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  • ELVIS NEVERS VS CECILIA BERNADETTE SOLARES ET AL Auto Negligence document preview
  • ELVIS NEVERS VS CECILIA BERNADETTE SOLARES ET AL Auto Negligence document preview
  • ELVIS NEVERS VS CECILIA BERNADETTE SOLARES ET AL Auto Negligence document preview
  • ELVIS NEVERS VS CECILIA BERNADETTE SOLARES ET AL Auto Negligence document preview
  • ELVIS NEVERS VS CECILIA BERNADETTE SOLARES ET AL Auto Negligence document preview
  • ELVIS NEVERS VS CECILIA BERNADETTE SOLARES ET AL Auto Negligence document preview
  • ELVIS NEVERS VS CECILIA BERNADETTE SOLARES ET AL Auto Negligence document preview
  • ELVIS NEVERS VS CECILIA BERNADETTE SOLARES ET AL Auto Negligence document preview
						
                                

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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.