES AND PHYSICAL EXAMS, QUESTIONNAIRES COMPLETED BY PATIENT, HOSPITAL RECORDS WITH ADMISSION/DISCHARGE SUMMARIES, EMERGENCY ROOM RECORDS AND OPERATIVE REPORTS, CONSULTATIONS AND REFERRALS, TESTS AND TEST RESULTS, PRESCRIPTION RECORDS, TELEPHONE NOTATIONS, X- RAYS, CT-SCANS, MRI'S AND OTHER RADIOLOGY FILMS AND REPORTS, BILLING INVOICES AND STATEMENTS, INSURANCE CLAIM FORMS, CORRESPONDENCE,ETC., INCLUDING COMPUTER AND ANY OTHER ELECTRONIC DATA STORAGE FILES PERTAINING TO RONALD VOHS. THIS REQUEST DOES NOT SEEK RECORDS DEEMED PROTECTED UNDER THE PSYCHOTHERAPIST-PATIENT PRIVILEGE. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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 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 2017. Connolly C. McArthur, Esquire FBN: 111244 FUDGE & McARTHUR, P.A. 650 16th Street North St. Petersburg, FL 33705 Phone: 727-490-3100/Fax: 727-490-3101 Primary: Eservice@fudgemearthur.com Attorneys for DefendantIN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, Plaintiff, CASE NO.: CACE-17-007673 DIVISION: 05 vs. JOSIMAR’S CLEANING SERVICES CORP., USA BR GENERAL SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES INC., AND COMCAST CORPORATION, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Record Custodian Dr. Craig Uecker 3449 Johnson Street Hollywood, FL 33021 YOU ARE COMMANDED to appear at Fudge & McArthur, P.A., 650 16" Street North, St. Petersburg, Florida 33705 in Pinellas County, Florida, within fifteen (15) days from the date of service of this Subpoena and to have with you at that time and place the following: Re: RONALD VOHS ANY AND ALL PATIENT RECORDS WHETHER FOR MEDICAL, OSTEOPATHIC, CHIROPRACTIC, DENTAL, PHYSICAL THERAPY, REHABILITATION, ACUPUNCTURE, INCLUDING BUT NOT LIMITED TO DOCTORS' AND NURSES' OFFICE NOTES, HISTORIES AND PHYSICAL EXAMS, QUESTIONNAIRES COMPLETED BY PATIENT, HOSPITAL RECORDS WITH ADMISSION/DISCHARGE SUMMARIES, EMERGENCY ROOM RECORDS AND OPERATIVE REPORTS, CONSULTATIONS AND REFERRALS, TESTS AND TEST RESULTS, PRESCRIPTION RECORDS, TELEPHONE NOTATIONS, X- RAYS, CT-SCANS, MRI'S AND OTHER RADIOLOGY FILMS AND REPORTS, BILLING INVOICES AND STATEMENTS, INSURANCE CLAIM FORMS, CORRESPONDENCE,ETC., INCLUDING COMPUTER AND ANY OTHER ELECTRONIC DATA STORAGE FILES PERTAINING TO RONALD VOHS. THIS REQUEST DOES NOT SEEK RECORDS DEEMED PROTECTED UNDER THE PSYCHOTHERAPIST-PATIENT PRIVILEGE. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. ‘You may mail or deliver the copies to the attorney whose name appears on this subpoena 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 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 2017. Connolly C. McArthur, Esquire FBN: 111244 FUDGE & McARTHUR, P.A. 650 16th Street North St. Petersburg, FL 33705 Phone: 727-490-3100/Fax: 727-490-3101 Primary: Eservice@fudgemearthur.com Secondary: Cmearthur@fudgemcarthur.com Attorneys for DefendantIN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, Plaintiff, CASE NO.: CACE-17-007673 DIVISION: 05 vs. JOSIMAR’S CLEANING SERVICES CORP., USA BR GENERAL SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES INC., AND COMCAST CORPORATION, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Record Custodian South Florida ENT Dr. Jonathon Cooper 601 N Flamingo Rd, Pembroke Pines, FL 33028 YOU ARE COMMANDED to appear