Preview
Filing # 140883464 E-Filed 12/23/2021 09:47:44 AM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L. CARTWRIGHT, IT,
Plaintiff,
v. CASE NO.; 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants,
NOTICE OF PRODUCTION FROM NON-PARTY/NON-PARTIES
TO: Thomas D. Hippelheuser, Esquire
Attorney for Plaintiff
LAW OFFICE OF
BRENT C. MILLER, P.A.,
205 E. Burleigh Blvd,
Tavares, FL 32778
Joseph F. Kinman, Esquire
Attorney for Plaintiff
BEYTIN, McLAUGHLIN, O’HARA
KINMAN & BOCCHINO
1706 E. 11" Ave,
Tampa, FL 33605
YOU ARE HEREBY notified that after ten (10) days from the date of service of this
notice and if no objection is received from any party, the undersigned will issue the
subpoena(s) directed to the records custodian of:Citrus Pain Clinic
Murali M. Angirekula MD PA
Alistair Co, M.D.
Farhan Siddiqi, MD
Constantine Toumbis, MD
Clinton Davis, MD
AYR YN
Who is/are not a party to this suit, to produce the items listed by the method and at the time
and place specified in the subpoena(s).
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via Email to: Thomas D. Hippelheuser, Esquire, LAW OFF ICES OF BRENT C. MILLER, P.A,, 205
E. Burl leigh Blvd., Tavares, FL 32778 (ton n fitigation@bemillerlaw
».com) and Joseph F. Kinman, Toquire, BEYTIN, McLAUGHLIN, MCLAUGHL.
oO ‘HARA, KINMAN & BOCCHINO, 1706 E 11" Ave., Tampa, FL 33605 (fk w-fla.com jib@la
fla.com), on this 2? “day of December 2021.
METZGER LAW GROUP, P.A
3018 W. Horatio St.
Tampa, FL 33609
(813)288-2650
(813)288-2670 Fax
service@metzgerlaw.net
Attorneys for Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY
Joseph T. Metéger, Esq.
Florida Bar No. 894478
Erin §. Kuenzel, Esq.
Florida Bar No. 103167IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L. CARTWRIGHT
Plaintiff,
v. CASE NO.; 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants,
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Citrus Pain Clinic
4065 N Lecanto Hwy Ste 100
Beverly Hills. FL,34465
YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale
Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena,
and to include the following:
YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to,
any and all office records, reports, doctors and nurse notes, insurance records, claim forms,
medical records with respect to any injury or illness, medical history, consultations, treatment,
patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions,
bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or
balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of
diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and
x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes.
Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of
incident.
PATIENT NAME: Norman Cartwright
PATIENT DOB: SSN:
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 American Retrieval whose name appears
on this Subpoena on or before the scheduled date of production,
‘You may condition the preparation of copies upon the payment in advance of the reasonable cost
for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs
exceeding $100.00 is required. You may email or fax prepayment requests to American
Retrieval.
Email: customerservice@americanretrieval.com
Fax; 763-233-7301
You have the right to object to the production pursuant to this subpoena at any time before
production by giving written noticed 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;
(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 DISCLOSURE
| HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been
provided to the individual whose documents are sought ("individual" means the Plaintiff in the
above styled matter), that the notice included sufficient information about the litigation or
proceeding to permit the individual to raise an objection to the production of the requested
documents , and that the time to raise an objection has elapsed and no objections were filed in
accordance with CFR Title 45, Subpart E, § 164.512(e)(ii).
Dated:
Continued on next page.For the Court
By:
Joseph T. Metzger, Esq./Erin S. Kuenzel
lorida Bar No.: 894478/103167
METZGER LAW GROUP, P.A.
3018 W. Horatio St
‘ampa, FL 33609
Phone: 813-288-2650
Fax: 813-288-2670
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L. CARTWRIGHT
Plaintiff,
CASE NO, 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN,
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Murali M. Angirekula MD PA
4065 N Lecanto Hwy
Ste 100
Beverly Hills.FL,34465
YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale
Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena,
and to include the following:
YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to,
any and all office records, reports, doctors and nurse notes, insurance records, claim forms,
medical records with respect to any injury or illness, medical history, consultations, treatment,
patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions,
bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or
balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of
diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and
x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes.
Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of
incident.
PATIENT NAME: Norman Cartwright
PATIENT DOB: SSN:
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 American Retrieval whose name appears
on this Subpoena on or before the scheduled date of production,
You may condition the preparation of copies upon the payment in advance of the reasonable cost
for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs
exceeding $100.00 is required. You may email or fax prepayment requests to American
Retrieval.
Email: customerservice@americanretrieval.com
Fax: 763-233-7301
You have the right to object to the production pursuant to this subpoena at any time before
production by giving written noticed to the attorney whose name appears on this subpoena. THIS
WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
If you fail to:
G) appear as specified: or
(2) furnish the records instead of appearing as provided above;
(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 DISCLOSURE
I HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been
provided to the individual whose documents are sought ("individual" means the Plaintiff in the
above styled matter), that the notice included sufficient information about the litigation or
proceeding to permit the individual to raise an objection to the production of the requested
documents , and that the time to raise an objection has elapsed and no objections were filed in
accordance with CFR Title 45, Subpart E. § 164.512(e)(ii).
Dated:
Continued on next page.For the Court
By:
Joseph T. Metzger, Esq./Erin S. Kuenzel
Florida Bar No.: 894478/103167
METZGER LAW GROUP, P.A.
3018 W. Horatio St
Tampa, FL 33609
Phone: 813-288-2650
Fax: 813-288-2670
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L. CARTWRIGHT
Plaintiff,
CASE NO,: 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants,
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Alistair Co, M.D.
10489 N. Florida Avenue
Citrus Springs,FL,34434.
YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale
Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena,
and to include the following:
YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to,
any and all office records, reports, doctors and nurse notes, insurance records, claim forms,
medical records with respect to any injury or illness, medical history, consultations, treatment,
patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions,
bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or
balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of
diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and
x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes.
Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of
incident.
PATIENT NAME: Norman Cartwright
PATIENT DOB: SSN:
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 American Retrieval whose name appears
on this Subpoena on or before the scheduled date of production.
You may condition the preparation of copies upon the payment in advance of the reasonable cost
for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs
exceeding $100.00 is required. You may email or fax prepayment requests to American
Retrieval.
Email: customerservice@americanretrieval.com
Fax: 763-233-7301
You have the right to object to the production pursuant to this subpoena at any time before
production by giving written noticed to the attorney whose name appears on this subpoena. THIS
WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
Tf you fail to:
() appear as specified; or
(Q) furnish the records instead of appearing as provided above;
GB) 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 DISCLOSURE
THEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been
provided to the individual whose documents are sought (“individual" means the Plaintiff in the
above styled matter), that the notice included sufficient information about the litigation or
proceeding to permit the individual to raise an objection to the production of the requested
documents , and that the time to raise an objection has elapsed and no objections were filed in
accordance with CFR Title 45, Subpart E, § 164.512(e)(ii).
Dated:
Continued on next page.For the Court
By:
Joseph T. Metzger, Esq./Erin S. Kuenzel
Florida Bar No.: 894478/103167
METZGER LAW GROUP, P.A.
3018 W. Horatio St
Tampa, FL 33609
Phone: 813-288-2650
Pax: 813-288-2670
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L. CARTWRIGHT
Plaintiff,
CASE NO,; 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: FARHAN SIDDIQI MD
7005 NIGHTWALKER RD
BROOKSVILLE,FL,34613
YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale
Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena,
and to include the following:
YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to,
any and all office records, reports, doctors and nurse notes, insurance records, claim forms,
medical records with respect to any injury or illness, medical history, consultations, treatment.
patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions,
bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or
balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of
diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and
x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes.
Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of
incident.
PATIENT NAME: Norman Cartwright
PATIENT DOB: SSN:
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 American Retrieval whose name appears
on this Subpoena on or before the scheduled date of production.
You may condition the preparation of copies upon the payment in advance of the reasonable cost
for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs
exceeding $100.00 is required. You may email or fax prepayment requests to American
Retrieval.
