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Filing # 114004847 E-Filed 09/25/2020 04:07:54 PM
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT, INAND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO: 50-2020-CA-007743 (AN)
JUSTINO VEGA PENA and JUSTIN WILLIE VEGA,
Plaintiff,
v.
SONY JOSEPH and HL UNIVERSAL
INC., a Florida for profit Corporation,
Defendant.
/
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE NOTIFIED that after 15 days from the date of eservice of this notice if no
objection is received from any party the undersigned will issue or apply to the clerk of this
court for issuance of the attached subpoena directed to the following entity who is not a
party, to produce the items listed at the time and place specified in the subpoena:
MRC Certififed Spine & Pain Care
1049 S. State Road 7
Wellington, FL 33414
561-578-4582
| HEREBY CERTIFY that a copy of the foregoing has been electronically filed with
the Court and service of same has been promulgated via the Court to all counsel on the
attached mailing list in accordance with Florida Supreme Court Administrative Order
AOSC13-49 on September 25, 2020.
LEWIS BRISBOIS BISGAARD & SMITH LLP
Attorneys for Defendant
110 SE 6" Street, Suite 2600
Fort Lauderdale, FL 33301
(954)728-1280 ext. 2210
(954)728-1282 fax
Jeffrey. Mowers@LewisBrisbois.com
BY:___/s/Jeffrey A. Mowers
JEFFREY A. MOWERS
FBN 508240
4850-8362-8748.1
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 09/25/2020 04:07:54 PM ***MAILING LIST
Carlos Jimenez, Esq. and Scott Goldstein, Esq.
Carlos J. Jimenez PL
1880 North Congress Avenue Suite 315
Boynton Beach, FL 33426
561-253-0434
eservice@247injurylaw.com
Counsel for Plaintiff(s)
Jeffrey A. Mowers, Esq.
LEWIS BRISBOIS BISGAARD & SMITH, LLP
110 SE 6" Street, Suite 2600
Fort Lauderdale, FL 33301
(954)495-2210
(954)728-1282 fax
FBN: 508240
Jeffrey. Mowers@LewisBrisbois.com
Ftlemaildesig@LewisBrisbois.com
Counsel for Defendant
4850-8362-8748.1IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT, INAND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO: 50-2020-CA-007743 (AN)
JUSTINO VEGA PENA and JUSTIN WILLIE VEGA,
Plaintiff,
v.
SONY JOSEPH and HL UNIVERSAL INC.,
a Florida for profit Corporation,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
PURSUANT TO F.R.C.P. 1.351
(Subpoena remains in full force and effect into the future)
THE STATE OF FLORIDA
TO: Medical Record Custodian for Certififed Spine & Pain Care
1049 S. State Road 7
Wellington, FL 33414
561-578-4582
YOU ARE COMMANDED to appear at the law offices of the undersigned attorney,
Jeffrey A. Mowers, Esquire, at the Law Offices of LEWIS BRISBOIS BISGAARD & SMITH, LLP,
110 SE 6" Street, Suite 2600, Fort Lauderdale, Florida, 33301, on or before October 26,
2020.
It is the intent of this subpoena that each and every document and thing in your
care, custody, or control, or available to you, no matter how insignificant that item might
appear to the party to whom this subpoena is directed, be produced.
This subpoena encompasses all documents and things, regardless of how old,
including anything that might be on microfilm/microfiche or kept at another location.
To comply with this subpoena, you are to produce each and every document or thing
which has ever been a part of your file regarding - JUSTINO VEGA PENA Date of Birth
00/00/1968; Social Security # XXX-XX-XXXX
(IF THE COST FOR PROVIDING THESE RECORDS EXCEEDS $250.00, PLEASE
CONTACT THE UNDERSIGNED PRIOR TO COMPLYING WITH THIS SUBPOENA).
