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Filing # 111353168 E-Filed 08/05/2020 05:22:30 PM
2010-041
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR
ALACHUA COUNTY, FLORIDA
BRENDA SNOW,
Plaintiff(s),
vs. CASE NO.: 01 2020 CA 001350
SHANDS TEACHING HOSPITAL AND
CLINICS, INC. d/b/a UF HEALTH
SHANDS HOSPITAL, A Florida Non-
Profit Corporation and UNIVERSITY OF
FLORIDA BOARD OF TRUSTEES d/b/a
UF HEALTH EYE CENTER, a Florida
Public Body Corporate,
Defendant(s).
/
NOTICE OF PRODUCTION FROM NON-PARTY
TO: ALL COUNSEL OF RECORD
YOU ARE HEREBY NOTIFIED that, pursuant to Florida Rules of Civil
Procedure 1.351 and 1.410, after ten (10) days from the date of service (if service is by
delivery or e-mail) OR after fifteen (15) days from the date of service (if service is by
mail) 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 subpoenas directed to
the Records Custodians for:
Seaborn M. Hunt, II, M.D.
3220 SW 31st Road, Ste. 301
Ocala, FL 34474
Family Internal Medicine
1623 SW Ist Ave.
Ocala, FL 34471
Heart of Florida Health Center
1025 Southwest Ist Avenue
Ocala, FL 34471
"2020 CA 001350" 111353168 Filed at Alachua County Clerk 08/06/2020 08:15:00 AM EDTHope Clinic
108 N Pine Ave
Ocala, FL 34475
Lange Eye Care & Associates
3101 SW College Road
Ocala, FL 34474
Case No.: 01 2020 CA 001350
who are not parties, to produce the items as specified in the subpoenas. Said production
will be made by U.S. mail.
CERTIFICATE OF SERVICE
I hereby certify that on this 5" day of August, 2020, a true and correct copy of the
foregoing has been electronically filed with the Clerk of the Court by using the Florida
Courts E-Filing Portal, and furnished via email to the following: Andrea A. Lewis,
Esquire, SEARCY DENNEY SCAROLA BARNHART & SHIPLEY P.A., 2139 Palm
Beach Lakes Boulevard, West Palm Beach, FL 33409; Francis E. Pierce, III, Esquire,
MATEER HARBERT, P.A., 225 East Robinson Street, Suite 600, Orlando, FL 32801; at
the following email addresses:
alewis@searcylaw.com;
lewisteam@searcylaw.com;
mweschrek@searcylaw.com;
litpleadings@mateerharbert.com
/s/ Wilbert R. Vancol
Rafael E. Martinez
Florida Bar No.: 0243248
rmartinez@mmdorl.com
Wilbert R. Vancol
Florida Bar No.: 0093132
wvancol@mmdorl.com
McEwan, Martinez, Dukes & Hall, P.A.
Post Office Box 753
Orlando, FL 32802-0753
Telephone: (407) 423-8571
Facsimile: (407) 423-8637
E-Service: © NOS@mmdorl.com
Attorneys for Defendant, UNIVERSITY
OF FLORIDA BOARD OF TRUSTEES
d/b/a UF HEALTH EYE CENTER, aCase No.: 01 2020 CA 001350
Florida Public Body Corporate2010-041
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR
ALACHUA COUNTY, FLORIDA
BRENDA SNOW,
Plaintiff(s),
vs. CASE NO.: 01 2020 CA 001350
SHANDS TEACHING HOSPITAL AND
CLINICS, INC. d/b/a UF HEALTH
SHANDS HOSPITAL, A Florida Non-
Profit Corporation and UNIVERSITY OF
FLORIDA BOARD OF TRUSTEES d/b/a
UF HEALTH EYE CENTER, a Florida
Public Body Corporate,
Defendant(s).
SUBPOENA DUCES TECUM
STATE OF FLORIDA
TO: RECORDS CUSTODIAN
Seaborn M. Hunt, III, M.D.