at Fudge & McArthur, P.A., 650 16" Street North, St. Petersburg, Florida 33705 in Pinellas County, Florida, within fifteen (15) days from the date of service of this Subpoena and to have with you at that time and place the following: Re: RONALD VOHS ANY AND ALL PATIENT RECORDS WHETHER FOR MEDICAL, OSTEOPATHIC, CHIROPRACTIC, DENTAL, PHYSICAL THERAPY, REHABILITATION, ACUPUNCTURE, INCLUDING BUT NOT LIMITED TO DOCTORS' AND NURSES' OFFICE NOTES, HISTORIES AND PHYSICAL EXAMS, QUESTIONNAIRES COMPLETED BY PATIENT, HOSPITAL RECORDS WITH ADMISSION/DISCHARGE SUMMARIES, EMERGENCY ROOM RECORDS AND OPERATIVE REPORTS, CONSULTATIONS AND REFERRALS, TESTS AND TEST RESULTS, PRESCRIPTION RECORDS, TELEPHONE NOTATIONS, X- RAYS, CT-SCANS, MRI'S AND OTHER RADIOLOGY FILMS AND REPORTS, BILLING INVOICES AND STATEMENTS, INSURANCE CLAIM FORMS, CORRESPONDENCE, 1ETC., INCLUDING COMPUTER AND ANY OTHER ELECTRONIC DATA STORAGE FILES PERTAINING TO RONALD VOHS. THIS REQUEST DOES NOT SEEK RECORDS DEEMED PROTECTED UNDER THE PSYCHOTHERAPIST-PATIENT PRIVILEGE. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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 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 2017. Connolly C. McArthur, Esquire FBN: 111244 FUDGE & McARTHUR, P.A. 650 16th Street North St. Petersburg, FL 33705 Phone: 727-490-3100/Fax: 727-490-3101 Primary: Eservice@fudgemcarthur.com Secondary: Cmcarthur@fudgemearthur.com Attorneys for DefendantIN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, Plaintiff, CASE NO.: CACE-17-007673 DIVISION: 0S vs. JOSIMAR’S CLEANING SERVICES CORP., USA BR GENERAL SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES INC., AND COMCAST CORPORATION, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: Record Custodian Aran Eye Associates Dr. Aran 14201 W Sunrise Blvd Sunrise, FL 33323 YOU ARE COMMANDED to appear at Fudge & McArthur, P.A., 650 16" Street North, St. Petersburg, Florida 33705 in Pinellas County, Florida, within fifteen (15) days from the date of service of this Subpoena and to have with you at that time and place the following: Re: RONALD VOHS ANY AND ALL PATIENT RECORDS WHETHER FOR MEDICAL, OSTEOPATHIC, CHIROPRACTIC, DENTAL, PHYSICAL THERAPY, REHABILITATION, ACUPUNCTURE, INCLUDING BUT NOT LIMITED TO DOCTORS' AND NURSES' OFFICE NOTES, HISTORIES AND PHYSICAL EXAMS, QUESTIONNAIRES COMPLETED BY PATIENT, HOSPITAL RECORDS WITH ADMISSION/DISCHARGE SUMMARIES, EMERGENCY ROOM RECORDS AND OPERATIVE REPORTS, CONSULTATIONS AND REFERRALS, TESTS AND TEST RESULTS, PRESCRIPTION RECORDS, TELEPHONE NOTATIONS, X- RAYS, CT-SCANS, MRI'S AND OTHER RADIOLOGY FILMS AND REPORTS, BILLING 1INVOICES AND STATEMENTS, INSURANCE CLAIM FORMS, CORRESPONDENCE, ETC., INCLUDING COMPUTER AND ANY OTHER ELECTRONIC DATA STORAGE FILES PERTAINING TO RONALD VOHS. THIS REQUEST DOES NOT SEEK RECORDS DEEMED PROTECTED UNDER THE PSYCHOTHERAPIST-PATIENT PRIVILEGE. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena 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 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 2017. Connolly C. McArthur, Esquire FBN: 111244 FUDGE & McARTHUR, P.A. 650 16th Street North St. Petersburg, FL 33705 Phone: 727-490-3100/Fax: 727-490-3101 Primary: Eservice@fudgemearthur.com Secondary: Cmcarthur@fudgemcarthur.com Attorneys for Defendant