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Filing # 29121268 E-Filed 06/30/2015 03:27:38 PM
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO.: 14-016683 CACE 03
BARBARA WILLIAMSON,
Plaintiff,
vs.
WYNMOOR COMMUNITY
COUNCIL, INC., a Florida
Non-Profit Corporation,
Defendant.
/
DEFENDANT’S NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if
no objection is received from any party, the undersigned will issue the attached
subpoenas directed to the following Records Custodian:
1. Rand Eye Institute
5 West Sample Road
Pompano Beach, FL 33064
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via electronic mail this 30th day of June, 2015 to: Glen B. Levine, Esq.,
pleadings@anl-law.com), Law Offices of Anidjar & Levine, P.A., 12 SE 7" Street, Suite
604, Fort Lauderdale, FL 33301.
GOLDEN & Grimes LLP
9350 South Dixie Highway, PH Il, Miami, Florida 33156, PH: (305) 670-4421; FX: (305) 670-4353
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 6/30/2015 3:27:38 PM.****CASE NO.: 14-016683 CACE 03
GOLDEN & GRIMES LLP
Attorneys for Defendant
9350 South Dixie Highway, PH IT
Miami, Florida 33156
PH: (305) 670-4421
FX: (305) 670-4353
BY: __ John D. Golden
JOHN D. GOLDEN
Florida Bar No.: 326399
igolden@goldengrimes.com
Gopen & Grimes LLP
9350 South Dixie Highway, PH 1, Miami, Florida 33156; PH: (305) 670-4421; FX: (305) 670-4353IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO.: 14-016683 CACE 03
BARBARA WILLIAMSON,
Plaintiff,
vs.
WYNMOOR COMMUNITY
COUNCIL, INC., a Florida
Non-Profit Corporation,
Defendant.
THE STATE OF FLORIDA
SUBPOENA DUCES TECUM FOR RECORDS
TO: Records Custodian
Rand Eye Institute
5 W. Sample Road
Pompano Beach, FL 33064
YOU ARE HEREBY COMMANDED to provide to the law offices of GOLDEN
& GRIMES LLP, 9350 South Dixie Highway, PH II, Miami, Florida 33156, on or before
the 31" day of July, 2015 the following:
ANY AND ALL RECORDS IN YOUR POSSESSION PERTAINING TO
BARBARA A. WILLIAMSON, including but not limited to: medical reports,
charts, documents, microfilmed documents, X-rays film, MRI films, films, CT
scan, radiology reports, laboratory reports, emergency room reports, doctors’ and
nurses’ notes, physical therapy reports, rehabilitation reports or evaluations, bills,
invoices or statements for services rendered relating to the examination, care,
treatment, diagnosis, and physical condition of Barbara Williamson, Date of Birth:
ee. SS ee from inception to present. WE ARE
REQUESTING ALL RECORDS OF BARBARA A. WILLIAMSON.
You may appear or deliver the copies to the attorney whose name appears on this
subpoena, together with your bill for same. You have the right to object to the production
pursuant to this subpoena at any time before production by giving written notice to the
GOLDEN & Grimes LLP
9350 South Dixie Highway, PH II, Miami, Florida 33156; PH: (305) 670-4421; FX: (305) 670-4353CASE NO.: 14-016683 CACE 03
attorney whose name appears on this subpoena. If you object to this subpoena, your
formal deposition will be taken as a non-expert custodian of the records and items sought
pursuant to F.R.C.P. 1.351.
Tf you fail to:
(1) _ furnish the records as provided above; or
(2) object to this subpoena,
you may be in contempt of Court. You are subpoenaed by the attorneys whose names
appear on this subpoena and unless excused from this subpoena by the attorneys or the
Court, you shall respond to this subpoena as directed.
DATED on.this day of July, 2015.
For the Court,
BY:____John D. Golden ___
John D. Golden, Esq.
Florida Bar No.: 326399
MAIL RECORDS TO:
John D. Golden, Esq.
GOLDEN & GRIMES LLP
9350 South Dixie Highway, PH II
Miami, Florida 33156
Telephone: (305) 670-4421 Facsimile: (305) 670-4353
Attorneys for Defendant
HIPAA Certificate: This certifies that this Subpoena has been issued in compliance with the Health
Insurance Portability and Accountability Act of 1996, (HIPPA), Public Law 104-901 and 45 CRF
164.512(e)(1)(ii) as this Subpoena has been issued pursuant to Rules1.410 and 1.351, Fla.R.Civ.P. The
Party issuing this Subpoena has made a good faith attempt to provide written notice to the
Plaintiff/Patient listed above by sending his/her attorney, a notice of the issuance of this Subpoena which
included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to
the court or administrative tribunal. The time for the Plaintiff/Patient to raise an objection pursuant to
Rule 1.351, Fla.R.Civ.P. has expired and no objections were filed. The undersigned further certified that
information and records hereby sought are specific and are minimally necessary to accomplish the
objectives of this action and will be used for no purpose other than the litigation in which this subpoena is
issued, and will be destroyed or returned to the custodian of said records at the end thereof. The
undersigned further certified that all litigants who have requested copies of the records hereby
subpoenaed pursuant to the Florida Rules of Civil Procedure will, as a condition precedent to being
provided said copies, certify that the records in question will be used only for the purpose of this litigation
and returned to their custodian or destroyed at the conclusion thereof.