3220 SW 31st Road, Ste. 301
Ocala, FL 34474
THIS PARTY HAS MADE A GOOD FAITH EFFORT TO PROVIDE WRITTEN NOTICE TO
THE PATIENT OR _HIS/HER ATTORNEY AS AGENT IN THE FORM OF A NOTICE OF
PRODUCTI WHICH NOTICE PROVIDED THE PATIENT WITH PERTINENT
INFORMATION_REGARDING THE CASE, CASE STYLE, AND MEDICAL RECORDS AS
REQUESTED. THE PATIENT HAS ADEQUATE TIME TO OBJECT AND THIS SUBPOENA
IS_ISSUED_ ONLY AFTER THE EXPIRATION OF REQUISITE TIME FOR SAID
OBJECTIONS OR AFTER RESOLUTION OF SAID OBJECTIONS.
YOU ARE COMMANDED to appear at McEwan, Martinez, Dukes & Hall, P.A., 108
East Central Boulevard, Orlando, Florida 32801, fifteen (15) days from receipt of this
subpoena, at 9:00 a.m., and to have with you at that time and place the documents
described in Schedule “A” attached hereto.
PATIENT: Brenda Snow
DATE OF BIRTH:
SOCIAL SECURITY NUMBER:
These items will be inspected and may be copied at that time. You will not be required to surrender the
original items. You may comply with this subpoena by providing legible copies of the items to be
produced to the attorney whose name appears on this subpoena on or before the scheduled date of
production. You may condition the preparation of the copies upon the payment in advance of the
reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appearsCase Number: 01 2020 CA 001350
on this subpoena and hereby eliminate your appearance at the time and place specified above. You have
the right to object to the production pursuant to the 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 to appear by the following attorney, and unless
excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed.
DATED: , 2020
Rafael E. Martinez
For the Court
Attorney for Defendant, UNIVERSITY OF FLORIDA
BOARD OF TRUSTEES d/b/a UF HEALTH EYE
CENTER, a Florida Public Body Corporate
Rafael E. Martinez, Esquire
Florida Bar No.: 0243248
rmartinez@mmdorl.com
Wilbert R. Vancol, Esquire
Florida Bar No.: 0093132
wvancol@mmdorl.com
McEwan, Martinez, Dukes & Hall, P.A.
108 E. Central Blvd, Post Office Box 753
Orlando, FL 32802-0753
**Tf your cost for copies of the requested documents exceeds $100.00, please contact this office at
(407) 423-8571 before complying with the above request.
In accordance with the American With Disabilities Act, persons with disabilities needing a special accommodation to participate
in this proceeding should contact the office of McEwan, Martinez, Dukes & Hall, P.A., at 108 East Central Boulevard, Post
Office Box 753, Orlando, Florida 32802-0753, Telephone: (407) 423 8571 not later than seven days prior to the proceeding. If
hearing impaired, (TDD) 1-800-955-8771, or Voice (V) 1-800-955-8770, via Florida Relay Service.
HIPAA CERTIFICATE
This certifies that this Subpoena has been issued in compliance with the Health Insurance Portability and
Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii), as this Subpoena has been
issued pursuant to Rules 1.410 and 1.310, Fla.R.Civ.P. The Party issuing this Subpoena has made a good faith effort
to provide written notice to the Plaintiff/Patient herein by sending his/her attorney a Notice of Non-Party Production
for which this Subpoena has been issued and which included sufficient information about the litigation and medical
records requested. The Patient/Plaintiff has had adequate time to raise an objection to the Court or administrative
tribunal, and this Subpoena is being issued only after the expiration of the requisite time for said objections, or after
objections, if any, have been resolved.Case Number: 01 2020 CA 001350
ATTACH! T “A”
PATIENT: Brenda Snow
DATE OF BIRTH:
SOCIAL SECURITY NUMBER:
Any and all medical records, charts, office records, doctors' and nurses’ and other notes,
evaluations, memoranda, correspondence, and all other data pertaining to the diagnosis, treatment
and care of the above named patient that are in your possession, regardless of the time period.
