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Filing # 112519242 E-Filed 08/27/2020 06:24:02 PM
92235-7
IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
ELVIS NEVERS CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2019-011633CA01
v.
CECILIA SOLARES
Defendant.
____________________________/
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service
is by delivery or email, or 15 days from the date of service if service is by mail, and if no objection
is received from any party, the undersigned will issue or apply to the clerk of this court for issuance
of the attached subpoenas directed to:
Dr. Rene Casanova Broward Health Coral Springs
3402 N Andrews Ave. Ext Attn: Medical, Billing, Radiology
Pompano Beach, FL 33064 3000 Coral Hills Dr
Coral Springs, FL 33065
Coral Springs Fire Department
2801 Coral Springs Dr
Coral Springs, FL 33065
who are not parties and whose addresses are indicated on the attached subpoenas, to produce the
items listed at the time and place specified in the subpoena.
WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida
ePortal to: Michael P. Maguire, lawpro70@aol.com
; on this 27th day of August, 2020.
CASE NO. 2019-011633CA01
/s/ Robert E. Paradela
Robert E. Paradela, Esquire
Florida Bar No. 842095
WICKER SMITH O'HARA MCCOY & FORD, P.A.
Attorneys for Cecilia Solares
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
92235-7
IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
ELVIS NEVERS CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2019-011633CA01
v.
CECILIA SOLARES
Defendant.
____________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Dr. Rene Casanova
3402 N Andrews Ave. Ext
Pompano Beach, FL 33064
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on
September 7, 2020, at 9:00 a.m., and to have with you at that time and place the following:
Any and all in-patient, out-patient and emergency room records including but not limited to
reports, charts, documents, microfilmed documents, radiology reports and radiology studies
including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services
(paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions,
correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG /
echocardiograms, requests for records, and any and all other evidence relating to the
examination, treatment care, diagnosis, physical and mental condition of the person named
below, from the inception of your records to the present.
IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00,
PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE-
APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF
YOUR INVOICE.
If the records are maintained in an electronic format, please produce all records via e-mail
FTLMedRecords@wickersmith.com , CD, USB flash drive, or a ShareFile link.
NAME: Elvis Nevers DOB: SS#:
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given
10 days’ notice to object our obtaining these records and this exact form has been provided
to the patient and/or the patient’s legal counsel.
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 must respond to this
subpoena as directed.
DATED on
/s/ Robert E. Paradela
Robert E. Paradela, Esquire
For the Court
Florida Bar No. 842095
WICKER, SMITH, O’HARA,McCOY & FORD, P.A.
Attorneys for Cecilia Solares
515 E. Las Olas Boulevard, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities
needing a special accommodation to participate in this proceeding should contact
the undersigned attorney’s secretary at the address and phone number given above
not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-
800-955-8770 via Florida Relay Service.
92235-7
IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
ELVIS NEVERS CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2019-011633CA01
v.
CECILIA SOLARES
Defendant.
____________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Coral Springs Fire Department
2801 Coral Springs Dr
Coral Springs, FL 33065
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on
September 7, 2020, at 9:00 a.m., and to have with you at that time and place the following:
Any and all office records, transport record, office cards, written memoranda, correspondence, x-
rays, x-ray reports, bills, payment ledgers, and payout logs, charges and any other records
pertaining to the care and treatment of the person named below, as well as your incident report,
laser copies of any photographs, memoranda, and all investigation notes and any and all other
reports and records in your custody.
IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00,
PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE-
APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF
YOUR INVOICE.
If the records are maintained in an electronic format, please produce all records via e-mail
FTLMedRecords@wickersmith.com , CD, USB flash drive, or a ShareFile link.
NAME: Elvis Nevers DOB: SS#:
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given
10 days’ notice to object our obtaining these records and this exact form has been provided
to the patient and/or the patient’s legal counsel.
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 must respond to this
subpoena as directed.
DATED on
/s/ Robert E. Paradela
Robert E. Paradela, Esquire
For the Court
Florida Bar No. 842095
WICKER, SMITH, O’HARA,McCOY & FORD, P.A.
Attorneys for Cecilia Solares
515 E. Las Olas Boulevard, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities
needing a special accommodation to participate in this proceeding should contact
the undersigned attorney’s secretary at the address and phone number given above
not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-
800-955-8770 via Florida Relay Service.
92235-7
IN THE CIRCUIT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
ELVIS NEVERS CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 2019-011633CA01
v.
CECILIA SOLARES
Defendant.
____________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Broward Health Coral Springs
Attn: Medical, Billing, Radiology
3000 Coral Hills Dr
Coral Springs, FL 33065
YOU ARE COMMANDED to appear at the offices of the undersigned counsel on
September 7, 2020, at 9:00 a.m., and to have with you at that time and place the following:
Any and all in-patient, out-patient and emergency room records including but not limited to
reports, charts, documents, microfilmed documents, radiology reports and radiology studies
including ultrasounds, x-rays, MRI, CT and mammograms, pathology slides, bills for services
(paid or unpaid), payment ledgers, payout logs, emergency room discharge instructions,
correspondence, laser copies of photographs, psychological records, cardiology / EEG / EKG /
echocardiograms, requests for records, and any and all other evidence relating to the
examination, treatment care, diagnosis, physical and mental condition of the person named
below, from the inception of your records to the present.
IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00,
PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE-
APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF
YOUR INVOICE.
If the records are maintained in an electronic format, please produce all records via e-mail
FTLMedRecords@wickersmith.com , CD, USB flash drive, or a ShareFile link.
NAME: Elvis Nevers DOB: SS#:
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given
10 days’ notice to object our obtaining these records and this exact form has been provided
to the patient and/or the patient’s legal counsel.
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 must respond to this
subpoena as directed.
DATED on
/s/ Robert E. Paradela
Robert E. Paradela, Esquire
For the Court
Florida Bar No. 842095
WICKER, SMITH, O’HARA,McCOY & FORD, P.A.
Attorneys for Cecilia Solares
515 E. Las Olas Boulevard, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
ftlcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities
needing a special accommodation to participate in this proceeding should contact
the undersigned attorney’s secretary at the address and phone number given above
not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-
800-955-8770 via Florida Relay Service.