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Filing # 121272026 E-Filed 02/11/2021 05:20:31 PM
IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA.
JOSE RODRIGUEZ, Case No.: CACE-20-017538
Plaintiff,
vs.
CELTIC INSURANCE COMPANY
d/b/a AMBETTER FROM SUNSHINE HEALTH,
Defendant.
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE NOTIFIED that after 10 days from the date of service of this notice 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 subpoena directed to FLORIDA OFFCIE OF INSURANCE
REGULATION, who is not a party and whose address is 200 East Gaines Street, Tallahassee, FL
32399, to produce the items listed at the time and place specified in the subpoena.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
U.S. Mail and/or E-Service compliant with Rule of Judicial Administration 2.516 delivery this
10th day of February 2021 to: Craig H. Smith, Esq., James L. VanLandingham, Esq., Counsel for
Defendant HOGAN LOVELLS US LLP, 600 Brickell Avenue, Suite 2700, Miami, FL, 33131,
craig.smith@hoganlovells.com,james.vanlandingham@hoganlovells.com
Gladys.cata@hoganlovells.com
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/11/2021 05:20:31 PM.****[4441378/1]
Respectfully submitted,
Your Insurance Attorney, PLLC
Health and Medicine Law Firm Division
Counsel for Plaintiff
2601 S. Bayshore Drive, 18th Floor
Miami, FL 33133
Ph: 305-444-5969
Service email:
health@mellawyers.com
Attormey email:
msanti@yourinsuranceattorney.com
jnunez@yourinsuranceattorney.com
By: /s/ Maria T. Santi
MARIA T. SANTI, ESQUIRE
Florida Bar No.: 117564IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
JOSE RODRIGUEZ, Case No.: CACE-20-017538
Plaintiff,
vs.
CELTIC INSURANCE COMPANY
d/b/a AMBETTER FROM SUNSHINE HEALTH,
Defendant.
ey
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
**THIS SUBPOENA IS HIPAA COMPLIANT**
(Records May Be Mailed in Lieu of Appearance)
THE STATE OF FLORIDA:
TO: FLORIDA OFFICE OF INSURANCE REGULATION
c/o Registered Agent
200 East Gaines Street, Tallahassee, FL 32399
YOU ARE COMMANDED to appear at the offices of YOUR INSURANCE ATTORNEY, PLLC
situated at, 2601 S. Bayshore Drive,18th Floor Miami, FL 33133, on , 2021, at 10:00 a.m.,
and to have with you at that time and place the following:
ALL ITEMS ENUMERATED ON EXHIBIT “A”
ATTACHED HERETO AND INCORPORATED HEREIN BY REFERENCE
Pursuant to 45 C.F.R. § 164.512, “A covered entity may use or disclose protected health
information without the written consent or authorization of the individual...to the extent that such
use or disclosure is required by law and the use or disclosure complied with and is limited to the
relevant requirements of such law.” Pursuant to 45 C.F.R. § 164.501, “Required by law” includes,
but not limited to, court orders and court ordered warrants; subpoenas or summons...a civil or an
authorized investigative demand” (emphasis added).
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
[4441378/1]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 this
[4441378/1]
day of February 2021.
FOR THE COURT
YOUR INSURANCE ATTORNEY, PLLC
Health and Medicine Law Firm Division
Counsel for Plaintiff
2601 S. Bayshore Drive, 18th Floor
Miami, FL 33133
Ph: 305-444-5969
Fax: 305-444-1939
Service email:
health@mellawyers.com
Attorney email:
msanti@yourinsuranceattorney.com
jnunez@yourinsuranceattorney.com
By: /s/ Maria T. Santi
MARIA T. SANTI, ESQUIRE
Florida Bar No.: 117564EXHIBIT “A” TO
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
DEFINITIONS
The term “documents” means and includes, without limitation, all writings of any kind,
including the originals and all non-identical copies or drafts, whether printed, recorded, stored, or
reproduced by any mechanical or electronic process or written or produced by hand, including
computer tapes (and backup tapes), whether different from the original by reason of any notation
made on such copy or draft or otherwise including, without limitation, correspondence,
memoranda, notes, diaries, statistics, letters, e-mail, electronic computer files, telegrams, minutes,
contracts, reports, accident reports, incident reports, studies, calculations, computations, surveys,
checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, circulars, trade
letters, advertisements, interoffice communications, offers, notations of any sort of
conversation(s), telephone calls, meetings or other communications, bulletins, printed matter,
computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations,
modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
or representations of any kind including, without limitation, photographs, charts, graphs,
microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
electric records or representations of any kind including, without limitation, tapes, cassettes and
disc recordings, and writings and printed material of every kind, whether or not the document is
out of your possession, custody or control.