Any and all medical records, charts, office records, doctors’ and nurses' and other notes,
evaluations, memoranda, correspondence, and all other data pertaining to the diagnosis, treatment
and care of concerning of the above named patient, rendered by any other health care providers
that are in your possession regardless of the time period.
Any and all pathology slides and diagnostic tests pertaining to the diagnosis, treatment and care
of above named patient, rendered by you, a hospital and/or rendered by any other health care
providers that are in your possession regardless of the time period. “Please contact our office
prior to shipping any pathology slides*
A list of any and all radiographic films, including but not limited to x-rays, CT scans, MRI's,
Ultrasounds, and any EKG strips, etc., taken of the above named patient by the hospital or by any
other health care providers that are in your possession and the reports thereof regardless of the
time period. (Films_on CD preferred) PLEASE CONTACT OUR OFFICE BEFORE
COPYING ANY OF THE ABOVE REFERENCED ITEMS TO AVOID DUPLICATION.
Any and all reports pertaining to all testing including but not limited to x-rays, CT scans, MRI's,
Ultrasounds, and any EKG strips, etc., taken of the above named patient by the hospital or by any
other health care providers that are in your possession and the reports thereof regardless of the
time period.
Any and all entries contained within any computer system pertaining to the diagnosis, treatment
and care of regardless of the time period, concerning the above named patient.
Any and all entries contained within any telephone log, diary or calendar pertaining to the
diagnosis, treatment and care of the above named patient regardless of the time period.
All emergency room records, notes, hospital records and all other data pertaining to the diagnosis,
treatment and care of the above named patient that are in your possession regardless of the time
period.
Any and all reports rendered by a hospital to any party concerning the diagnosis, care and
treatment of the above named patient that are in your possession regardless of the time period.
Any and all patient information forms or questionnaires, or any other information provided by the
above named patient that is in your possession regardless of the time period.
All billing records, including explanation of benefits, for all services rendered by you pertaining
to the diagnosis, treatment and care of the above named patient that are in your possession
regardless of the time period.
RECORDS SHOULD BE ALL INCLUSIVE AND NOT LIMITED TO ONE,
ACCIDENT, INCIDENT, PHYSICIAN, HOSPITAL, ETC.
PLEASE PHONE OUR OFFICE BEFORE MAKING COPIES IF COST EXCEEDS 100.00.2010-041
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR
ALACHUA COUNTY, FLORIDA
BRENDA SNOW,
Plaintiff(s),
vs. CASE NO.: 01 2020 CA 001350
SHANDS TEACHING HOSPITAL AND
CLINICS, INC. d/b/a UF HEALTH
SHANDS HOSPITAL, A Florida Non-
Profit Corporation and UNIVERSITY OF
FLORIDA BOARD OF TRUSTEES d/b/a
UF HEALTH EYE CENTER, a Florida
Public Body Corporate,
Defendant(s).
SUBPOENA DUCES TECUM
STATE OF FLORIDA
TO: RECORDS CUSTODIAN
Lange Eye Care & Associates
3101 SW College Road
Ocala, FL 34474
THIS PARTY HAS MADE A GOOD FAITH EFFORT TO PROVIDE WRITTEN NOTICE TO
THE PATIENT OR _HIS/HER ATTORNEY AS AGENT IN THE FORM OF A NOTICE OF
PRODUCTI WHICH NOTICE PROVIDED THE PATIENT WITH PERTINENT
INFORMATION_REGARDING THE CASE, CASE STYLE, AND MEDICAL RECORDS AS
REQUESTED. THE PATIENT HAS ADEQUATE TIME TO OBJECT AND THIS SUBPOENA
IS_ISSUED_ ONLY AFTER THE EXPIRATION OF REQUISITE TIME FOR SAID
OBJECTIONS OR AFTER RESOLUTION OF SAID OBJECTIONS.