GOLDEN & GRIMES LLP
9350 South Dixie Highway, PH II, Miami, Florida 33156, PH: (305) 670-4421; FX: (305) 670-4353
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Filing # 29121268 E-Filed 06/30/2015 03:27:38 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIRCUIT CIVIL DIVISION CASE NO.: 14-016683 CACE 03 BARBARA WILLIAMSON, Plaintiff, vs. WYNMOOR COMMUNITY COUNCIL, INC., a Florida Non-Profit Corporation, Defendant. / DEFENDANT’S NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if no objection is received from any party, the undersigned will issue the attached subpoenas directed to the following Records Custodian: 1. Rand Eye Institute 5 West Sample Road Pompano Beach, FL 33064 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via electronic mail this 30th day of June, 2015 to: Glen B. Levine, Esq., pleadings@anl-law.com), Law Offices of Anidjar & Levine, P.A., 12 SE 7" Street, Suite 604, Fort Lauderdale, FL 33301. GOLDEN & Grimes LLP 9350 South Dixie Highway, PH Il, Miami, Florida 33156, PH: (305) 670-4421; FX: (305) 670-4353 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 6/30/2015 3:27:38 PM.****CASE NO.: 14-016683 CACE 03 GOLDEN & GRIMES LLP Attorneys for Defendant 9350 South Dixie Highway, PH IT Miami, Florida 33156 PH: (305) 670-4421 FX: (305) 670-4353 BY: __ John D. Golden JOHN D. GOLDEN Florida Bar No.: 326399 igolden@goldengrimes.com Gopen & Grimes LLP 9350 South Dixie Highway, PH 1, Miami, Florida 33156; PH: (305) 670-4421; FX: (305) 670-4353IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIRCUIT CIVIL DIVISION CASE NO.: 14-016683 CACE 03 BARBARA WILLIAMSON, Plaintiff, vs. WYNMOOR COMMUNITY COUNCIL, INC., a Florida Non-Profit Corporation, Defendant. THE STATE OF FLORIDA SUBPOENA DUCES TECUM FOR RECORDS TO: Records Custodian Rand Eye Institute 5 W. Sample Road Pompano Beach, FL 33064 YOU ARE HEREBY COMMANDED to provide to the law offices of GOLDEN & GRIMES LLP, 9350 South Dixie Highway, PH II, Miami, Florida 33156, on or before the 31" day of July, 2015 the following: ANY AND ALL RECORDS IN YOUR POSSESSION PERTAINING TO BARBARA A. WILLIAMSON, including but not limited to: medical reports, charts, documents, microfilmed documents, X-rays film, MRI films, films, CT scan, radiology reports, laboratory reports, emergency room reports, doctors’ and nurses’ notes, physical therapy reports, rehabilitation reports or evaluations, bills, invoices or statements for services rendered relating to the examination, care, treatment, diagnosis, and physical condition of Barbara Williamson, Date of Birth: ee. SS ee from inception to present. WE ARE REQUESTING ALL RECORDS OF BARBARA A. WILLIAMSON. You may appear or deliver the copies to the attorney whose name appears on this subpoena, together with your bill for same. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the GOLDEN & Grimes LLP 9350 South Dixie Highway, PH II, Miami, Florida 33156; PH: (305) 670-4421; FX: (305) 670-4353CASE NO.: 14-016683 CACE 03 attorney whose name appears on this subpoena. If you object to this subpoena, your formal deposition will be taken as a non-expert custodian of the records and items sought pursuant to F.R.C.P. 1.351. Tf you fail to: (1) _ furnish the records as provided above; or (2) object to this subpoena, you may be in contempt of Court. You are subpoenaed by the attorneys whose names appear on this subpoena and unless excused from this subpoena by the attorneys or the Court, you shall respond to this subpoena as directed. DATED on.this day of July, 2015. For the Court, BY:____John D. Golden ___ John D. Golden, Esq. Florida Bar No.: 326399 MAIL RECORDS TO: John D. Golden, Esq. GOLDEN & GRIMES LLP 9350 South Dixie Highway, PH II Miami, Florida 33156 Telephone: (305) 670-4421 Facsimile: (305) 670-4353 Attorneys for Defendant HIPAA Certificate: This certifies that this Subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996, (HIPPA), Public Law 104-901 and 45 CRF 164.512(e)(1)(ii) as this Subpoena has been issued pursuant to Rules1.410 and 1.351, Fla.R.Civ.P. The Party issuing this Subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney, a notice of the issuance of this Subpoena which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal. The time for the Plaintiff/Patient to raise an objection pursuant to Rule 1.351, Fla.R.Civ.P. has expired and no objections were filed. The undersigned further certified that information and records hereby sought are specific and are minimally necessary to accomplish the objectives of this action and will be used for no purpose other than the litigation in which this subpoena is issued, and will be destroyed or returned to the custodian of said records at the end thereof. The undersigned further certified that all litigants who have requested copies of the records hereby subpoenaed pursuant to the Florida Rules of Civil Procedure will, as a condition precedent to being provided said copies, certify that the records in question will be used only for the purpose of this litigation and returned to their custodian or destroyed at the conclusion thereof. GOLDEN & GRIMES LLP 9350 South Dixie Highway, PH II, Miami, Florida 33156, PH: (305) 670-4421; FX: (305) 670-4353