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Filing # 143326126 E-Filed 02/04/2022 02:07:09 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L. CARTWRIGHT, III,
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.
/
DEFENDANT, R. T. BROWN, IN!
NOTICE OF PRODUCTION FROM N
PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
notice, if service is by delivery or electronic mail, or fifteen (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 the
attached subpoenas directed to the following, who are not parties, to produce the items listed at the
time and placed specified in the subpoena:
1. Security Site Supervisor
GAS Secure Solutions (USA) INC., n/k/a Allied Universal
502 W Highland Blvd
Inverness, FL 34452CASE NO.: 20-CA-006334
Defendant’s Notice of Production from Non-Party
Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via E-Portal to: Thomas D. Hippelheuser, Esquire, LAW OFFICES OF BRENT C. MILLER,
P.A. 205 E. Burleigh Blvd. Tavares, FL 32778 (tom@bemillerlaw.com
litigation@bemillerlaw.com melisa@bemillerlaw.com) and Joseph F. Kinman, Esquire,
BEYTIN, McLAUGHLIN, MCLAUGHLIN, O’HARA, KINMAN & BOCCHINO, 1706 E 11%
Ave., Tampa, FL 33605 (jfk@law-fla.com jlb@law-fla.com), on this 4" day of February, 2022.
METZGER LAW GROUP, P.A.
3018 W. Horatio St.
Tampa, FL 33609
(813) 288-2650
(813) 288-2670 Fax
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY
JOSEPH T. METZGER, ESQUIRE
Florida Bar No. 894478
ERIN S. KUENZEL, ESQUIRE
Florida Bar No. 103167IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
NORMAN L. CARTWRIGHT, III,
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: Security Site Supervisor
G4S Secure Solutions (USA) INC., n/k/a Allied Universal
502 W Highland Blvd
Inverness, FL 34452
YOU ARE HEREBY COMMANDED to appear at the law offices of METZGER LAW
GROUP, P.A., 3018 West Horatio Street, Tampa, FL 33609, within 30 days of the date of this
subpoena, and to have with you at that time and place the following:
1. G4S Injury Report and Accident Investigation form dated October 7, 2017
pertaining to G4S Security Officer, NORMAN L. CARTWRIGHT, III’s,
accident of October 6, 2017 at Citrus Memorial Hospital, located at 502
Highland Blvd., Inverness, Florida.
a. A copy of the Injury Report is attached here as Exhibit “A”. You are
commanded to produce a legible copy of this Injury Report including any
additional pages.
2. The G4S Log Book for Citrus Memorial Hospital’s morgue, which was utilized
by G4S Security Officers assigned to Citrus Memorial Hospital to document
transfers of deceased patients in and out of the hospital morgue, for the time
period October 1, 2017 to October 8, 2017. Patient names, dates of birth and
social security numbers should be redacted prior to production.Case No.: 20-CA-007510
Subpoena Duces Tecum Without Deposition
Page 2
3. All training materials provided to G4S Security Officers who were assigned to
Citrus Memorial Hospital from January 1, 2017 to October 31, 2017
regarding the following topics:
a. Transport and transfer of deceased patients;
Handling deceased patients;
Use of stretchers;
Use of gurneys;
Use of mortuary cots;
Safe lifting techniques; and
Lifting and transporting heavy loads.
wme aes
If you fail to appear, you may be in contempt of court.
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 copies of the
records to the attorney whose name appears on this Subpoena on or before the scheduled date of
production. 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:
(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.
HIPAA Compliance Certificate - This certifies that this subpoena has been issued in
compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) andCase No.: 20-CA-007510
Subpoena Duces Tecum Without Deposition
Page 3
45 CFR 164.512(e)(1)(ii) and Fla. R. Civ. P. 1.351. The party issuing this subpoena has made a
good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her
attorney a Notice of Production from Non-Party pursuant to Fla. R. Civ. P. 1.351 which included
sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the
court.
The time for the Plaintiff/Patient to raise objections to the court has elapsed and no
objections were filed, or all objections filed by the patient have been resolved by the court and the
disclosures being sought are consistent with such resolution.
DATED:
For the Court
By:
METZGER LAW GROUP, P.A.