YOU ARE COMMANDED to appear at McEwan, Martinez, Dukes & Hall, P.A., 108
East Central Boulevard, Orlando, Florida 32801, fifteen (15) days from receipt of this
subpoena, at 9:00 a.m., and to have with you at that time and place the documents
described in Schedule “A” attached hereto.
PATIENT: Brenda Snow
DATE OF BIRTH:
SOCIAL SECURITY NUMBER:
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 theCase Number: 01 2020 CA 001350
reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears
on this subpoena and hereby eliminate your appearance at the time and place specified above. You have
the right to object to the production pursuant to the 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 to appear by the following attorney, and unless
excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed.
DATED: , 2020
Rafael E. Martinez
For the Court
Attorney for Defendant, UNIVERSITY OF FLORIDA
BOARD OF TRUSTEES d/b/a UF HEALTH EYE
CENTER, a Florida Public Body Corporate
Rafael E. Martinez, Esquire
Florida Bar No.: 0243248
tmartinez@mmdorl.com
Wilbert R. Vancol, Esquire
Florida Bar No.: 0093132
wvancol@mmdorl.com
McEwan, Martinez, Dukes & Hall, P.A.
108 E. Central Blvd, Post Office Box 753
Orlando, FL 32802-0753
**If your cost for copies of the requested documents exceeds $100.00, please contact this office at
(407) 423-8571 before complying with the above request.
In accordance with the American With Disabilities Act, persons with disabilities needing a special accommodation to participate
in this proceeding should contact the office of McEwan, Martinez, Dukes & Hall, P.A., at 108 East Central Boulevard, Post
Office Box 753, Orlando, Florida 32802-0753, Telephone: (407) 423 8571 not later than seven days prior to the proceeding, If
hearing impaired, (TDD) 1-800-955-8771, or Voice (V) 1-800-955-8770, via Florida Relay Service.
HIPAA CERTIFICATE
This certifies that this Subpoena has been issued in compliance with the Health Insurance Portability and
Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii), as this Subpoena has been
issued pursuant to Rules 1.410 and 1.310, Fla.R.Civ.P. The Party issuing this Subpoena has made a good faith effort
to provide written notice to the Plaintiff/Patient herein by sending his/her attorney a Notice of Non-Party Production
for which this Subpoena has been issued and which included sufficient information about the litigation and medical
records requested. The Patient/Plaintiff has had adequate time to raise an objection to the Court or administrative
tribunal, and this Subpoena is being issued only after the expiration of the requisite time for said objections, or after
objections, if any, have been resolved.10.
li.
Case Number: 01 2020 CA 001350
ATTACH! T “A”
PATIENT: Brenda Snow
DATE OF BIRTH:
SOCIAL SECURITY NUMBER:
Any and all medical records, charts, office records, doctors' and nurses’ and other notes,
evaluations, memoranda, correspondence, and all other data pertaining to the diagnosis, treatment
and care of the above named patient that are in your possession, regardless of the time period.
Any and all medical records, charts, office records, doctors’ and nurses' and other notes,
evaluations, memoranda, correspondence, and all other data pertaining to the diagnosis, treatment
and care of concerning of the above named patient, rendered by any other health care providers
that are in your possession regardless of the time period.
Any and all pathology slides and diagnostic tests pertaining to the diagnosis, treatment and care
of above named patient, rendered by you, a hospital and/or rendered by any other health care
providers that are in your possession regardless of the time period. “Please contact our office
prior to shipping any pathology slides*
A list of any and all radiographic films, including but not limited to x-rays, CT scans, MRI's,
Ultrasounds, and any EKG strips, etc., taken of the above named patient by the hospital or by any
other health care providers that are in your possession and the reports thereof regardless of the
time period. (Films_on CD preferred) PLEASE CONTACT OUR OFFICE BEFORE
COPYING ANY OF THE ABOVE REFERENCED ITEMS TO AVOID DUPLICATION.
Any and all reports pertaining to all testing including but not limited to x-rays, CT scans, MRI's,
Ultrasounds, and any EKG strips, etc., taken of the above named patient by the hospital or by any
other health care providers that are in your possession and the reports thereof regardless of the
time period.