Email: customerservice@americanretrieval.com
Fax: 763-233-7301
You have the right to object to the production pursuant to this subpoena at any time before
production by giving written noticed to the attorney whose name appears on this subpoena. THIS
WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
If you fail to:
a) appear as specified; or
(2) furnish the records instead of appearing as provided above;
(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 DISCLOSURE
1 HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been
provided to the individual whose documents are sought ("individual" means the Plaintiff in the
above styled matter), that the notice included sufficient information about the litigation or
proceeding to permit the individual to raise an objection to the production of the requested
documents , and that the time to raise an objection has elapsed and no objections were filed in
accordance with CFR Title 45, Subpart E, § 164.512(e)(ii).
Dated:
Continued on next page.For the Court
By: __
Joseph T. Metzger, Esq./Erin S. Kuenzel
Florida Bar No.: 894478/103167
METZGER LAW GROUP, P.A.
3018 W. Horatio St
Tampa, FL 33609
Phone: 813-288-2650
Fax: 813-288-2670
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
TN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L. CARTWRIGHT
Plaintiff,
Vv. CASE NO,: 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC,
Defendants,
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Farhan Siddiqi, MD
FastMD Spine & Orthopedics
701 N. Westshore Blvd.
Tampa,FL,33609
YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale
Mabry Hwy, Suite 260, Tampa, PL 33618 within thirty (30) days of the date of this subpoena,
and to include the following:
YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to,
any and all office records, reports, doctors and nurse notes, insurance records, claim forms,
medical records with respect to any injury or illness, medical history, consultations, treatment,
patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions,
bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or
balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of
diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and
x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes.
Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of
incident.
PATIENT NAME: Norman Cartwright
PATIENT DOB: SSN:
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 American Retrieval whose name appears
on this Subpoena on or before the scheduled date of production.
You may condition the preparation of copies upon the payment in advance of the reasonable cost
for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs
exceeding $100.00 is required. You may email or fax prepayment requests to American,
Retrieval.
Email: customerservice@americanretrieval.com
Fax: 763-233-7301
You have the right to object to the production pursuant to this subpoena at any time before
production by giving written noticed 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;
(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 DISCLOSURE
IT HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been
provided to the individual whose documents are sought ("individual" means the Plaintiff in the
above styled matter), that the notice included sufficient information about the litigation or
proceeding to permit the individual to raise an objection to the production of the requested
documents , and that the time to raise an objection has elapsed and no objections were filed in
accordance with CFR Title 45, Subpart E. § 164.512(e)(ii).
Dated:
Continued on next page.For the Court
By:
Joseph T. Metzger, Esq./Erin S. Kuenzel
Florida Bar No.: 894478/103167
METZGER LAW GROUP, P.A.
3018 W. Horatio St
Tampa, FL 33609
Phone: 813-288-2650
Fax: 813-288-2670
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L, CARTWRIGHT
Plaintiff,
CASE NO,: 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,.
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO: Constantine Toumbis, MD
6099 W Gulf to Lake Hwy
Crystal River,FL,34429
YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale
Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena,
and to include the following:
YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to,
any and all office records, reports, doctors and nurse notes, insurance records, claim forms,
medical records with respect to any injury or illness, medical history, consultations, treatment,
patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions,
bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or
balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of
diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and
x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes.
Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of
incident.
PATIENT NAME: Norman Cartwright
PATIENT DOB: SSN:
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 American Retrieval whose name appears
on this Subpoena on or before the scheduled date of production.
You may condition the preparation of copies upon the payment in advance of the reasonable cost
for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs
exceeding $160.00 is required. You may email or fax prepayment requests to American
Retrieval.
Email: customerservice@americanretrieval.com
Fax: 763-233-7301
You have the right to object to the production pursuant to this subpoena at any time before
production by giving written noticed 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;
(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 DISCLOSURE
| HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been
provided to the individual whose documents are sought ("individual" means the Plaintiff in the
above styled matter), that the notice included sufficient information about the litigation or
proceeding to permit the individual to raise an objection to the production of the requested
documents , and that the time to raise an objection has elapsed and no objections were filed in
accordance with CFR Title 45, Subpart E, § 164.512(e)(ii).