Any and all records in your possession regarding the above stated
patient including: medical records; documents; correspondence;
memoranda; reports; evaluations; progress notes; nursing notes;
history and physical; discharge summary; consultations; type-
written or hand written notes; intake forms; physical therapy
records; and invoices and/or bills for services rendered (either
paid or unpaid). ALSO INCLUDE x-rays; x-ray reports; MRIs; MRI
4850-8362-8748.1reports; CT scans; CT scan reports; and referral records. In other
words, EVERYTHING in your possession regarding this patient.
If any document or thing is not produced, you are to identify that
document or thing by date, title, author, and recipient; and identify
the person pursuant to whose instructions the documents or
things were not produced by name, address, and employer.
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 the Subpoena by
providing legible copies of the items to be produced to the attorney whose name
appears on this Subpoena on or before the scheduled date of production. You may
condition the preparation of the copies upon the payment in advance of the reasonable cost
of preparation. YOU MAY MAIL OR DELIVER THE COPIES TO THE ATTORNEY
WHOSE NAME APPEARS ON THIS SUBPOENA. 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:
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.
**HIPAA COMPLIANCE ON FOLLOWING PAGE**
(1) The subpoenaing party made a good faith attempt to provide written notice to the
i (2) The Notice was sufficient to permit the individual to object; (3) The time for
dual to object expired; (4) no objections were filed or all objections were
resolved in favor of disclosure, in compliance with 45 C.F.R. Sec. 164.512(e)(1)
| HEREBY CERTIFY that pursuant to Rule 1.351 of the Florida Rules of Civil
Procedure, | caused to be served upon all counsel of record, the attorneys in fact for all
parties, a Notice of Production From Non-party that contained sufficient information to
permit all parties, to raise an objection to the requested disclosures, and that the time for all
Parties, to raise an objection has lapsed or no objections have been received.
DATED on October 13, 2020.
By: /s/Jeffrey A. Mowers
JEFFREY A. MOWERS
For the Court
Lewis Brisbois Bisgaard & Smith LLP
Counsel for Defendant
110 SE 6" Street, Suite 2600
Fort Lauderdale, FL 33301
Jeffrey. Mowers@LewisBrisbois.com
Marvalyn.Williams@LewisBrisbois.com
Ftlemaildesig@LewisBrisbois.com
954-495-2210
954-728-1282 fax
Florida Bar No.: 508240
4850-8362-8748.1
Preview
Filing # 114004847 E-Filed 09/25/2020 04:07:54 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, INAND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 50-2020-CA-007743 (AN) JUSTINO VEGA PENA and JUSTIN WILLIE VEGA, Plaintiff, v. SONY JOSEPH and HL UNIVERSAL INC., a Florida for profit Corporation, Defendant. / NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE NOTIFIED that after 15 days from the date of eservice of this notice if no objection is received from any party the undersigned will issue or apply to the clerk of this court for issuance of the attached subpoena directed to the following entity who is not a party, to produce the items listed at the time and place specified in the subpoena: MRC Certififed Spine & Pain Care 1049 S. State Road 7 Wellington, FL 33414 561-578-4582 | HEREBY CERTIFY that a copy of the foregoing has been electronically filed with the Court and service of same has been promulgated via the Court to all counsel on the attached mailing list in accordance with Florida Supreme Court Administrative Order AOSC13-49 on September 25, 2020. LEWIS BRISBOIS BISGAARD & SMITH LLP Attorneys for Defendant 110 SE 6" Street, Suite 2600 Fort Lauderdale, FL 33301 (954)728-1280 ext. 2210 (954)728-1282 fax Jeffrey. Mowers@LewisBrisbois.com BY:___/s/Jeffrey A. Mowers JEFFREY A. MOWERS FBN 508240 4850-8362-8748.1 *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 09/25/2020 04:07:54 PM ***MAILING LIST Carlos Jimenez, Esq. and Scott Goldstein, Esq. Carlos