Any and all entries contained within any computer system pertaining to the diagnosis, treatment
and care of regardless of the time period, concerning the above named patient.
Any and all entries contained within any telephone log, diary or calendar pertaining to the
diagnosis, treatment and care of the above named patient regardless of the time period.
All emergency room records, notes, hospital records and all other data pertaining to the diagnosis,
treatment and care of the above named patient that are in your possession regardless of the time
period.
Any and all reports rendered by a hospital to any party concerning the diagnosis, care and
treatment of the above named patient that are in your possession regardless of the time period.
Any and all patient information forms or questionnaires, or any other information provided by the
above named patient that is in your possession regardless of the time period.
All billing records, including explanation of benefits, for all services rendered by you pertaining
to the diagnosis, treatment and care of the above named patient that are in your possession
regardless of the time period.
RECORDS SHOULD BE ALL INCLUSIVE AND NOT LIMITED TO ONE,
ACCIDENT, INCIDENT, PHYSICIAN, HOSPITAL, ETC.
PLEASE PHONE OUR OFFICE BEFORE MAKING COPIES IF COST EXCEEDS 100.00.
Preview
Filing # 111353168 E-Filed 08/05/2020 05:22:30 PM 2010-041 IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA BRENDA SNOW, Plaintiff(s), vs. CASE NO.: 01 2020 CA 001350 SHANDS TEACHING HOSPITAL AND CLINICS, INC. d/b/a UF HEALTH SHANDS HOSPITAL, A Florida Non- Profit Corporation and UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate, Defendant(s). / NOTICE OF PRODUCTION FROM NON-PARTY TO: ALL COUNSEL OF RECORD YOU ARE HEREBY NOTIFIED that, pursuant to Florida Rules of Civil Procedure 1.351 and 1.410, after ten (10) days from the date of service (if service is by delivery or e-mail) OR after fifteen (15) days from the date of service (if service is by mail) 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 subpoenas directed to the Records Custodians for: Seaborn M. Hunt, II, M.D. 3220 SW 31st Road, Ste. 301 Ocala, FL 34474 Family Internal Medicine 1623 SW Ist Ave. Ocala, FL 34471 Heart of Florida Health Center 1025 Southwest Ist Avenue Ocala, FL 34471 "2020 CA 001350" 111353168 Filed at Alachua County Clerk 08/06/2020 08:15:00 AM EDTHope Clinic 108 N Pine Ave Ocala, FL 34475 Lange Eye Care & Associates 3101 SW College Road Ocala, FL 34474 Case No.: 01 2020 CA 001350 who are not parties, to produce the items as specified in the subpoenas. Said production will be made by U.S. mail. CERTIFICATE OF SERVICE I hereby certify that on this 5" day of August, 2020, a true and correct copy of the foregoing has been electronically filed with the Clerk of the Court by using the Florida Courts E-Filing Portal, and furnished via email to the following: Andrea A. Lewis, Esquire, SEARCY DENNEY SCAROLA BARNHART & SHIPLEY P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Francis E. Pierce, III, Esquire, MATEER HARBERT, P.A., 225 East Robinson Street, Suite 600, Orlando, FL 32801; at the following email addresses: alewis@searcylaw.com; lewisteam@searcylaw.com; mweschrek@searcylaw.com; litpleadings@mateerharbert.com /s/ Wilbert R. Vancol Rafael E. Martinez Florida Bar No.: 0243248 rmartinez@mmdorl.com Wilbert R. Vancol Florida Bar No.: 0093132 wvancol@mmdorl.com McEwan, Martinez, Dukes & Hall, P.A. Post Office Box 753 Orlando, FL 32802-0753 Telephone: (407) 423-8571 Facsimile: (407) 423-8637 E-Service: © NOS@mmdorl.com Attorneys for Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, aCase No.: 01 2020 CA 001350 Florida Public Body Corporate2010-041 IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA BRENDA SNOW, Plaintiff(s), vs. CASE NO.: 01 2020 CA 001350 SHANDS TEACHING HOSPITAL AND CLINICS, INC. d/b/a UF HEALTH SHANDS HOSPITAL, A Florida Non- Profit Corporation and UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate, Defendant(s). SUBPOENA DUCES TECUM STATE OF FLORIDA TO: RECORDS