Dated:
Continued on next page.For the Court
By:
Joseph T. Metzger, Esq./Erin S, Kuenzel
Florida Bar No.: 894478/103 167
METZGER LAW GROUP, P.A.
3018 W. Horatio St
Tampa, FL 33609
Phone: 813-288-2650
Fax: 813-288-2670
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L. CARTWRIGHT
Plaintiff,
CASE NO,; 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants,
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO; Clinton Davis, MD
4600 4th St N
St. Petersburg,FL.33703
YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale
Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena,
and to include the following:
YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to,
any and all office records, reports, doctors and nurse notes, insurance records, claim forms,
medical records with respect to any injury or illness, medical history, consultations, treatment,
patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions,
bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or
balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of
diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and
x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes.
Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of
incident.
PATIENT NAME: Norman Cartwright
PATIENT DOB: SSN:
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 American Retrieval whose name appears
on this Subpoena on or before the scheduled date of production.
You may condition the preparation of copies upon the payment in advance of the reasonable cost
for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs
exceeding $100.00 is required. You may email or fax prepayment requests to American
Retrieval.
Email: customerservice@americanretrieval.com
Fax: 763-233-7301
You have the right to object to the production pursuant to this subpoena at any time before
production by giving written noticed to the attorney whose name appears on this subpoena. THIS
WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
If you fail to:
dy appear as specified; or
Q) furnish the records instead of appearing as provided above;
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 DISCLOSURE
1 HEREBY CERTIFY that in compliance with CFR 164,512(e) written notification has been
provided to the individual whose documents are sought ("individual means the Plaintiff in the
above styled matter), that the notice included sufficient information about the litigation or
proceeding to permit the individual to raise an objection to the production of the requested
documents , and that the time to raise an objection has elapsed and no objections were filed in
accordance with CFR Title 45, Subpart E, § 164.512(e)(ii).
Dated:
Continued on next page.For the Court
Joseph T. Metzger, Esq./Erin S. Kuenzel
Florida Bar No.: 894478/103167
METZGER LAW GROUP, P.A.
3018 W. Horatio St
Tampa, FL 33609
Phone: 813-288-2650
Fax: 813-288-2670
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY
Preview
Filing # 140883464 E-Filed 12/23/2021 09:47:44 AM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L. CARTWRIGHT, IT, Plaintiff, v. CASE NO.; 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants, NOTICE OF PRODUCTION FROM NON-PARTY/NON-PARTIES TO: Thomas D. Hippelheuser, Esquire Attorney for Plaintiff LAW OFFICE OF BRENT C. MILLER, P.A., 205 E. Burleigh Blvd, Tavares, FL 32778 Joseph F. Kinman, Esquire Attorney for Plaintiff BEYTIN, McLAUGHLIN, O’HARA KINMAN & BOCCHINO 1706 E. 11" Ave, Tampa, FL 33605 YOU ARE HEREBY notified that after ten (10) days from the date of service of this notice and if no objection is received from any party, the undersigned will issue the subpoena(s) directed to the records custodian of:Citrus Pain Clinic Murali M. Angirekula MD PA Alistair Co, M.D. Farhan Siddiqi, MD Constantine Toumbis, MD Clinton Davis, MD AYR YN Who is/are not a party to this suit, to produce the items listed by the method and at the time and place specified in the subpoena(s). I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Email to: Thomas D. Hippelheuser, Esquire, LAW OFF ICES OF BRENT C. MILLER, P.A,, 205 E. Burl leigh Blvd., Tavares, FL 32778 (ton n fitigation@bemillerlaw ».com) and Joseph F. Kinman, Toquire, BEYTIN, McLAUGHLIN, MCLAUGHL. oO ‘HARA, KINMAN & BOCCHINO, 1706 E 11" Ave., Tampa, FL 33605 (fk w-fla.com jib@la fla.com), on this 2? “day of December 2021. METZGER LAW GROUP, P.A 3018 W. Horatio St. Tampa, FL 33609 (813)288-2650 (813)288-2670 Fax service@metzgerlaw.net Attorneys for Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY Joseph T. Metéger, Esq. Florida Bar No. 894478 Erin §. Kuenzel, Esq. Florida Bar No. 103167IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L. CARTWRIGHT Plaintiff, v. CASE NO.; 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants, SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Citrus Pain Clinic 4065 N Lecanto Hwy Ste 100 Beverly Hills. FL,34465 YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena, and to include the following: YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to, any and all office records, reports, doctors and nurse notes, insurance records, claim forms, medical records with respect to any injury or illness, medical history, consultations, treatment, patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions, bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes. Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of incident. PATIENT NAME: Norman Cartwright PATIENT DOB: SSN: 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 American Retrieval whose name appears on this Subpoena on or before the scheduled date of production, ‘You may condition the preparation of copies upon the payment in advance of the reasonable cost for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs exceeding $100.00 is required. You may email or fax prepayment requests to American Retrieval. Email: customerservice@americanretrieval.com Fax; 763-233-7301 You have the right to object to the production pursuant to this subpoena at any time before production by giving written noticed 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; (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 DISCLOSURE | HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been provided to the individual whose documents are sought ("individual" means the Plaintiff in the above styled matter), that the notice included sufficient information about the litigation or proceeding to permit the individual to raise an objection to the production of the requested documents , and that the time to raise an objection has elapsed and no objections were filed in accordance with CFR Title 45, Subpart E, § 164.512(e)(ii). Dated: Continued on next page.For the Court By: Joseph T. Metzger, Esq./Erin S. Kuenzel lorida Bar No.: 894478/103167 METZGER LAW GROUP, P.A. 3018 W. Horatio St ‘ampa, FL 33609 Phone: 813-288-2650 Fax: 813-288-2670 Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L. CARTWRIGHT Plaintiff, CASE NO, 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN, FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Murali M. Angirekula MD PA 4065 N Lecanto Hwy Ste 100 Beverly Hills.FL,34465 YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena, and to include the following: YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to, any and all office records, reports, doctors and nurse notes, insurance records, claim forms, medical records with respect to any injury or illness, medical history, consultations, treatment, patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions, bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes. Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of incident. PATIENT NAME: Norman Cartwright PATIENT DOB: SSN: 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 American Retrieval whose name appears on this Subpoena on or before the scheduled date of production, You may condition the preparation of copies upon the payment in advance of the reasonable cost for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs exceeding $100.00 is required. You may email or fax prepayment requests to American Retrieval. Email: customerservice@americanretrieval.com Fax: 763-233-7301 You have the right to object to the production pursuant to this subpoena at any time before production by giving written noticed to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: G) appear as specified: or (2) furnish the records instead of appearing as provided above; (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 DISCLOSURE I HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been provided to the individual whose documents are sought ("individual" means the Plaintiff in the above styled matter), that the notice included sufficient information about the litigation or proceeding to permit the individual to raise an objection to the production of the requested documents , and that the time to raise an objection has elapsed and no objections were filed in accordance with CFR Title 45, Subpart E. § 164.512(e)(ii). Dated: Continued on next page.For the Court By: Joseph T. Metzger, Esq./Erin S. Kuenzel Florida Bar No.: 894478/103167 METZGER LAW GROUP, P.A. 3018 W. Horatio St Tampa, FL 33609 Phone: 813-288-2650 Fax: 813-288-2670 Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L. CARTWRIGHT Plaintiff, CASE NO,: 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants, SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Alistair Co, M.D. 10489 N. Florida Avenue Citrus Springs,FL,34434. YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena, and to include the following: YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to, any and all office records, reports, doctors and nurse notes, insurance records, claim forms, medical records with respect to any injury or illness, medical history, consultations, treatment, patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions, bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes. Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of incident. PATIENT NAME: Norman Cartwright PATIENT DOB: SSN: 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 American Retrieval whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparation of copies upon the payment in advance of the reasonable cost for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs exceeding $100.00 is required. You may email or fax prepayment requests to American Retrieval. Email: customerservice@americanretrieval.com Fax: 763-233-7301 You have the right to object to the production pursuant to this subpoena at any time before production by giving written noticed to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. Tf you fail to: () appear as specified; or (Q) furnish the records instead of appearing as provided