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Filing # 26244355 E-Filed 04/17/2015 03:42:12 PM
IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY FLORIDA SMALL CLAIMS DIVISION
MRI ASSOCIATES OF PALM HARBOR,
INC., d/b/a PALM HARBOR MRI, a/a/o
JENNIFER KNUTSON,
Plaintiff,
vs. CASENO. — 14-000735-SC-North
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,
Defendant.
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service is
by delivery, or 15 days from the date of service, if service is by mail, and if no objection is received
from any party, the undersigned will issue or apply to the clerk of this court for issuance of the
attached subpoenas directed to the following entities:
1. Rose Radiology — Boot Ranch
4133 Woodlands Parkway
Palm Harbor, FL 34685
2. Peluso Chiropractic & Rehab Center
36949 US Hwy 19 North
Palm Harbor, FL 34684
who are not a patties, to produce the items at the time and date specified in the subpoena. In order
to comply with Fla.R.Civ.Pro. 1.351(e), the above entities shall produce to each party named in the
subpoena a complete copy of the records sought and individually billed each party for copying
/as
***ELECTRONICALLY FILED 4/17/2015 3:42:12 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***charges.
CERTIFICATE OF SERVICE
I certify that the foregoing document has been furnished to Stephen Farkas, Esquire,
service@dolmanlaw.com, 800 N. Belcher Rd., Clearwater, FL 33765 by email on this 17" day of
April, 2015.
/s/ Robert H. Oxendine, Esq.
ROBERT H. OXENDINE, ESQUIRE
FL Bar No: 603473
OXENDINE & OXENDINE, P.A.
14428 Bruce B. Downs Blvd.
Tampa, Florida 33613
Ph: (813) 632-8786 / Fax: (813-632-8857
Rule 2.516 email: eservice@oxendinelaw.com
Attorneys for Defendant
/asIN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY FLORIDA SMALL CLAIMS DIVISION
MRI ASSOCIATES OF PALM HARBOR,
INC., d/b/a PALM HARBOR MRI, a/a/o
JENNIFER KNUTSON,
Plaintiff,
vs. CASENO. — 14-000735-SC-North
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: — Records Custodian
Rose Radiology — Boot Ranch
4133 Woodlands Parkway
Palm Harbor, FL 34685
YOU ARE COMMANDED to appear at the law offices of Oxendine & Oxendine, P.A., Arbor
Ridge Professional Park, 14428 Bruce B. Downs Boulevard, Tampa, Florida 33613 (813/632-8786), or you
may mail or deliver the copies of the items to be produced as follows to below named attorneys and
thereby eliminate your appearance:
1. Make two complete, identical sets of copies of the record.
2. Mail one set, along with a bill for the copying charges for that set to:
OXENDINE & OXENDINE, P.A.
14428 Bruce B. Downs Blvd.
Tampa, FL 33613
3. Mail an additional set, along with a bill for copying charges for that set to:
Stephen Farkas, Esquire
800 N. Belcher Rd.
Clearwater, FL 33765
(If you do not have records on the requested party, provide a written note stating that your facility does not
have the information requested and why), on or before April 30, 2015 and to have with you at that time and
/asplace the following:
RE: JENNIFER KNUTSON; DOB: 07191999
All medical records, office records, doctors' and nurses' notes and all other data for the
diagnosis, treatment and care of the above patient, rendered by the witness; all medical
records, office records, doctors' and nurses’ notes and all other data pertaining to the
diagnosis, treatment and care of the above patient, rendered by any other health care
providers that are in the possession of the witness; all reports rendered by the witness to
any party concerning the diagnosis, care and treatment of the above patient; all reports or
correspondence prepared for attorneys by the witness and all correspondence received by
the witness from attorneys; all patient information forms or questionnaires or any other
information provided by the patient; a current bill for all services rendered by the witness
pertaining to the diagnosis, treatment and care of the above patient; a current statement
indicating the total amount of the bill that has been paid and by whom; any and all x-rays
and MRIs taken of the above patient by the witness or by any other health care providers
that are in the possession of the witness; a COPY OF YOUR CURRICULUM VITAE; and
EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S
CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET.
All records requested should be all inclusive and should in no way be limited to one
incident.