CUSTODIAN Seaborn M. Hunt, III, M.D. 3220 SW 31st Road, Ste. 301 Ocala, FL 34474 THIS PARTY HAS MADE A GOOD FAITH EFFORT TO PROVIDE WRITTEN NOTICE TO THE PATIENT OR _HIS/HER ATTORNEY AS AGENT IN THE FORM OF A NOTICE OF PRODUCTI WHICH NOTICE PROVIDED THE PATIENT WITH PERTINENT INFORMATION_REGARDING THE CASE, CASE STYLE, AND MEDICAL RECORDS AS REQUESTED. THE PATIENT HAS ADEQUATE TIME TO OBJECT AND THIS SUBPOENA IS_ISSUED_ ONLY AFTER THE EXPIRATION OF REQUISITE TIME FOR SAID OBJECTIONS OR AFTER RESOLUTION OF SAID OBJECTIONS. YOU ARE COMMANDED to appear at McEwan, Martinez, Dukes & Hall, P.A., 108 East Central Boulevard, Orlando, Florida 32801, fifteen (15) days from receipt of this subpoena, at 9:00 a.m., and to have with you at that time and place the documents described in Schedule “A” attached hereto. PATIENT: Brenda Snow DATE OF BIRTH: SOCIAL SECURITY NUMBER: These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appearsCase Number: 01 2020 CA 001350 on this subpoena and hereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to the 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED: , 2020 Rafael E. Martinez For the Court Attorney for Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate Rafael E. Martinez, Esquire Florida Bar No.: 0243248 rmartinez@mmdorl.com Wilbert R. Vancol, Esquire Florida Bar No.: 0093132 wvancol@mmdorl.com McEwan, Martinez, Dukes & Hall, P.A. 108 E. Central Blvd, Post Office Box 753 Orlando, FL 32802-0753 **Tf your cost for copies of the requested documents exceeds $100.00, please contact this office at (407) 423-8571 before complying with the above request. In accordance with the American With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the office of McEwan, Martinez, Dukes & Hall, P.A., at 108 East Central Boulevard, Post Office Box 753, Orlando, Florida 32802-0753, Telephone: (407) 423 8571 not later than seven days prior to the proceeding. If hearing impaired, (TDD) 1-800-955-8771, or Voice (V) 1-800-955-8770, via Florida Relay Service. HIPAA CERTIFICATE This certifies that this Subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii), as this Subpoena has been issued pursuant to Rules 1.410 and 1.310, Fla.R.Civ.P. The Party issuing this Subpoena has made a good faith effort to provide written notice to the Plaintiff/Patient herein by sending his/her attorney a Notice of Non-Party Production for which this Subpoena has been issued and which included sufficient information about the litigation and medical records requested. The Patient/Plaintiff has had adequate time to raise an objection to the Court or administrative tribunal, and this Subpoena is being issued only after the expiration of the requisite time for said objections, or after objections, if any, have been resolved.Case Number: 01 2020 CA 001350 ATTACH! T “A” PATIENT: Brenda Snow DATE OF BIRTH: SOCIAL SECURITY NUMBER: Any and all medical records, charts, office records, doctors' and nurses’ and other notes, evaluations, memoranda, correspondence, and all other data pertaining to the diagnosis, treatment and care of the above named patient that are in your possession, regardless of the time period. Any and all medical records, charts, office records, doctors’ and nurses' and other notes, evaluations, memoranda, correspondence, and all other data pertaining to the diagnosis, treatment and care of concerning of the above named patient, rendered by any other health care providers that are in your possession regardless of the time period. Any and all pathology slides and diagnostic tests pertaining to the diagnosis, treatment and care of above named patient, rendered by you, a hospital and/or rendered by any other health care providers that are in your possession regardless of the time period. “Please contact our office prior to shipping any pathology slides* A list of any and all radiographic films, including but not limited to x-rays, CT scans, MRI's, Ultrasounds, and any EKG strips, etc., taken of the above named patient by the hospital or by any other health care providers that are in your possession and the reports thereof regardless of the time period. (Films_on CD preferred) PLEASE CONTACT OUR OFFICE BEFORE COPYING ANY OF THE ABOVE REFERENCED ITEMS TO AVOID DUPLICATION. Any and all reports pertaining to all testing including but not limited to x-rays, CT scans, MRI's, Ultrasounds, and any EKG strips, etc., taken of the above named patient by the hospital or by any other health care providers that are in your possession and the reports thereof regardless of the time period. Any and all entries contained within any computer system pertaining to the diagnosis, treatment and care of regardless of the time period, concerning the above named patient. Any and all entries contained within any telephone log, diary or calendar pertaining to the diagnosis, treatment and care of the above named patient regardless of the time period. All emergency room records, notes, hospital records and all other data pertaining to the diagnosis, treatment and care of the above named patient that are in your possession regardless of the time period. Any and all reports rendered by a hospital to any party concerning the diagnosis, care and treatment of the above named patient that are in your possession regardless of the time period. Any and all patient information forms or questionnaires, or any other information provided by the above named patient that is in your possession regardless of the time period. All billing records, including explanation of benefits, for all services rendered by you pertaining to the diagnosis, treatment and care of the above named patient that are in your possession regardless of the time period. RECORDS SHOULD BE ALL INCLUSIVE AND NOT LIMITED TO ONE, ACCIDENT, INCIDENT, PHYSICIAN, HOSPITAL, ETC. PLEASE PHONE OUR OFFICE BEFORE MAKING COPIES IF COST EXCEEDS 100.00.2010-041 IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA BRENDA SNOW, Plaintiff(s), vs. CASE NO.: 01 2020 CA 001350 SHANDS TEACHING HOSPITAL AND CLINICS, INC. d/b/a UF HEALTH SHANDS HOSPITAL, A Florida Non- Profit Corporation and UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate, Defendant(s). SUBPOENA DUCES TECUM STATE OF FLORIDA TO: RECORDS CUSTODIAN Lange Eye Care & Associates 3101 SW College Road Ocala, FL 34474 THIS PARTY HAS MADE A GOOD FAITH EFFORT TO PROVIDE WRITTEN NOTICE TO THE PATIENT OR _HIS/HER ATTORNEY AS AGENT IN THE FORM OF A NOTICE OF PRODUCTI WHICH NOTICE PROVIDED THE PATIENT WITH PERTINENT INFORMATION_REGARDING THE CASE, CASE STYLE, AND MEDICAL RECORDS AS REQUESTED. THE PATIENT HAS ADEQUATE TIME TO OBJECT AND THIS SUBPOENA IS_ISSUED_ ONLY AFTER THE EXPIRATION OF REQUISITE TIME FOR SAID OBJECTIONS OR AFTER RESOLUTION OF SAID OBJECTIONS. YOU ARE COMMANDED to appear at McEwan, Martinez, Dukes & Hall, P.A., 108 East Central Boulevard, Orlando, Florida 32801, fifteen (15) days from receipt of this subpoena, at 9:00 a.m., and to have with you at that time and place the documents described in Schedule “A” attached hereto. PATIENT: Brenda Snow DATE OF BIRTH: SOCIAL SECURITY NUMBER: 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 theCase Number: 01 2020 CA 001350 reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and hereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to the 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED: , 2020 Rafael E. Martinez For the Court Attorney for Defendant, UNIVERSITY OF FLORIDA BOARD OF TRUSTEES d/b/a UF HEALTH EYE CENTER, a Florida Public Body Corporate Rafael E. Martinez, Esquire Florida Bar No.: 0243248 tmartinez@mmdorl.com Wilbert R. Vancol, Esquire Florida Bar No.: 0093132 wvancol@mmdorl.com McEwan, Martinez, Dukes & Hall, P.A. 108 E. Central Blvd, Post Office Box 753 Orlando, FL 32802-0753 **If your cost for copies of the requested documents exceeds $100.00, please contact this office at (407) 423-8571 before complying with the above request. In accordance with the American With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the office of McEwan, Martinez, Dukes & Hall, P.A., at 108 East Central Boulevard, Post Office Box 753, Orlando, Florida 