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Filing # 59947270 E-Filed 08/04/2017 10:23:46 AM
IN THE COUNTY COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO: 15-01461-CC-25
SUNSHINE MEDICAL HEALTH SERVICE,
INC A/A/O LISA LANGE,
Plaintiff,
v.
EQUITY INSURANCE CO.,
Defendant,
|
NOTICE OF PRODUCTION FROM NON-PARTY
To: All parties listed on the Certificate of Service below;
YOU ARE NOTIFIED that after 15 days from the date of electronic 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 issuance of the attached subpoena(s) directed to the Records Custodians of:
Florida Department of Motor Vehicles
2900 Apalachee Highway
Tallahassee, FL 32399
to produce the items listed at the time and place specified in the subpoena.CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was electronically mailed to:
Lewis J. Mertz, Esq., Mertz Law Group, 6291 SW 40 Street, Miami, FL 33155,
mertz@mertzlawgroup.com
on this 4" day of August, 2017.
Windhaven Claims Management, LLC
Attorney for Defendant
P.O. Box 269015
Miami, FL 33126
Telephone Number: 305-265-3149
Fax Number: 786-456-5327
By: {S| Wallace Richardson
Wallace Richardson, Esq.
FBN: 0544728
Primary:
wallace richardson@windhaveninsurance.com
70757T0757-1
IN THE COUNTY COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
SUNSHINE MEDICAL HEALTH SERVICE,
INC A/A/O LISA LANGE,
Plaintiff,
v.
EQUITY INSURANCE CO., CASE NO: 15-01461-CC-25
CIVIL DIVISION
Defendant
/
SUBPOENA DUCES TECUM
THE STATE OF FLORIDA
TO: — Records Custodian
Florida Department of Motor Vehicles
2900 Apalachee Highway
Tallahassee, FL 32399
YOU ARE COMMANDED to appear at or mail to: Unisource Discovery at 3901 NW 28
Street, gna Floor, Miami, FL 33142 fifteen (15) days from date of service and to have with you at that
time and place the following regarding the below-named individual
NAME: Edward William Lange DOB: XX/XX/XXXX SSN: XXX-XX-xxxx_ AKA:
Description - 2007 Dodge Caliber CXT - Sedan 4 Door
VIN - 1B3HB48B57D529233
*PLEASE DO NOT CALL OR SEND RECORDS TO LAW OFFICE. IF YOU HAVE ANY
QUESTIONS PLEASE CONTACT UNISOURCE DISCOVERY AT 866-580-0002*
Any and all records in your possession pertaining the individual and or car listed above.
IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT, NO
MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR TO THE PARTY TO WHOM
THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS SUBPOENA IS MEANT TO
INCLUDE ALL RECORDS, REGARDLESS OF DATE (PRIOR AND SUBSEQUENT TO THE
DATE OF ACCIDENT).-TITLE HISTORY-CERTIFIED
-DMV REPORT-CERTIFIED
-REGISTRATION
-AFFIDAVIT SIGNED OF RECORDS CUSTODIAN CERTIFIED
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 UNISOURCE DISCOVERY. the agent of the attomey whose name appears on this
subpoena on or before the scheduled date of production. “The records requested will be used for this
litigation only and will be returned or destroyed after litigation is complete.” Please contact them directly
and send all Records and all other items necessary for compliance to 3901 NW 28" Street, 2"! Floor,
Miami, FL 33142, Tel: 866-580-0002, Fax: 866-580-9070 and thereby eliminating your appearance at
the time and place specified above. DO NOT SEND RECORDS TO LAW OFFICE. THIS WILL NOT
BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. PLEASE ATTACH A COPY OF THIS
SUBPOENA TO THE RECORDS PROVIDED.
***CIOX, IOD & BACTES- PLEASE DO NOT COPY RECORDS IF THE COST EXCEEDS
$50.00 WITHOUT WRITTEN APPROVAL AND/OR PREPAYMENT***
****FOR FACILITIES THAT COPY RECORDS IN-HOUSE - Please DO NOT Copy Records
without written approval and/or prepayment if the cost exceeds $250.00****CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts
160 and 164, CFR 164.512 and FRCP 1.351, I hereby certify that I have complied with the regulations
and requirements to obtain patient health information and that the representations below are true and
correct
1 Ihave made a good faith attempt to provide written notice to the above-named patient, through
counsel, of intent to obtain the patient’s health information pursuant to this subpoena;
2 The written notice provided sufficient information about this litigation or proceeding in which the
protected health information is requested to permit the patient to raise an objection to the court or
administrative tribunal; and
3 The time for the patient to raise objections to the court or administrative tribunal has elapsed and;
no objections were filed; or all objections filed by the patient were resolved by the court or
administrative tribunal and the disclosure being sought are consistent with such resolution.
