Preview
Filing # 131455208 E-Filed 07/27/2021 09:34:41 AM
CLAIM NO: 0511559726
ORDER #:FLO165696
‘TOTAL PAGES: 2
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA, FLORIDA
CIVIL DIVISION
KRISTIN RUTHERFORD
CASE NO. 2021-CA-681
Plaintiff{s),
VS.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS
FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
Notice, service is by email, and if no objection is received from any party, the undersigned will
issue or apply to the Clerk of this court for the issuance of the attached Subpoena(s) directed to
the following:
Medical Records Custodian for
TOTAL EYE CARE
406 EAST 9 MILE ROAD
PENSACOLA, FL 32514
Medical Records Custodian for
WEST FLORIDA MEDICAL CENTER CLINIC
8333 NORTH DAVIS HIGHWAY
PENSACOLA, FL 32514
Radiology Records Custodian for
WEST FLORIDA MEDICAL CENTER CLINIC - FILMS
8333 NORTH DAVIS HIGHWAY
PENSACOLA, FL 32514
Page 1 of 4CLAIM NO: 0511559726
ORDER #:FL0165696
TOTAL PAGES: 2
Medical Records Custodian for
MEDICAL CENTER CLINIC, PENSACOLA
8333 NORTH DAVIS HIGHWAY BUILDING 1
PENSACOLA, FL 32514
Radiology Records Custodian for
MEDICAL CENTER CLINIC - RADIOLOGY
8333 NORTH DAVIS HIGHWAY
PENSACOLA, FL 32514
Medical Records Custodian for
BAPTIST MEDICAL TOWERS
1717 NORTH E STREET
PENSACOLA, FL 32501
Medical Records Custodian for
BAPTIST MEDICAL GROUP - LADIES FIRST OB/GYN
3417 NORTH 12TH AVE.
PENSACOLA, FL 32503
Medical Records Custodian for
ALICIA CHEN, MD
4621 NORTH DAVIS HIGHWAY
PENSACOLA, FL 32503
Medical Records Custodian for
ADVANCED WOMEN'S CARE
525 BRENT LANE
PENSACOLA, FL 32503
Prescription & Pharmacy Records Custodian for
EXPRESS SCRIPTS, INC. C/O CORPORATION SERVICE COMPANY
8455 UNIVERSITY PLACE DRIVE
SAINT LOUIS, MO 63121
Insurance Records Custodian for
ANTHEM BLUE CROSS
21215 BURBANK BOULEVARD
WOODLAND HILLS, CA 91367
Tnsurance Records Custodian for
ANTHEM BLUE CROSS
21215 BURBANK BOULEVARD
WOODLAND HILLS, CA 91367
Page 2 of 4CLAIM NO: 0511559726
ORDER #:FL0165696
TOTAL PAGES: 2
Insurance Records Custodian for
BLUE CROSS BLUE SHIELD OF NORTH CAROLINA
P.O, BOX 2291
DURHAM, NC 27702
Insurance Records Custodian for
METROPOLITAN LIFE INSURANCE COMPANY
200 EAST GAINES STREET
TALLAHASSEE, FL 32399
Jnsurance Records Custodian for
BLUE CROSS BLUE SHIELD OF NORTH CAROLINA
P.O, BOX 2291
DURHAM, NC 27702
Employment & Payroll Records Custodian for
KINDRED AT HOME
5111 NORTH 12TH AVENUE
PENSACOLA, FL 32504.
Employment & Payroll Records Custodian for
ARCADIA HEALTH & REHABILITATION CENTER (GULF COAST HEALTHCARE)
10095 HILLVIEW DRIVE
PENSACOLA, FL 32514
The above listed are not a party to this lawsuit and ate requested to produce the items listed at
the time and place specified in the attached Subpoena(s).
If you wish to receive copies of these documents, please advise the undersigned, in writing,
and same will be provided, at a cost for photocopies, upon receipt.
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES
INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES.
PLEASE BE GOVERNED ACCORDINGLY.
pow
I HEREBY CERTIFY that on the ~) {day of __} uk : 202 {_a true and correct copy
of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been
furnished by email to:
BRIAN CONNORS, ESQ.
PERRY & YOUNG, P.A.
200 HARRISON AVENUE
PANAMA CITY, FL 32401
BCONNORS@PERRY-YOUNG.COM
Page 3 of 4CLAIM NO: 0511559726
ORDER #:FL0165696
TOTAL PAGES: 2,
DBARTON@PERRY-YOUNG.COM
ESERVICE@PERRY-YOUNG.COM
BOBBY WHITNEY, ESQ
SEYMOUR, WHITNEY & PAPPAS
150 NE EGLIN PKWY
FORT WALTON BEACH FL 32548
BWHITNEY @SEYMOUR-WHITNEY.COM
NBLAIS@SEYMOUR-WHITNEY.COM
NICOLE BLAIS
SEYMOUR, WHITNEY & PAPPAS
150 NE EGLIN PKWY
FORT WALTON BEACH FL 32548
CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT
1820 SOUTHEAST 18TH AVENUE, SUITE 1
OCALA, FL 34471
Telephone: 352-351-1119
Fax: 352-351-0151
By: /S/ Virgil W. Wright, IIT, Esq.
VIRGIL W. WRIGHT, IIL, ESQ.
FL BAR NO. 993141
PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS:
SERVICEV W W@CAMERONHODGES3.COM
Attorney for Defendant(s)
ALLSTATE INSURANCE
Page 4 of 4CLAIM NO.: 0511559726
ORDER #: FLO165696-021
‘TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA COUNTY, FLORIDA
CIVIL DIVISION
KRISTIN RUTHERFORD
CASE NO. 2021-CA-681
Plaintifits),
VS.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
|
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
TOTAL EYE CARE
406 EAST 9 MILE ROAD
PENSACOLA, FL 32514
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax ¢/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD
INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS,
PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL
OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND
OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY
RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION
RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS
OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND
TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL
RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS
MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF
THE PATIENT; AND
Page 1 of 3CLAIM NO.: 0511559726
ORDER #: F10165696-021
‘TOTAL PAGES: 3
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY
AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF
BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE
BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS
AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION; AND
COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER
SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT
SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD
KRISTIN LEIGH RUTHERFORD; DOB: EE SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
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 COMPEX LEGAL SERVICES, INC., the agent of
the attorney 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 Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC.
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3CLAIM NO.: 0511559726
ORDER #: FL0165696-021
TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1, 1 have 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 of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
tribunal and the disclosures being sought are consistent with such resolutions.
VIRGIL W. WRIGHT, Il], ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 993141
CAMERON, HODGES, COLEMAN, LAPOINTE &
WRIGHT
1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq.
OCALA, FL 34471 For the Court
Telephone: 352-351-1119
Page 3 of 3CLAIM NO.: 0511559726
ORDER #: FL0165696-022,
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA COUNTY, FLORIDA.
CIVIL DIVISION
KRISTIN RUTHERFORD
CASE NO. 2021-CA-681
Plaintiff(s),
vs.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
|
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
WEST FLORIDA MEDICAL CENTER CLINIC MAIN: 850-969-2121, M: 850-474-8299,
B: 850-474-8100, F: 850-494-5306
8333 NORTH DAVIS HIGHWAY
PENSACOLA, FL 32514
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc, located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD
INCLUDING, BUT NOT LIMITED TO, ALLL MEDICAL RECORDS, INTAKE FORMS,
PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL
OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND
OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY
RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION
RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS
OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND
TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL
RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS
MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF
THE PATIENT; AND
Page 1 of 3CLAIM NO.: 0511559726
ORDER #: FL0165696-022
TOTAL PAGES: 3
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY
AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF
BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE
BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS
AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION. KRISTIN RUTHERFORD
KRISTIN LEIGH RUTHERFORD; DOB: SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
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 COMPEX LEGAL SERVICES, INC., the agent of
the attorney 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 Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC.
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3CLAIM NO.: 0511559726
ORDER #: FL0165696-022
TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. {have 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 of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
tribunal and the disclosures being sought are consistent with such resolutions.
VIRGIL W. WRIGHT, III, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No, 993141
CAMERON, HODGES, COLEMAN, LAPOINTE &
WRIGHT
1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq.