These items will be inspected and may be copied at that time. You will not be required to surrender the
original items. You may comply with this subpoena by providing legible copies of the items to be
produced to the attorney whose name appears on this subpoena on or before the scheduled date of
production. You may condition the preparation of the copies upon the payment in advance of the
reasonable cost of preparation by providing an invoice to include the name of the patient, number of copies.
cost per copy, facility name and Tax ID number (you may mail or fax the invoice). You may mail or
deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your
appearance at the time and place specified above. You have the right to object to the production pursuant
to this subpoena at any time before production by giving written notice to the attorney whose name appears
on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
If you fail to:
qd) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless
excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act - HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must
obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been
provided to the patient whose protected health information has been subpoenaed. _As the attorney issuing
the above-named subpoena, I hereby certify that the following statements are true:
/asqd) Ihave made a good faith attempt to provide written notice to the above-named patient that his/her
protected health information has been subpoenaed;
(2) The notice I provided included sufficient information about the litigation or proceeding for which the
protected health information is requested to permit the patient to raise an objection to the court or
administrative tribunal; and
(3) The time for the patient to raise objections to the court or administrative tribunal has elapsed; and
(A) No objections were filed; or
(B) All objections filed by the patient were resolved by the court or the administrative tribunal
and the disclosures being sought are consistent with such resolution.
Dated on this the day of , 2015.
For the Clerk of Court
By:
ROBERT H. OXENDINE, ESQUIRE
Florida Bar No. 603473
Robert H. Oxendine, Esquire
Oxendine & Oxendine, P.A.
Arbor Ridge Professional Park
14428 Bruce B. Downs Boulevard
Tampa, Florida 33613
Phone: (813) 632-8786
Fax: (813) 632-8857
Attorneys for Defendant(s)
/asIN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY FLORIDA SMALL CLAIMS DIVISION
MRI ASSOCIATES OF PALM HARBOR,
INC., d/b/a PALM HARBOR MRI, a/a/o
JENNIFER KNUTSON,
Plaintiff,
vs. CASENO. — 14-000735-SC-North
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: — Records Custodian
Peluso Chiropractic & Rehab Center
36949 US Hwy 19 North
Palm Harbor, FL 34684
YOU ARE COMMANDED to appear at the law offices of Oxendine & Oxendine, P.A., Arbor
Ridge Professional Park, 14428 Bruce B. Downs Boulevard, Tampa, Florida 33613 (813/632-8786), or you
may mail or deliver the copies of the items to be produced as follows to below named attorneys and
thereby eliminate your appearance:
1. Make two complete, identical sets of copies of the record.
2. Mail one set, along with a bill for the copying charges for that set to:
OXENDINE & OXENDINE, P.A.
14428 Bruce B. Downs Blvd.
Tampa, FL 33613
3. Mail an additional set, along with a bill for copying charges for that set to:
Stephen Farkas, Esquire
800 N. Belcher Rd.
Clearwater, FL 33765
(If you do not have records on the requested party, provide a written note stating that your facility does not
have the information requested and why), on or before April 30, 2015 and to have with you at that time and
/asplace the following:
RE: JENNIFER KNUTSON; DOB: 07191999
All medical records, office records, doctors' and nurses' notes and all other data for the
diagnosis, treatment and care of the above patient, rendered by the witness; all medical
records, office records, doctors' and nurses’ notes and all other data pertaining to the
diagnosis, treatment and care of the above patient, rendered by any other health care
providers that are in the possession of the witness; all reports rendered by the witness to
any party concerning the diagnosis, care and treatment of the above patient; all reports or
correspondence prepared for attorneys by the witness and all correspondence received by
the witness from attorneys; all patient information forms or questionnaires or any other
information provided by the patient; a current bill for all services rendered by the witness
pertaining to the diagnosis, treatment and care of the above patient; a current statement
indicating the total amount of the bill that has been paid and by whom; any and all x-rays
and MRIs taken of the above patient by the witness or by any other health care providers
that are in the possession of the witness; a COPY OF YOUR CURRICULUM VITAE; and
EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S
CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET.
All records requested should be all inclusive and should in no way be limited to one
incident.
These items will be inspected and may be copied at that time. You will not be required to surrender the
original items. You may comply with this subpoena by providing legible copies of the items to be
produced to the attorney whose name appears on this subpoena on or before the scheduled date of
production. You may condition the preparation of the copies upon the payment in advance of the
reasonable cost of preparation by providing an invoice to include the name of the patient, number of copies.
cost per copy, facility name and Tax ID number (you may mail or fax the invoice). You may mail or
deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your
appearance at the time and place specified above. You have the right to object to the production pursuant
to this subpoena at any time before production by giving written notice to the attorney whose name appears
on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
If you fail to:
qd) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless
excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed.
HIPAA NOTICE AND COMPLIANCE
To comply with Federal regulations protecting patient privacy (Health Insurance Portability and
Accountability Act - HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must
obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been
provided to the patient whose protected health information has been subpoenaed. _As the attorney issuing
the above-named subpoena, I hereby certify that the following statements are true:
/asqd) Ihave made a good faith attempt to provide written notice to the above-named patient that his/her
protected health information has been subpoenaed;
(2) The notice I provided included sufficient information about the litigation or proceeding for which the
protected health information is requested to permit the patient to raise an objection to the court or
administrative tribunal; and
(3) The time for the patient to raise objections to the court or administrative tribunal has elapsed; and
(A) No objections were filed; or
(B) All objections filed by the patient were resolved by the court or the administrative tribunal
and the disclosures being sought are consistent with such resolution.