3018 W. Horatio Street
Tampa, FL 33609
(813) 288-2650
(813) 288-2670 Fax
Attorneys for the Defendant,
R. T. BROWN, INC.
JOSEPH T. METZGER, ESQUIRE
Florida Bar No.: 894478
ERIN S. KUENZEL, ESQUIRE
Florida Bar No.: 103167Exhibit “A”
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Filing # 143326126 E-Filed 02/04/2022 02:07:09 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L. CARTWRIGHT, III, 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. / DEFENDANT, R. T. BROWN, IN! NOTICE OF PRODUCTION FROM N PARTY YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this notice, if service is by delivery or electronic mail, or fifteen (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 the attached subpoenas directed to the following, who are not parties, to produce the items listed at the time and placed specified in the subpoena: 1. Security Site Supervisor GAS Secure Solutions (USA) INC., n/k/a Allied Universal 502 W Highland Blvd Inverness, FL 34452CASE NO.: 20-CA-006334 Defendant’s Notice of Production from Non-Party Page 2 of 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via E-Portal to: Thomas D. Hippelheuser, Esquire, LAW OFFICES OF BRENT C. MILLER, P.A. 205 E. Burleigh Blvd. Tavares, FL 32778 (tom@bemillerlaw.com litigation@bemillerlaw.com melisa@bemillerlaw.com) and Joseph F. Kinman, Esquire, BEYTIN, McLAUGHLIN, MCLAUGHLIN, O’HARA, KINMAN & BOCCHINO, 1706 E 11% Ave., Tampa, FL 33605 (jfk@law-fla.com jlb@law-fla.com), on this 4" day of February, 2022. METZGER LAW GROUP, P.A. 3018 W. Horatio St. Tampa, FL 33609 (813) 288-2650 (813) 288-2670 Fax Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY JOSEPH T. METZGER, ESQUIRE Florida Bar No. 894478 ERIN S. KUENZEL, ESQUIRE Florida Bar No. 103167IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION NORMAN L. CARTWRIGHT, III, 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: Security Site Supervisor G4S Secure Solutions (USA) INC., n/k/a Allied Universal 502 W Highland Blvd Inverness, FL 34452 YOU ARE HEREBY COMMANDED to appear at the law offices of METZGER LAW GROUP, P.A., 3018 West Horatio Street, Tampa, FL 33609, within 30 days of the date of this subpoena, and to have with you at that time and place the following: 1. G4S Injury Report and Accident Investigation form dated October 7, 2017 pertaining to G4S Security Officer, NORMAN L. CARTWRIGHT, III’s, accident of October 6, 2017 at Citrus Memorial Hospital, located at 502 Highland Blvd., Inverness, Florida. a. A copy of the Injury Report is attached here as Exhibit “A”. You are commanded to produce a legible copy of this Injury Report including any additional pages. 2. The G4S Log Book for Citrus Memorial Hospital’s morgue, which was utilized by G4S Security Officers assigned to Citrus Memorial Hospital to document transfers of deceased patients in and out of the hospital morgue, for the time period October 1, 2017 to October 8, 2017. Patient names, dates of birth and social security numbers should be redacted prior to production.Case No.: 20-CA-007510 Subpoena Duces Tecum Without Deposition Page 2 3. All training materials provided to G4S Security Officers who were assigned to Citrus Memorial Hospital from January 1, 2017 to October 31, 2017 regarding the following topics: a. Transport and transfer of deceased patients; Handling deceased patients; Use of stretchers; Use of gurneys; Use of mortuary cots; Safe lifting techniques; and Lifting and transporting heavy loads. wme aes If you fail to appear, you may be in contempt of court. 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 copies of the records to the attorney whose name appears on this Subpoena on or before the scheduled date of production. 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: (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. HIPAA Compliance Certificate - This certifies that this subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) andCase No.: 20-CA-007510 Subpoena Duces Tecum Without Deposition Page 3 45 CFR 164.512(e)(1)(ii) and Fla. R. Civ. P. 1.351. The party issuing this subpoena has made a good faith attempt to provide written notice to the Plaintiff/Patient listed above by sending his/her attorney a Notice of Production from Non-Party pursuant to Fla. R. Civ. P. 1.351 which included sufficient information about the litigation to permit the Plaintiff/Patient to raise an objection to the court. The time for the Plaintiff/Patient to raise objections to the court has elapsed and no objections were filed, or all objections filed by the patient have been resolved by the court and the disclosures being sought are consistent with such resolution. DATED: For the Court By: METZGER LAW GROUP, P.A. 3018 W. Horatio Street Tampa, FL 33609 (813) 288-2650 (813) 288-2670 Fax Attorneys for the Defendant, R. T. BROWN, INC. JOSEPH T. METZGER, ESQUIRE Florida Bar No.: 894478 ERIN S. KUENZEL, ESQUIRE Florida Bar No.: 103167Exhibit “A”