OCALA, FL 34471 For the Court
Telephone: 352-351-1119
Page 3 of 3CLAIM NO.: 0511559726
ORDER #: FL0165696-023
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA COUNTY, FLORIDA
CIVIL DIVISION
KRISTIN RUTHERFORD
CASE NO. 2021-CA-681
Plaintiff(s),
vs.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
|
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
WEST FLORIDA MEDICAL CENTER CLINIC - FILMS 850-494-5306
8333 NORTH DAVIS HIGHWAY
PENSACOLA, FL 32514
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, $481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER
SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT
SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD
KRISTIN LEIGH RUTHERFORD; DOB: EE SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
Page 1 of3CLAIM NO.: 0811559726
ORDER #: F10165696-023
TOTAL PAGES: 3
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 COMPEX LEGAL SERVICES, INC., the agent of
the attorney 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 Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC.
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3CLAIM NO.: 0511559726
ORDER #: FL0165696-023
‘TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. | have 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 fo permit the patient to raise an objection to
the court or administrative tribunal; and
3. The time of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
trisunal and the disclosures being sought are consistent with such resolutions.
VIRGIL W. WRIGHT, Ill, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 993141
CAMERON, HODGES, COLEMAN, LAPOINTE &
WRIGHT
1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq.
OCALA, FL 34471 For the Court
Telephone: 352-351-1119
Page 3 of 3CLAIM NO.; 0511559726
ORDER #: FLO165696-024
TOTAL PAGES; 3
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA COUNTY, FLORIDA
CIVIL DIVISION
KRISTIN RUTHERFORD
CASE NO. 2021-CA-681
Plaintiff(s),
VS.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
MEDICAL CENTER CLINIC, PENSACOLA MAIN: 850-474-8000, M: 850-474-8299, B:
850-474-8100, F: 850-969-2134
8333 NORTH DAVIS HIGHWAY BUILDING 1
PENSACOLA, FL 32514
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD
INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS,
PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL
OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND
OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY
RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION
RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS
OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND
TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL
RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS
MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF
THE PATIENT; AND
Page 1 of 3CLAIM NO, ; 0511559726
ORDER #: FLO165696-024.
TOTAL PAGES: 3
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY
AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF
BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE
BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS
AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION. KRISTIN RUTHERFORD
KRISTIN LEIGH RUTHERFORD; DOB; EEE SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
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 COMPEX LEGAL SERVICES, INC., the agent of
the attorney 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 Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC.
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3CLAIM NO.: 0541559726
ORDER #: FL0165696-024
TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. | have 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 of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
tribunal and the disclosures being sought are consistent with such resolutions,
VIRGIL W. WRIGHT, IH, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 993141
CAMERON, HODGES, COLEMAN, LAPOINTE &
WRIGHT
1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq.
OCALA, FL 34471 For the Court
Telephone: 352-351-1119
Page 3 of 3CLAIM NO.: 0511559726
ORDER #; FLO165696-025
‘TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA COUNTY, FLORIDA
CIVIL DIVISION
KRISTIN RUTHERFORD
CASE NO. 2021-CA-681
Plaintiff(s),
VS.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
|
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
MEDICAL CENTER CLINIC - RADIOLOGY MAIN: 850-474-8000, M: 850-474-8299
8333 NORTH DAVIS HIGHWAY
PENSACOLA, FL 32514
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER
SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT
SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD
KRISTIN LEIGH RUTHERFORD; DOB: ESSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
Page 1 of 3CLAIM NO.: 0511559726
ORDER #: FL0165696-025
TOTAL PAGES: 3
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 COMPEX LEGAL SERVICES, INC., the agent of
the attorney 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 Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC.
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3CLAIM NO.: 0511559726
ORDER #: FL0165696-025
TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. | have 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 of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
tribunal and the disclosures being sought are consistent with such resolutions.
VIRGIL W. WRIGHT, fll, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 993141
CAMERON, HODGES, COLEMAN, LAPOINTE &
WRIGHT
1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq.
OCALA, FL 34471 For the Court
Telephone: 352-351-1119
Page 3 of 3CLAIM NO.: 0511559726
ORDER #: FLO165696-026
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA COUNTY, FLORIDA
CIVIL DIVISION
KRISTIN RUTHERFORD
CASE NO. 2021-CA-681
Plaintiff(s),
vs.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
|
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
BAPTIST MEDICAL TOWERS 850-434-4011
1717 NORTH E STREET
PENSACOLA, FL 32501
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD
INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS,
PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL
OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND
OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY
RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION
RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS
OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND
TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL
RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS
MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF
THE PATIENT; AND
Page 1 of 3CLAIM NO.: 0511559726
ORDER #: F10165696-026
‘TOTAL PAGES; 3
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR,
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-91CD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY
AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF
BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE
BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS
AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION; AND
COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER
SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT
SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD
KRISTIN LEIGH RUTHERFORD; DOB: ESSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
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 COMPEX LEGAL SERVICES, INC., the agent of
the attorney 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 Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC.
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel; 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3CLAIM NO.; 0511559726
ORDER #: FL0165696-026
TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. | have 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 of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
tribunal and the disclosures being sought are consistent with such resolutions.
VIRGIL W. WRIGHT, Ill, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 993141
CAMERON, HODGES, COLEMAN, LAPOINTE &
WRIGHT
1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: = /S/ Virgil W. Wright, lll, Esq.
OCALA, FL 34471 For the Court
Telephone: 352-351-1119
Page 3 of 3CLAIM NO.: 0511559726
ORDER #: FLO165696-027
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA COUNTY, FLORIDA
CIVIL DIVISION
KRISTIN RUTHERFORD
CASE NO. 2021-CA-681
Plaintiff(s),
Vs.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
|
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR,
BAPTIST MEDICAL GROUP - LADIES FIRST OB/GYN 850-432-7310
3417 NORTH 12TH AVE.
PENSACOLA, FL 32503
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD
INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS,
PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL
OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND
OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY
RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION
RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS
OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND
TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL
RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS
MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF
THE PATIENT; AND
Page 1 of 3CLAIM NO.; 0511559726
ORDER #: FL0165696-027
‘TOTAL PAGES: 3
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY
AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF
BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE
BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS
AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION; AND
COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER
SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT
SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD
KRISTIN LEIGH RUTHERFORD; DOB: SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
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 COMPEX LEGAL SERVICES, INC.., the agent of
the attorney 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 Compex Legal Services,
Ine. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC,
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel; 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3CLAIM NO.: 0511559726
ORDER #: FLO165696-027
TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. | have 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 of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
tribunal and the disclosures being sought are consistent with such resolutions.
VIRGIL W. WRIGHT, Ill, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 993141
CAMERON, HODGES, COLEMAN, LAPOINTE &
WRIGHT
1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: = /S/ Virgil W. Wright, Ill, Esq.
OCALA, FL 34471 For the Court
Telephone: 352-351-1119
Page 3 of 3CLAIM NO.: 0511559726
ORDER #: FLO165696-028
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA COUNTY, FLORIDA
CIVIL DIVISION
KRISTIN RUTHERFORD
Plaintifi(s),
CASE NO. 2021-CA-681
vs.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
|
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
ALICIA CHEN, MD 850-607-7177,850-741-4723
4621 NORTH DAVIS HIGHWAY
PENSACOLA, FL 32503
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD
INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS,
PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL
OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND
OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY
RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION
RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS
OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND
TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL
RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS
MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF
THE PATIENT; AND
Page 1 of 3CLAIM NO. 0511559726
ORDER #: FL0165696-028
TOTAL PAGES: 3
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY
AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF
BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE
BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS
AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION; AND
COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER
SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT
SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD
KRISTIN LEIGH RUTHERFORD; DOB: EEEESSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
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 COMPEX LEGAL SERVICES, INC., the agent of
the attorney 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 Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC.
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3CLAIM NO.: 0511559726
ORDER #: FLO165696-028
TOTAL PAGES: 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. {have 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 fo 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 of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
tribunal and the disclosures being sought are consistent with such resolutions.
VIRGIL W. WRIGHT, Ill, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 993141
CAMERON, HODGES, COLEMAN, LAPOINTE &
WRIGHT
1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq.