Dated on this the day of , 2015.
For the Clerk of Court
By:
ROBERT H. OXENDINE, ESQUIRE
Florida Bar No. 603473
Robert H. Oxendine, Esquire
Oxendine & Oxendine, P.A.
Arbor Ridge Professional Park
14428 Bruce B. Downs Boulevard
Tampa, Florida 33613
Phone: (813) 632-8786
Fax: (813) 632-8857
Attorneys for Defendant(s)
/as
Preview
Filing # 26244355 E-Filed 04/17/2015 03:42:12 PM IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY FLORIDA SMALL CLAIMS DIVISION MRI ASSOCIATES OF PALM HARBOR, INC., d/b/a PALM HARBOR MRI, a/a/o JENNIFER KNUTSON, Plaintiff, vs. CASENO. — 14-000735-SC-North STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service is by delivery, or 15 days from the date of service, if service is by mail, and if no objection is received from any party, the undersigned will issue or apply to the clerk of this court for issuance of the attached subpoenas directed to the following entities: 1. Rose Radiology — Boot Ranch 4133 Woodlands Parkway Palm Harbor, FL 34685 2. Peluso Chiropractic & Rehab Center 36949 US Hwy 19 North Palm Harbor, FL 34684 who are not a patties, to produce the items at the time and date specified in the subpoena. In order to comply with Fla.R.Civ.Pro. 1.351(e), the above entities shall produce to each party named in the subpoena a complete copy of the records sought and individually billed each party for copying /as ***ELECTRONICALLY FILED 4/17/2015 3:42:12 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***charges. CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to Stephen Farkas, Esquire, service@dolmanlaw.com, 800 N. Belcher Rd., Clearwater, FL 33765 by email on this 17" day of April, 2015. /s/ Robert H. Oxendine, Esq. ROBERT H. OXENDINE, ESQUIRE FL Bar No: 603473 OXENDINE & OXENDINE, P.A. 14428 Bruce B. Downs Blvd. Tampa, Florida 33613 Ph: (813) 632-8786 / Fax: (813-632-8857 Rule 2.516 email: eservice@oxendinelaw.com Attorneys for Defendant /asIN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY FLORIDA SMALL CLAIMS DIVISION MRI ASSOCIATES OF PALM HARBOR, INC., d/b/a PALM HARBOR MRI, a/a/o JENNIFER KNUTSON, Plaintiff, vs. CASENO. — 14-000735-SC-North STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: — Records Custodian Rose Radiology — Boot Ranch 4133 Woodlands Parkway Palm Harbor, FL 34685 YOU ARE COMMANDED to appear at the law offices of Oxendine & Oxendine, P.A., Arbor Ridge Professional Park, 14428 Bruce B. Downs Boulevard, Tampa, Florida 33613 (813/632-8786), or you may mail or deliver the copies of the items to be produced as follows to below named attorneys and thereby eliminate your appearance: 1. Make two complete, identical sets of copies of the record. 2. Mail one set, along with a bill for the copying charges for that set to: OXENDINE & OXENDINE, P.A. 14428 Bruce B. Downs Blvd. Tampa, FL 33613 3. Mail an additional set, along with a bill for copying charges for that set to: Stephen Farkas, Esquire 800 N. Belcher Rd. Clearwater, FL 33765 (If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why), on or before April 30, 2015 and to have with you at that time and /asplace the following: RE: JENNIFER KNUTSON; DOB: 07191999 All medical records, office records, doctors' and nurses' notes and all other data for the diagnosis, treatment and care of the above patient, rendered by the witness; all medical records, office records, doctors' and nurses’ notes and all other data pertaining to the diagnosis, treatment and care of the above patient, rendered by any other health care providers that are in the possession of the witness; all reports rendered by the witness to any party concerning the diagnosis, care and treatment of the above patient; all reports or correspondence prepared for attorneys by the witness and all correspondence received by the witness from attorneys; all patient information forms or questionnaires or any other information provided by the patient; a current bill for all services rendered by the witness pertaining to the diagnosis, treatment and care of the above patient; a current statement indicating the total amount of the bill that has been paid and by whom; any and all x-rays and MRIs taken of the above patient by the witness or by any other health care providers that are in the possession of the witness; a COPY OF YOUR CURRICULUM VITAE; and EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. All records requested should be all inclusive and should in no way be limited to one incident. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation by providing an invoice to include the name of the patient, number of copies. cost per copy, facility name and Tax ID number (you may mail or fax the invoice). You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: qd) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act - HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. _As the attorney issuing the above-named subpoena, I hereby certify that the following statements are true: /asqd) Ihave made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed; (2) The notice I provided included sufficient information about the litigation or proceeding for which the protected health information is requested to permit the patient to raise an objection to the court or administrative tribunal; and (3) The time for the patient to raise objections to the court or administrative tribunal has elapsed; and (A) No objections were filed; or (B) All objections filed by the patient were resolved by the court or the administrative tribunal and the disclosures being sought are consistent with such resolution. Dated on this the day of , 2015. For the Clerk of Court By: ROBERT H. OXENDINE, ESQUIRE Florida Bar No. 603473 Robert H. Oxendine, Esquire Oxendine & Oxendine, P.A. Arbor Ridge Professional Park 14428 Bruce B. Downs Boulevard Tampa, Florida 33613 Phone: (813) 632-8786 Fax: (813) 632-8857 Attorneys for Defendant(s) /asIN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY FLORIDA SMALL CLAIMS DIVISION MRI ASSOCIATES OF PALM HARBOR, INC., d/b/a PALM HARBOR MRI, a/a/o JENNIFER KNUTSON, Plaintiff, vs. CASENO. — 14-000735-SC-North STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: — Records Custodian Peluso Chiropractic & Rehab Center 36949 US Hwy 19 North Palm Harbor, FL 34684 YOU ARE COMMANDED to appear at the law offices of Oxendine & Oxendine, P.A., Arbor Ridge Professional Park, 14428 Bruce B. Downs Boulevard, Tampa, Florida 33613 (813/632-8786), or you may mail or deliver the copies of the items to be produced as follows to below named attorneys and thereby eliminate your appearance: 1. Make two complete, identical sets of copies of the record. 2. Mail one set, along with a bill for the copying charges for that set to: OXENDINE & OXENDINE, P.A. 14428 Bruce B. Downs Blvd. Tampa, FL 33613 3. Mail an additional set, along with a bill for copying charges for that set to: Stephen Farkas, Esquire 800 N. Belcher Rd. Clearwater, FL 33765 (If you do not have records on the requested party, provide a written note stating that your facility does not have the information requested and why), on or before April 30, 2015 and to have with you at that time and /asplace the following: RE: JENNIFER KNUTSON; DOB: 07191999 All medical records, office records, doctors' and nurses' notes and all other data for the diagnosis, treatment and care of the above patient, rendered by the witness; all medical records, office records, doctors' and nurses’ notes and all other data pertaining to the diagnosis, treatment and care of the above patient, rendered by any other health care providers that are in the possession of the witness; all reports rendered by the witness to any party concerning the diagnosis, care and treatment of the above patient; all reports or correspondence prepared for attorneys by the witness and all correspondence received by the witness from attorneys; all patient information forms or questionnaires or any other information provided by the patient; a current bill for all services rendered by the witness pertaining to the diagnosis, treatment and care of the above patient; a current statement indicating the total amount of the bill that has been paid and by whom; any and all x-rays and MRIs taken of the above patient by the witness or by any other health care providers that are in the possession of the witness; a COPY OF YOUR CURRICULUM VITAE; and EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. All records requested should be all inclusive and should in no way be limited to one incident. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation by providing an invoice to include the name of the patient, number of copies. cost per copy, facility name and Tax ID number (you may mail or fax the invoice). You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: qd) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. HIPAA NOTICE AND COMPLIANCE To comply with Federal regulations protecting patient privacy (Health Insurance Portability and Accountability Act - HIPAA) of 1996, 45 CFR Subtitle A, Subchapter C, Part 164.512(e), I, we must obtain satisfactory assurance from the party issuing the below-named subpoena that notice has been provided to the patient whose protected health information has been subpoenaed. _As the attorney issuing the above-named subpoena, I hereby certify that the following statements are true: /asqd) Ihave made a good faith attempt to provide written notice to the above-named patient that his/her protected health information has been subpoenaed; (2) The notice I provided included sufficient information about the litigation or proceeding for which the protected health information is requested to permit the patient to raise an objection to the court or administrative tribunal; and (3) The time for the patient to raise objections to the court or administrative tribunal has elapsed; and (A) No objections were filed; or (B) All objections filed by the patient were resolved by the court or the administrative tribunal and the disclosures being sought are consistent with such resolution. Dated on this the day of , 2015. For the Clerk of Court By: ROBERT H. OXENDINE, ESQUIRE Florida Bar No. 603473 Robert H. Oxendine, Esquire Oxendine & Oxendine, P.A. Arbor Ridge Professional Park 14428 Bruce B. Downs Boulevard Tampa, Florida 33613 Phone: (813) 632-8786 Fax: (813) 632-8857 Attorneys for Defendant(s) /as