The term “correspondence” means any tangible object that conveys information or
memorializes information that was conveyed in tangible or oral form including, but not limited to,
writings, letters, memoranda, electronic mail (otherwise known as “e-mail”), facsimiles, reports,
notes, telegrams and interoffice communication.
DOCUMENTS REQUESTED
1. Any and all documents (including, emails, letters, text messages) in your possession sent
from LSOP.Info@myfloridacfo.com or any email from the Florida Office of Insurance
regulation to Aurora Loaiza of Celtic Insurance Company from September 1, 2020 to
December 29, 2020.
2. Any and all documents (including, emails, letters, text messages)to and/or from Celtic
Insurance Company, related to service of process from April 2020 through the present.
3. Any and all documents (including, emails, letters, text messages) to and/or from Celtic
Insurance Company, related to Case No. CACE-20-017538 filed in the County Court of
the Seventeenth Judicial Circuit in and for Broward County, Florida.
4. Any and all correspondence you received from Celtic Insurance Company d/b/a Ambetter
Sunshine Health related to service of process for Case No. CACE-20-017538 filed in the
County Court of the Seventeenth Judicial Circuit in and for Broward County, Florida.
[4441378/1]5. Any and all correspondence you received from Aurora Loaiza of Celtic Insurance
Company d/b/a Ambetter Sunshine Health related to service of process for Case No.
CACE-20-017538 filed in the County Court of the Seventeenth Judicial Circuit in and for
Broward County, Florida.
6. Any and all copies of call logs related to service of process for Case No. CACE-20-017538
filed in the County Court of the Seventeenth Judicial Circuit in and for Broward County,
Florida.
Note: The afore-mentioned document requests do not seek documents that are protected
by privilege.
[4441378/1]
Preview
Filing # 121272026 E-Filed 02/11/2021 05:20:31 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. JOSE RODRIGUEZ, Case No.: CACE-20-017538 Plaintiff, vs. CELTIC INSURANCE COMPANY d/b/a AMBETTER FROM SUNSHINE HEALTH, Defendant. NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE NOTIFIED that after 10 days from the date of service of this notice 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 subpoena directed to FLORIDA OFFCIE OF INSURANCE REGULATION, who is not a party and whose address is 200 East Gaines Street, Tallahassee, FL 32399, to produce the items listed at the time and place specified in the subpoena. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail and/or E-Service compliant with Rule of Judicial Administration 2.516 delivery this 10th day of February 2021 to: Craig H. Smith, Esq., James L. VanLandingham, Esq., Counsel for Defendant HOGAN LOVELLS US LLP, 600 Brickell Avenue, Suite 2700, Miami, FL, 33131, craig.smith@hoganlovells.com,james.vanlandingham@hoganlovells.com Gladys.cata@hoganlovells.com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/11/2021 05:20:31 PM.****[4441378/1] Respectfully submitted, Your Insurance Attorney, PLLC Health and Medicine Law Firm Division Counsel for Plaintiff 2601 S. Bayshore Drive, 18th Floor Miami, FL 33133 Ph: 305-444-5969 Service email: health@mellawyers.com Attormey email: msanti@yourinsuranceattorney.com jnunez@yourinsuranceattorney.com By: /s/ Maria T. Santi MARIA T. SANTI, ESQUIRE Florida Bar No.: 117564IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JOSE RODRIGUEZ, Case No.: CACE-20-017538 Plaintiff, vs. CELTIC INSURANCE COMPANY d/b/a AMBETTER FROM SUNSHINE HEALTH, Defendant. ey SUBPOENA DUCES TECUM WITHOUT DEPOSITION **THIS SUBPOENA IS HIPAA COMPLIANT** (Records May Be Mailed in Lieu of Appearance) THE STATE OF FLORIDA: TO: FLORIDA OFFICE OF INSURANCE REGULATION c/o Registered Agent 200 East Gaines Street, Tallahassee, FL 32399 YOU ARE COMMANDED to appear at the offices of YOUR INSURANCE ATTORNEY, PLLC situated at, 2601 S. Bayshore Drive,18th Floor Miami, FL 