OCALA, FL 34471 For the Court
Telephone: 352-351-1119
Page 3 of 3CLAIM NO,: 0511559726
ORDER #: FL0165696-029
TOTAL PAGES; 3
IN THE CIRCUIT COURT OF THE
FIRST JUDICIAL COURT
IN AND FOR ESCAMBIA COUNTY, FLORIDA.
CIVIL DIVISION
KRISTIN RUTHERFORD
CASE NO. 2021-CA-681
Plaintiff(s),
vs.
KATHERINE BENOIT AND ALLSTATE FIRE
AND CASUALTY INSURANCE COMPANY
Defendant(s),
|
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
ADVANCED WOMEN'S CARE 850-471-2221
525 BRENT LANE
PENSACOLA, FL 32503
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD
INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS,
PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL
OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND
OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY
RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION
RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS
OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND
TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL
RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS
MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF
THE PATIENT; AND
Page Lof3CLAIM NO.: 0511559726
ORDER #: FL0165696-029
TOTAL PAGES: 3
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY
AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF
BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE
BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS
AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION; AND
COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER
SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT
SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD
KRISTIN LEIGH RUTHERFORD; DOB: IEE SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
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 COMPEX LEGAL SERVICES, INC., the agent of
the attorney 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 Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC,
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. 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 appear
Preview
Filing # 131455208 E-Filed 07/27/2021 09:34:41 AM CLAIM NO: 0511559726 ORDER #:FLO165696 ‘TOTAL PAGES: 2 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA, FLORIDA CIVIL DIVISION KRISTIN RUTHERFORD CASE NO. 2021-CA-681 Plaintiff{s), VS. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS FROM NON-PARTY YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this Notice, service is by email, and if no objection is received from any party, the undersigned will issue or apply to the Clerk of this court for the issuance of the attached Subpoena(s) directed to the following: Medical Records Custodian for TOTAL EYE CARE 406 EAST 9 MILE ROAD PENSACOLA, FL 32514 Medical Records Custodian for WEST FLORIDA MEDICAL CENTER CLINIC 8333 NORTH DAVIS HIGHWAY PENSACOLA, FL 32514 Radiology Records Custodian for WEST FLORIDA MEDICAL CENTER CLINIC - FILMS 8333 NORTH DAVIS HIGHWAY PENSACOLA, FL 32514 Page 1 of 4CLAIM NO: 0511559726 ORDER #:FL0165696 TOTAL PAGES: 2 Medical Records Custodian for MEDICAL CENTER CLINIC, PENSACOLA 8333 NORTH DAVIS HIGHWAY BUILDING 1 PENSACOLA, FL 32514 Radiology Records Custodian for MEDICAL CENTER CLINIC - RADIOLOGY 8333 NORTH DAVIS HIGHWAY PENSACOLA, FL 32514 Medical Records Custodian for BAPTIST MEDICAL TOWERS 1717 NORTH E STREET PENSACOLA, FL 32501 Medical Records Custodian for BAPTIST MEDICAL GROUP - LADIES FIRST OB/GYN 3417 NORTH 12TH AVE. PENSACOLA, FL 32503 Medical Records Custodian for ALICIA CHEN, MD 4621 NORTH DAVIS HIGHWAY PENSACOLA, FL 32503 Medical Records Custodian for ADVANCED WOMEN'S CARE 525 BRENT LANE PENSACOLA, FL 32503 Prescription & Pharmacy Records Custodian for EXPRESS SCRIPTS, INC. C/O CORPORATION SERVICE COMPANY 8455 UNIVERSITY PLACE DRIVE SAINT LOUIS, MO 63121 Insurance Records Custodian for ANTHEM BLUE CROSS 21215 BURBANK BOULEVARD WOODLAND HILLS, CA 91367 Tnsurance Records Custodian for ANTHEM BLUE CROSS 21215 BURBANK BOULEVARD WOODLAND HILLS, CA 91367 Page 2 of 4CLAIM NO: 0511559726 ORDER #:FL0165696 TOTAL PAGES: 2 Insurance Records Custodian for BLUE CROSS BLUE SHIELD OF NORTH CAROLINA P.O, BOX 2291 DURHAM, NC 27702 Insurance Records Custodian for METROPOLITAN LIFE INSURANCE COMPANY 200 EAST GAINES STREET TALLAHASSEE, FL 32399 Jnsurance Records Custodian for BLUE CROSS BLUE SHIELD OF NORTH CAROLINA P.O, BOX 2291 DURHAM, NC 27702 Employment & Payroll Records Custodian for KINDRED AT HOME 5111 NORTH 12TH AVENUE PENSACOLA, FL 32504. Employment & Payroll Records Custodian for ARCADIA HEALTH & REHABILITATION CENTER (GULF COAST HEALTHCARE) 10095 HILLVIEW DRIVE PENSACOLA, FL 32514 The above listed are not a party to this lawsuit and ate requested to produce the items listed at the time and place specified in the attached Subpoena(s). If you wish to receive copies of these documents, please advise the undersigned, in writing, and same will be provided, at a cost for photocopies, upon receipt. IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. PLEASE BE GOVERNED ACCORDINGLY. pow I HEREBY CERTIFY that on the ~) {day of __} uk : 202 {_a true and correct copy of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been furnished by email to: BRIAN CONNORS, ESQ. PERRY & YOUNG, P.A. 200 HARRISON AVENUE PANAMA CITY, FL 32401 BCONNORS@PERRY-YOUNG.COM Page 3 of 4CLAIM NO: 0511559726 ORDER #:FL0165696 TOTAL PAGES: 2, DBARTON@PERRY-YOUNG.COM ESERVICE@PERRY-YOUNG.COM BOBBY WHITNEY, ESQ SEYMOUR, WHITNEY & PAPPAS 150 NE EGLIN PKWY FORT WALTON BEACH FL 32548 BWHITNEY @SEYMOUR-WHITNEY.COM NBLAIS@SEYMOUR-WHITNEY.COM NICOLE BLAIS SEYMOUR, WHITNEY & PAPPAS 150 NE EGLIN PKWY FORT WALTON BEACH FL 32548 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 1820 SOUTHEAST 18TH AVENUE, SUITE 1 OCALA, FL 34471 Telephone: 352-351-1119 Fax: 352-351-0151 By: /S/ Virgil W. Wright, IIT, Esq. VIRGIL W. WRIGHT, IIL, ESQ. FL BAR NO. 993141 PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS: SERVICEV W W@CAMERONHODGES3.COM Attorney for Defendant(s) ALLSTATE INSURANCE Page 4 of 4CLAIM NO.: 0511559726 ORDER #: FLO165696-021 ‘TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA COUNTY, FLORIDA CIVIL DIVISION KRISTIN RUTHERFORD CASE NO. 2021-CA-681 Plaintifits), VS. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), | SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR TOTAL EYE CARE 406 EAST 9 MILE ROAD PENSACOLA, FL 32514 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax ¢/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS, PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT; AND Page 1 of 3CLAIM NO.: 0511559726 ORDER #: F10165696-021 ‘TOTAL PAGES: 3 ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; AND COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD KRISTIN LEIGH RUTHERFORD; DOB: EE SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney 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 Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC. 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3CLAIM NO.: 0511559726 ORDER #: FL0165696-021 TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1, 1 have 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 of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative tribunal and the disclosures being sought are consistent with such resolutions. VIRGIL W. WRIGHT, Il], ESQ. Dated: Attorney for Defendant(s) FL Bar No. 993141 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq. OCALA, FL 34471 For the Court Telephone: 352-351-1119 Page 3 of 3CLAIM NO.: 0511559726 ORDER #: FL0165696-022, TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA COUNTY, FLORIDA. CIVIL DIVISION KRISTIN RUTHERFORD CASE NO. 2021-CA-681 Plaintiff(s), vs. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), | SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR WEST FLORIDA MEDICAL CENTER CLINIC MAIN: 850-969-2121, M: 850-474-8299, B: 850-474-8100, F: 850-494-5306 8333 NORTH DAVIS HIGHWAY PENSACOLA, FL 32514 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc, located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD INCLUDING, BUT NOT LIMITED TO, ALLL MEDICAL RECORDS, INTAKE FORMS, PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT; AND Page 1 of 3CLAIM NO.: 0511559726 ORDER #: FL0165696-022 TOTAL PAGES: 3 ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION. KRISTIN RUTHERFORD KRISTIN LEIGH RUTHERFORD; DOB: SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney 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 Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC. 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3CLAIM NO.: 0511559726 ORDER #: FL0165696-022 TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. {have 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 of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative tribunal and the disclosures being sought are consistent with such resolutions. VIRGIL W. WRIGHT, III, ESQ. Dated: Attorney for Defendant(s) FL Bar No, 993141 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq. OCALA, FL 34471 For the Court Telephone: 352-351-1119 Page 3 of 3CLAIM NO.: 0511559726 ORDER #: FL0165696-023 TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA COUNTY, FLORIDA CIVIL DIVISION KRISTIN RUTHERFORD CASE NO. 2021-CA-681 Plaintiff(s), vs. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), | SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR WEST FLORIDA MEDICAL CENTER CLINIC - FILMS 850-494-5306 8333 NORTH DAVIS HIGHWAY PENSACOLA, FL 32514 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, $481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD KRISTIN LEIGH RUTHERFORD; DOB: EE SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. Page 1 of3CLAIM NO.: 0811559726 ORDER #: F10165696-023 TOTAL PAGES: 3 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney 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 Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC. 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3CLAIM NO.: 0511559726 ORDER #: FL0165696-023 ‘TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. | have 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 fo permit the patient to raise an objection to the court or administrative tribunal; and 3. The time of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative trisunal and the disclosures being sought are consistent with such resolutions. VIRGIL W. WRIGHT, Ill, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 993141 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq. OCALA, FL 34471 For the Court Telephone: 352-351-1119 Page 3 of 3CLAIM NO.; 0511559726 ORDER #: FLO165696-024 TOTAL PAGES; 3 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA COUNTY, FLORIDA CIVIL DIVISION KRISTIN RUTHERFORD CASE NO. 2021-CA-681 Plaintiff(s), VS. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR MEDICAL CENTER CLINIC, PENSACOLA MAIN: 850-474-8000, M: 850-474-8299, B: 850-474-8100, F: 850-969-2134 8333 NORTH DAVIS HIGHWAY BUILDING 1 PENSACOLA, FL 32514 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS, PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT; AND Page 1 of 3CLAIM NO, ; 0511559726 ORDER #: FLO165696-024. TOTAL PAGES: 3 ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION. KRISTIN RUTHERFORD KRISTIN LEIGH RUTHERFORD; DOB; EEE SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney 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 Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC. 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3CLAIM NO.: 0541559726 ORDER #: FL0165696-024 TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. | have 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 of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative tribunal and the disclosures being sought are consistent with such resolutions, VIRGIL W. WRIGHT, IH, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 993141 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq. OCALA, FL 34471 For the Court Telephone: 352-351-1119 Page 3 of 3CLAIM NO.: 0511559726 ORDER #; FLO165696-025 ‘TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA COUNTY, FLORIDA CIVIL DIVISION KRISTIN RUTHERFORD CASE NO. 2021-CA-681 Plaintiff(s), VS. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), | SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR MEDICAL CENTER CLINIC - RADIOLOGY MAIN: 850-474-8000, M: 850-474-8299 8333 NORTH DAVIS HIGHWAY PENSACOLA, FL 32514 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD KRISTIN LEIGH RUTHERFORD; DOB: ESSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. Page 1 of 3CLAIM NO.: 0511559726 ORDER #: FL0165696-025 TOTAL PAGES: 3 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney 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 Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC. 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3CLAIM NO.: 0511559726 ORDER #: FL0165696-025 TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. | have 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 of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative tribunal and the disclosures being sought are consistent with such resolutions. VIRGIL W. WRIGHT, fll, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 993141 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq. OCALA, FL 34471 For the Court Telephone: 352-351-1119 Page 3 of 3CLAIM NO.: 0511559726 ORDER #: FLO165696-026 TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA COUNTY, FLORIDA CIVIL DIVISION KRISTIN RUTHERFORD CASE NO. 2021-CA-681 Plaintiff(s), vs. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), | SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR BAPTIST MEDICAL TOWERS 850-434-4011 1717 NORTH E STREET PENSACOLA, FL 32501 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS, PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT; AND Page 1 of 3CLAIM NO.: 0511559726 ORDER #: F10165696-026 ‘TOTAL PAGES; 3 ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR, CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-91CD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; AND COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD KRISTIN LEIGH RUTHERFORD; DOB: ESSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney 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 Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC. 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel; 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3CLAIM NO.; 0511559726 ORDER #: FL0165696-026 TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. | have 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 of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative tribunal and the disclosures being sought are consistent with such resolutions. VIRGIL W. WRIGHT, Ill, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 993141 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: = /S/ Virgil W. Wright, lll, Esq. OCALA, FL 34471 For the Court Telephone: 352-351-1119 Page 3 of 3CLAIM NO.: 0511559726 ORDER #: FLO165696-027 TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA COUNTY, FLORIDA CIVIL DIVISION KRISTIN RUTHERFORD CASE NO. 2021-CA-681 Plaintiff(s), Vs. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), | SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR, BAPTIST MEDICAL GROUP - LADIES FIRST OB/GYN 850-432-7310 3417 NORTH 12TH AVE. PENSACOLA, FL 32503 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS, PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT; AND Page 1 of 3CLAIM NO.; 0511559726 ORDER #: FL0165696-027 ‘TOTAL PAGES: 3 ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; AND COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD KRISTIN LEIGH RUTHERFORD; DOB: SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC.., the agent of the attorney 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 Compex Legal Services, Ine. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC, 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel; 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3CLAIM NO.: 0511559726 ORDER #: FLO165696-027 TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. | have 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 of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative tribunal and the disclosures being sought are consistent with such resolutions. VIRGIL W. WRIGHT, Ill, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 993141 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: = /S/ Virgil W. Wright, Ill, Esq. OCALA, FL 34471 For the Court Telephone: 352-351-1119 Page 3 of 3CLAIM NO.: 0511559726 ORDER #: FLO165696-028 TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA COUNTY, FLORIDA CIVIL DIVISION KRISTIN RUTHERFORD Plaintifi(s), CASE NO. 2021-CA-681 vs. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), | SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR ALICIA CHEN, MD 850-607-7177,850-741-4723 4621 NORTH DAVIS HIGHWAY PENSACOLA, FL 32503 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS, PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT; AND Page 1 of 3CLAIM NO. 0511559726 ORDER #: FL0165696-028 TOTAL PAGES: 3 ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; AND COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD KRISTIN LEIGH RUTHERFORD; DOB: EEEESSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney 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 Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC. 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3CLAIM NO.: 0511559726 ORDER #: FLO165696-028 TOTAL PAGES: 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. {have 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 fo 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 of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative tribunal and the disclosures being sought are consistent with such resolutions. VIRGIL W. WRIGHT, Ill, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 993141 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 1820 SOUTHEAST 18TH AVENUE, SUITE 1 By: — /S/ Virgil W. Wright, Ill, Esq. OCALA, FL 34471 For the Court Telephone: 352-351-1119 Page 3 of 3CLAIM NO,: 0511559726 ORDER #: FL0165696-029 TOTAL PAGES; 3 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL COURT IN AND FOR ESCAMBIA COUNTY, FLORIDA. CIVIL DIVISION KRISTIN RUTHERFORD CASE NO. 2021-CA-681 Plaintiff(s), vs. KATHERINE BENOIT AND ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY Defendant(s), | SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR ADVANCED WOMEN'S CARE 850-471-2221 525 BRENT LANE PENSACOLA, FL 32503 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT OR METHOD INCLUDING, BUT NOT LIMITED TO, ALL MEDICAL RECORDS, INTAKE FORMS, PATIENT COMPLETED FORMS AND/OR DOCUMENTS, CORRESPONDENCE, ALL OFFICE RECORDS, EMERGENCY ROOM RECORDS OR REPORTS, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT’S APPOINTMENTS, INSURANCE DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT; AND Page Lof3CLAIM NO.: 0511559726 ORDER #: FL0165696-029 TOTAL PAGES: 3 ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; AND COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. KRISTIN RUTHERFORD KRISTIN LEIGH RUTHERFORD; DOB: IEE SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney 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 Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC, 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 appear