If you fail to:
() 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:
Windhaven Claims Management, LLC
Attorney for Defendant
P.O. Box 269015
Miami, FL 33126
By:
Wallace Richardson, Esq.
FBN: 0544728
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Filing # 59947270 E-Filed 08/04/2017 10:23:46 AM IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO: 15-01461-CC-25 SUNSHINE MEDICAL HEALTH SERVICE, INC A/A/O LISA LANGE, Plaintiff, v. EQUITY INSURANCE CO., Defendant, | NOTICE OF PRODUCTION FROM NON-PARTY To: All parties listed on the Certificate of Service below; YOU ARE NOTIFIED that after 15 days from the date of electronic 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 issuance of the attached subpoena(s) directed to the Records Custodians of: Florida Department of Motor Vehicles 2900 Apalachee Highway Tallahassee, FL 32399 to produce the items listed at the time and place specified in the subpoena.CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was electronically mailed to: Lewis J. Mertz, Esq., Mertz Law Group, 6291 SW 40 Street, Miami, FL 33155, mertz@mertzlawgroup.com on this 4" day of August, 2017. Windhaven Claims Management, LLC Attorney for Defendant P.O. Box 269015 Miami, FL 33126 Telephone Number: 305-265-3149 Fax Number: 786-456-5327 By: {S| Wallace Richardson Wallace Richardson, Esq. FBN: 0544728 Primary: wallace richardson@windhaveninsurance.com 70757T0757-1 IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA SUNSHINE MEDICAL HEALTH SERVICE, INC A/A/O LISA LANGE, Plaintiff, v. EQUITY INSURANCE CO., CASE NO: 15-01461-CC-25 CIVIL DIVISION Defendant / SUBPOENA DUCES TECUM THE STATE OF FLORIDA TO: — Records Custodian Florida Department of Motor Vehicles 2900 Apalachee Highway Tallahassee, FL 32399 YOU ARE COMMANDED to appear at or mail to: Unisource Discovery at 3901 NW 28 Street, gna Floor, Miami, FL 33142 fifteen (15) days from date of service and to have with you at that time and place the following regarding the below-named individual NAME: Edward William Lange DOB: XX/XX/XXXX SSN: XXX-XX-xxxx_ AKA: Description - 2007 Dodge Caliber CXT - Sedan 4 Door VIN - 1B3HB48B57D529233 *PLEASE DO NOT CALL OR SEND RECORDS TO LAW OFFICE. IF YOU HAVE ANY QUESTIONS PLEASE CONTACT UNISOURCE DISCOVERY AT 866-580-0002* Any and all records in your possession pertaining the individual and or car listed above. IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR TO THE PARTY TO WHOM THIS SUBPOENA IS DIRECTED, BE PRODUCED; THIS SUBPOENA IS MEANT TO INCLUDE ALL RECORDS, REGARDLESS OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT).-TITLE HISTORY-CERTIFIED -DMV REPORT-CERTIFIED -REGISTRATION -AFFIDAVIT SIGNED OF RECORDS CUSTODIAN CERTIFIED 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 UNISOURCE DISCOVERY. the agent of the attomey whose name appears on this subpoena on or before the scheduled date of production. “The records requested will be used for this litigation only and will be returned or destroyed after litigation is complete.” Please contact them directly and send all Records and all other items necessary for compliance to 3901 NW 28" Street, 2"! Floor, Miami, FL 33142, Tel: 866-580-0002, Fax: 866-580-9070 and thereby eliminating your appearance at the time and place specified above. DO NOT SEND RECORDS TO LAW OFFICE. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. PLEASE ATTACH A COPY OF THIS SUBPOENA TO THE RECORDS PROVIDED. ***CIOX, IOD & BACTES- PLEASE DO NOT COPY RECORDS IF THE COST EXCEEDS $50.00 WITHOUT WRITTEN APPROVAL AND/OR PREPAYMENT*** ****FOR FACILITIES THAT COPY RECORDS IN-HOUSE - Please DO NOT Copy Records without written approval and/or prepayment if the cost exceeds $250.00****CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, CFR 164.512 and FRCP 1.351, I hereby certify that I have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct 1 Ihave made a good faith attempt to provide written notice to the above-named patient, through counsel, of intent to obtain the patient’s health information pursuant to this subpoena; 2 The written notice provided sufficient information about this litigation or proceeding in which the protected health information is requested to permit the patient to raise an objection to the court or administrative tribunal; and 3 The time for the patient to raise objections to the court or administrative tribunal has elapsed and; no objections were filed; or all objections filed by the patient were resolved by the court or administrative tribunal and the disclosure being sought are consistent with such resolution. If you fail to: () 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: Windhaven Claims Management, LLC Attorney for Defendant P.O. Box 269015 Miami, FL 33126 By: Wallace Richardson, Esq. FBN: 0544728