above; GB) 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 DISCLOSURE THEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been provided to the individual whose documents are sought (“individual" means the Plaintiff in the above styled matter), that the notice included sufficient information about the litigation or proceeding to permit the individual to raise an objection to the production of the requested documents , and that the time to raise an objection has elapsed and no objections were filed in accordance with CFR Title 45, Subpart E, § 164.512(e)(ii). Dated: Continued on next page.For the Court By: Joseph T. Metzger, Esq./Erin S. Kuenzel Florida Bar No.: 894478/103167 METZGER LAW GROUP, P.A. 3018 W. Horatio St Tampa, FL 33609 Phone: 813-288-2650 Pax: 813-288-2670 Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L. CARTWRIGHT Plaintiff, CASE NO,; 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: FARHAN SIDDIQI MD 7005 NIGHTWALKER RD BROOKSVILLE,FL,34613 YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena, and to include the following: YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to, any and all office records, reports, doctors and nurse notes, insurance records, claim forms, medical records with respect to any injury or illness, medical history, consultations, treatment. patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions, bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes. Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of incident. PATIENT NAME: Norman Cartwright PATIENT DOB: SSN: 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 American Retrieval whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparation of copies upon the payment in advance of the reasonable cost for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs exceeding $100.00 is required. You may email or fax prepayment requests to American Retrieval. Email: customerservice@americanretrieval.com Fax: 763-233-7301 You have the right to object to the production pursuant to this subpoena at any time before production by giving written noticed to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: a) appear as specified; or (2) furnish the records instead of appearing as provided above; (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 DISCLOSURE 1 HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been provided to the individual whose documents are sought ("individual" means the Plaintiff in the above styled matter), that the notice included sufficient information about the litigation or proceeding to permit the individual to raise an objection to the production of the requested documents , and that the time to raise an objection has elapsed and no objections were filed in accordance with CFR Title 45, Subpart E, § 164.512(e)(ii). Dated: Continued on next page.For the Court By: __ Joseph T. Metzger, Esq./Erin S. Kuenzel Florida Bar No.: 894478/103167 METZGER LAW GROUP, P.A. 3018 W. Horatio St Tampa, FL 33609 Phone: 813-288-2650 Fax: 813-288-2670 Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT TN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L. CARTWRIGHT Plaintiff, Vv. CASE NO,: 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC, Defendants, SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Farhan Siddiqi, MD FastMD Spine & Orthopedics 701 N. Westshore Blvd. Tampa,FL,33609 YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale Mabry Hwy, Suite 260, Tampa, PL 33618 within thirty (30) days of the date of this subpoena, and to include the following: YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to, any and all office records, reports, doctors and nurse notes, insurance records, claim forms, medical records with respect to any injury or illness, medical history, consultations, treatment, patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions, bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes. Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of incident. PATIENT NAME: Norman Cartwright PATIENT DOB: SSN: 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 American Retrieval whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparation of copies upon the payment in advance of the reasonable cost for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs exceeding $100.00 is required. You may email or fax prepayment requests to American, Retrieval. Email: customerservice@americanretrieval.com Fax: 763-233-7301 You have the right to object to the production pursuant to this subpoena at any time before production by giving written noticed 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; (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 DISCLOSURE IT HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been provided to the individual whose documents are sought ("individual" means the Plaintiff in the above styled matter), that the notice included sufficient information about the litigation or proceeding to permit the individual to raise an objection to the production of the requested documents , and that the time to raise an objection has elapsed and no objections were filed in accordance with CFR Title 45, Subpart E. § 164.512(e)(ii). Dated: Continued on next page.For the Court By: Joseph T. Metzger, Esq./Erin S. Kuenzel Florida Bar No.: 894478/103167 METZGER LAW GROUP, P.A. 3018 W. Horatio St Tampa, FL 33609 Phone: 813-288-2650 Fax: 813-288-2670 Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L, CARTWRIGHT Plaintiff, CASE NO,: 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY,. and CITRUS MEMORIAL HOSPITAL, INC., Defendants, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: Constantine Toumbis, MD 6099 W Gulf to Lake Hwy Crystal River,FL,34429 YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena, and to include the following: YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to, any and all office records, reports, doctors and nurse notes, insurance records, claim forms, medical records with respect to any injury or illness, medical history, consultations, treatment, patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions, bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes. Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of incident. PATIENT NAME: Norman Cartwright PATIENT DOB: SSN: 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 American Retrieval whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparation of copies upon the payment in advance of the reasonable cost for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs exceeding $160.00 is required. You may email or fax prepayment requests to American Retrieval. Email: customerservice@americanretrieval.com Fax: 763-233-7301 You have the right to object to the production pursuant to this subpoena at any time before production by giving written noticed 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; (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 DISCLOSURE | HEREBY CERTIFY that in compliance with CFR 164.512(e) written notification has been provided to the individual whose documents are sought ("individual" means the Plaintiff in the above styled matter), that the notice included sufficient information about the litigation or proceeding to permit the individual to raise an objection to the production of the requested documents , and that the time to raise an objection has elapsed and no objections were filed in accordance with CFR Title 45, Subpart E, § 164.512(e)(ii). Dated: Continued on next page.For the Court By: Joseph T. Metzger, Esq./Erin S, Kuenzel Florida Bar No.: 894478/103 167 METZGER LAW GROUP, P.A. 3018 W. Horatio St Tampa, FL 33609 Phone: 813-288-2650 Fax: 813-288-2670 Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORYIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L. CARTWRIGHT Plaintiff, CASE NO,; 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants, / SUBPOENA DUCES TECUM WITHOUT DEPOSITION THE STATE OF FLORIDA: TO; Clinton Davis, MD 4600 4th St N St. Petersburg,FL.33703 YOU ARE HEREBY COMMANDED to mail records to American Retrieval 14499 North Dale Mabry Hwy, Suite 260, Tampa, FL 33618 within thirty (30) days of the date of this subpoena, and to include the following: YOUR ENTIRE MEDICAL, BILLING AND RADIOLOGY FILE, including but not limited to, any and all office records, reports, doctors and nurse notes, insurance records, claim forms, medical records with respect to any injury or illness, medical history, consultations, treatment, patient questionnaires, progress notes, laboratory reports, test results, charts, prescriptions, bills/account ledgers including date of treatment, services rendered, all payments, adjustments, or balances due, any hospital and or emergency room (ABSTRACT SET ONLY), reports of diagnosis, treatment and care of the patient, any and all x-rays and any and all x-rays/scans and x-ray/scan reports, MRI films and reports, diagnostic test results, narrative reports, office notes. Any surgical recommendations, correspondence, memoranda, notes, or other medical records.The records requested should be all-inclusive and should be in no way limited to one date of incident. PATIENT NAME: Norman Cartwright PATIENT DOB: SSN: 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 American Retrieval whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparation of copies upon the payment in advance of the reasonable cost for preparation in line with Florida Administrative Code 64B8-10.003. Prior approval for costs exceeding $100.00 is required. You may email or fax prepayment requests to American Retrieval. Email: customerservice@americanretrieval.com Fax: 763-233-7301 You have the right to object to the production pursuant to this subpoena at any time before production by giving written noticed to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: dy appear as specified; or Q) furnish the records instead of appearing as provided above; 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 DISCLOSURE 1 HEREBY CERTIFY that in compliance with CFR 164,512(e) written notification has been provided to the individual whose documents are sought ("individual means the Plaintiff in the above styled matter), that the notice included sufficient information about the litigation or proceeding to permit the individual to raise an objection to the production of the requested documents , and that the time to raise an objection has elapsed and no objections were filed in accordance with CFR Title 45, Subpart E, § 164.512(e)(ii). Dated: Continued on next page.For the Court Joseph T. Metzger, Esq./Erin S. Kuenzel Florida Bar No.: 894478/103167 METZGER LAW GROUP, P.A. 3018 W. Horatio St Tampa, FL 33609 Phone: 813-288-2650 Fax: 813-288-2670 Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY