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Filing # 58121444 E-Filed 06/22/2017 01:15:01 PM
IN THE CIRCUIT COURT OF THE 17â„¢ 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 22â„¢ 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 17â„¢ 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 17â„¢ 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 17â„¢ 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