33133, on , 2021, at 10:00 a.m., and to have with you at that time and place the following: ALL ITEMS ENUMERATED ON EXHIBIT “A” ATTACHED HERETO AND INCORPORATED HEREIN BY REFERENCE Pursuant to 45 C.F.R. § 164.512, “A covered entity may use or disclose protected health information without the written consent or authorization of the individual...to the extent that such use or disclosure is required by law and the use or disclosure complied with and is limited to the relevant requirements of such law.” Pursuant to 45 C.F.R. § 164.501, “Required by law” includes, but not limited to, court orders and court ordered warrants; subpoenas or summons...a civil or an authorized investigative demand” (emphasis added). 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 [4441378/1]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 this [4441378/1] day of February 2021. FOR THE COURT YOUR INSURANCE ATTORNEY, PLLC Health and Medicine Law Firm Division Counsel for Plaintiff 2601 S. Bayshore Drive, 18th Floor Miami, FL 33133 Ph: 305-444-5969 Fax: 305-444-1939 Service email: health@mellawyers.com Attorney email: msanti@yourinsuranceattorney.com jnunez@yourinsuranceattorney.com By: /s/ Maria T. Santi MARIA T. SANTI, ESQUIRE Florida Bar No.: 117564EXHIBIT “A” TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION DEFINITIONS The term “documents” means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether printed, recorded, stored, or reproduced by any mechanical or electronic process or written or produced by hand, including computer tapes (and backup tapes), whether different from the original by reason of any notation made on such copy or draft or otherwise including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e-mail, electronic computer files, telegrams, minutes, contracts, reports, accident reports, incident reports, studies, calculations, computations, surveys, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, circulars, trade letters, advertisements, interoffice communications, offers, notations of any sort of conversation(s), telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every kind, whether or not the document is out of your possession, custody or control. The term “correspondence” means any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, electronic mail (otherwise known as “e-mail”), facsimiles, reports, notes, telegrams and interoffice communication. DOCUMENTS REQUESTED 1. Any and all documents (including, emails, letters, text messages) in your possession sent from LSOP.Info@myfloridacfo.com or any email from the Florida Office of Insurance regulation to Aurora Loaiza of Celtic Insurance Company from September 1, 2020 to December 29, 2020. 2. Any and all documents (including, emails, letters, text messages)to and/or from Celtic Insurance Company, related to service of process from April 2020 through the present. 3. Any and all documents (including, emails, letters, text messages) to and/or from Celtic Insurance Company, related to Case No. CACE-20-017538 filed in the County Court of the Seventeenth Judicial Circuit in and for Broward County, Florida. 4. Any and all correspondence you received from Celtic Insurance Company d/b/a Ambetter Sunshine Health related to service of process for Case No. CACE-20-017538 filed in the County Court of the Seventeenth Judicial Circuit in and for Broward County, Florida. [4441378/1]5. Any and all correspondence you received from Aurora Loaiza of Celtic Insurance Company d/b/a Ambetter Sunshine Health related to service of process for Case No. CACE-20-017538 filed in the County Court of the Seventeenth Judicial Circuit in and for Broward County, Florida. 6. Any and all copies of call logs related to service of process for Case No. CACE-20-017538 filed in the County Court of the Seventeenth Judicial Circuit in and for Broward County, Florida. Note: The afore-mentioned document requests do not seek documents that are protected by privilege. [4441378/1]