J. Jimenez PL 1880 North Congress Avenue Suite 315 Boynton Beach, FL 33426 561-253-0434 eservice@247injurylaw.com Counsel for Plaintiff(s) Jeffrey A. Mowers, Esq. LEWIS BRISBOIS BISGAARD & SMITH, LLP 110 SE 6" Street, Suite 2600 Fort Lauderdale, FL 33301 (954)495-2210 (954)728-1282 fax FBN: 508240 Jeffrey. Mowers@LewisBrisbois.com Ftlemaildesig@LewisBrisbois.com Counsel for Defendant 4850-8362-8748.1IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, INAND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 50-2020-CA-007743 (AN) JUSTINO VEGA PENA and JUSTIN WILLIE VEGA, Plaintiff, v. SONY JOSEPH and HL UNIVERSAL INC., a Florida for profit Corporation, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION PURSUANT TO F.R.C.P. 1.351 (Subpoena remains in full force and effect into the future) THE STATE OF FLORIDA TO: Medical Record Custodian for Certififed Spine & Pain Care 1049 S. State Road 7 Wellington, FL 33414 561-578-4582 YOU ARE COMMANDED to appear at the law offices of the undersigned attorney, Jeffrey A. Mowers, Esquire, at the Law Offices of LEWIS BRISBOIS BISGAARD & SMITH, LLP, 110 SE 6" Street, Suite 2600, Fort Lauderdale, Florida, 33301, on or before October 26, 2020. It is the intent of this subpoena that each and every document and thing in your care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of how old, including anything that might be on microfilm/microfiche or kept at another location. To comply with this subpoena, you are to produce each and every document or thing which has ever been a part of your file regarding - JUSTINO VEGA PENA Date of Birth 00/00/1968; Social Security # XXX-XX-XXXX (IF THE COST FOR PROVIDING THESE RECORDS EXCEEDS $250.00, PLEASE CONTACT THE UNDERSIGNED PRIOR TO COMPLYING WITH THIS SUBPOENA). Any and all records in your possession regarding the above stated patient including: medical records; documents; correspondence; memoranda; reports; evaluations; progress notes; nursing notes; history and physical; discharge summary; consultations; type- written or hand written notes; intake forms; physical therapy records; and invoices and/or bills for services rendered (either paid or unpaid). ALSO INCLUDE x-rays; x-ray reports; MRIs; MRI 4850-8362-8748.1reports; CT scans; CT scan reports; and referral records. In other words, EVERYTHING in your possession regarding this patient. If any document or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify the person pursuant to whose instructions the documents or things were not produced by name, address, and employer. 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 the Subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. YOU MAY MAIL OR DELIVER THE COPIES TO THE ATTORNEY WHOSE NAME APPEARS ON THIS SUBPOENA. 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: 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. **HIPAA COMPLIANCE ON FOLLOWING PAGE** (1) The subpoenaing party made a good faith attempt to provide written notice to the i (2) The Notice was sufficient to permit the individual to object; (3) The time for dual to object expired; (4) no objections were filed or all objections were resolved in favor of disclosure, in compliance with 45 C.F.R. Sec. 164.512(e)(1) | HEREBY CERTIFY that pursuant to Rule 1.351 of the Florida Rules of Civil Procedure, | caused to be served upon all counsel of record, the attorneys in fact for all parties, a Notice of Production From Non-party that contained sufficient information to permit all parties, to raise an objection to the requested disclosures, and that the time for all Parties, to raise an objection has lapsed or no objections have been received. DATED on October 13, 2020. By: /s/Jeffrey A. Mowers JEFFREY A. MOWERS For the Court Lewis Brisbois Bisgaard & Smith LLP Counsel for Defendant 110 SE 6" Street, Suite 2600 Fort Lauderdale, FL 33301 Jeffrey. Mowers@LewisBrisbois.com Marvalyn.Williams@LewisBrisbois.com Ftlemaildesig@LewisBrisbois.com 954-495-2210 954-728-1282 fax Florida Bar No.: 508240 4850-8362-8748.1