32802-0753, Telephone: (407) 423 8571 not later than seven days prior to the proceeding, If hearing impaired, (TDD) 1-800-955-8771, or Voice (V) 1-800-955-8770, via Florida Relay Service. HIPAA CERTIFICATE This certifies that this Subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii), as this Subpoena has been issued pursuant to Rules 1.410 and 1.310, Fla.R.Civ.P. The Party issuing this Subpoena has made a good faith effort to provide written notice to the Plaintiff/Patient herein by sending his/her attorney a Notice of Non-Party Production for which this Subpoena has been issued and which included sufficient information about the litigation and medical records requested. The Patient/Plaintiff has had adequate time to raise an objection to the Court or administrative tribunal, and this Subpoena is being issued only after the expiration of the requisite time for said objections, or after objections, if any, have been resolved.10. li. Case Number: 01 2020 CA 001350 ATTACH! T “A” PATIENT: Brenda Snow DATE OF BIRTH: SOCIAL SECURITY NUMBER: Any and all medical records, charts, office records, doctors' and nurses’ and other notes, evaluations, memoranda, correspondence, and all other data pertaining to the diagnosis, treatment and care of the above named patient that are in your possession, regardless of the time period. Any and all medical records, charts, office records, doctors’ and nurses' and other notes, evaluations, memoranda, correspondence, and all other data pertaining to the diagnosis, treatment and care of concerning of the above named patient, rendered by any other health care providers that are in your possession regardless of the time period. Any and all pathology slides and diagnostic tests pertaining to the diagnosis, treatment and care of above named patient, rendered by you, a hospital and/or rendered by any other health care providers that are in your possession regardless of the time period. “Please contact our office prior to shipping any pathology slides* A list of any and all radiographic films, including but not limited to x-rays, CT scans, MRI's, Ultrasounds, and any EKG strips, etc., taken of the above named patient by the hospital or by any other health care providers that are in your possession and the reports thereof regardless of the time period. (Films_on CD preferred) PLEASE CONTACT OUR OFFICE BEFORE COPYING ANY OF THE ABOVE REFERENCED ITEMS TO AVOID DUPLICATION. Any and all reports pertaining to all testing including but not limited to x-rays, CT scans, MRI's, Ultrasounds, and any EKG strips, etc., taken of the above named patient by the hospital or by any other health care providers that are in your possession and the reports thereof regardless of the time period. Any and all entries contained within any computer system pertaining to the diagnosis, treatment and care of regardless of the time period, concerning the above named patient. Any and all entries contained within any telephone log, diary or calendar pertaining to the diagnosis, treatment and care of the above named patient regardless of the time period. All emergency room records, notes, hospital records and all other data pertaining to the diagnosis, treatment and care of the above named patient that are in your possession regardless of the time period. Any and all reports rendered by a hospital to any party concerning the diagnosis, care and treatment of the above named patient that are in your possession regardless of the time period. Any and all patient information forms or questionnaires, or any other information provided by the above named patient that is in your possession regardless of the time period. All billing records, including explanation of benefits, for all services rendered by you pertaining to the diagnosis, treatment and care of the above named patient that are in your possession regardless of the time period. RECORDS SHOULD BE ALL INCLUSIVE AND NOT LIMITED TO ONE, ACCIDENT, INCIDENT, PHYSICIAN, HOSPITAL, ETC. PLEASE PHONE OUR OFFICE BEFORE MAKING COPIES IF COST EXCEEDS 100.00.