Preview
Filing # 56298359 E-Filed 05/11/2017 11:35:27 AM
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 NON-PARTY
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
All-Pro Orthopaedics and Sports Medicine
17779 SW 2™ Street,
Hollywood FL 33029
All radiology films
Medical records from June 13, 2016 to Present
*4* FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 5/11/2017 11:35:26 AM.****Record Custodian
Dr. David Berndt
5930 SW 64th Ave,
Davie, FL 33314
Medical records from March 21, 2016 to Present
Record Custodian
Cleveland Clinic
3100 Weston Rd.
Weston FL 33331
Radiology films January 8, 2016 — Present
Record Custodian
Maya Physical Therapy
4022 Turquoise Trail
Weston FL 33331
Medical records from June 7, 2016 to Present
Record Custodian
Memorial Hospital West
703 N Flamingo Rd
Pembroke Pines, FL 33028
All radiology films and medical records from January 1, 2016 to present
Record Custodian
Palmetto General Hospital
2001 W 68 St.
Hialeah, FL 33016
All radiology films from February 1, 2016 to Present
Medical records from February 3, 2016 to present
Record Custodian
Humana - Medicare
111 Ryan Court, Suite 300
Pittsburgh, PA 15205
From January 8, 2016 to PresentCERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11" day of May, 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
injurylawyers.com
injurylawyers.com.
CE M4ar~
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@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
All-Pro Orthopaedics and Sports Medicine
17779 SW 2" Street,
Hollywood FL 33029
All radiology films
Medical records from June 13, 2016 to Present
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,
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.
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 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 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
Cleveland Clinic
3100 Weston Rd,
Weston FL 33331
Radiology films January 8, 2016 — Present
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: 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
Maya Physical Therapy
4022 Turquoise Trail
Weston FL 33331
Medical records from June 7, 2016 to Present
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
Memorial Hospital West
703 N Flamingo Rd
Pembroke Pines, FL 33028
All radiology films and medical records from January 1, 2016 to present
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
Palmetto General Hospital
2001 W 68 St.
Hialeah, FL 33016
All radiology films from February 1, 2016 to Present
Medical records from February 3, 2016 to present
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: 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
Humana - Medicare
111 Ryan Court, Suite 300
Pittsburgh, PA 15205
From January 8, 2016 to Present
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@fudgemeartl
Attorneys for Defendant
Preview
Filing # 56298359 E-Filed 05/11/2017 11:35:27 AM 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 NON-PARTY 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 All-Pro Orthopaedics and Sports Medicine 17779 SW 2™ Street, Hollywood FL 33029 All radiology films Medical records from June 13, 2016 to Present *4* FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 5/11/2017 11:35:26 AM.****Record Custodian Dr. David Berndt 5930 SW 64th Ave, Davie, FL 33314 Medical records from March 21, 2016 to Present Record Custodian Cleveland Clinic 3100 Weston Rd. Weston FL 33331 Radiology films January 8, 2016 — Present Record Custodian Maya Physical Therapy 4022 Turquoise Trail Weston FL 33331 Medical records from June 7, 2016 to Present Record Custodian Memorial Hospital West 703 N Flamingo Rd Pembroke Pines, FL 33028 All radiology films and medical records from January 1, 2016 to present Record Custodian Palmetto General Hospital 2001 W 68 St. Hialeah, FL 33016 All radiology films from February 1, 2016 to Present Medical records from February 3, 2016 to present Record Custodian Humana - Medicare 111 Ryan Court, Suite 300 Pittsburgh, PA 15205 From January 8, 2016 to PresentCERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11" day of May, 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 injurylawyers.com injurylawyers.com. CE M4ar~ 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@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 All-Pro Orthopaedics and Sports Medicine 17779 SW 2" Street, Hollywood FL 33029 All radiology films Medical records from June 13, 2016 to Present 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, 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. 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 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 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 Cleveland Clinic 3100 Weston Rd, Weston FL 33331 Radiology films January 8, 2016 — Present 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: 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 Maya Physical Therapy 4022 Turquoise Trail Weston FL 33331 Medical records from June 7, 2016 to Present 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 Memorial Hospital West 703 N Flamingo Rd Pembroke Pines, FL 33028 All radiology films and medical records from January 1, 2016 to present 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 Palmetto General Hospital 2001 W 68 St. Hialeah, FL 33016 All radiology films from February 1, 2016 to Present Medical records from February 3, 2016 to present 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: 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 Humana - Medicare 111 Ryan Court, Suite 300 Pittsburgh, PA 15205 From January 8, 2016 to Present 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@fudgemeartl Attorneys for Defendant