Preview
Filing # 64998906 E-Filed 12/05/2017 04:22:25 PM
CLAIM NO: 0256939547.1
ORDER #: I15609
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
LORRAINE BRADSHAW,
CASE NO. 2017-CA-003987-O
Plaintiff(s),
vs.
A L L S TAT E FIRE AND C A S UA LT Y
INSURANCE COMPANY,
Defendant(s),
DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS
FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after fifteen (15) days from the date of service of this
Notice, service is by email, and if no objection is received from any party, the undersigned will
issue or apply to the Clerk of this court for the issuance of the attached Subpoena(s) directed to
the following:
Medical Records Custodian for
NEUROSKELETAL IMAGING (NSI)
2222 SOUTH HARBOR CITY BOULEVARD, SUITE 520
MELBOURNE, FL 32901
Records Custodian for
WALGREENS CORPORATION
1901 EAST VOORHEES STREET, MAIL STOP 735
DANVILLE, IL 61834
Medical Records Custodian for
ABILITY REHABILITATION
20 SOUTH PARK AVENUE, SUITE A
APOPKA, FL 32703
The above listed are not a party to this lawsuit and are requested to produce the items listed at
the time and place specified in the attached Subpoena(s).
Page 1 of 2
CLAIM NO: 0256939547.1
ORDER #: I15609
If you wish to receive copies of these documents, please advise the undersigned, in writing,
and same will be provided, at a cost for photocopies, upon receipt.
PLEASE BE GOVERNED ACCORDINGLY.
I HEREBY CERTIFY that on December 5, 2017, a true and correct copy of the foregoing
Defendant(s) Notice of Production of Documents from Non Party has been furnished by email to:
LAWRENCE GONZALEZ, II, ESQ
MORGAN & MORGAN, P.A.
20 NORTH ORANGE AVENUE, SUITE 1600, 16TH FLOOR
ORLANDO FL 32801
mcoriano-lopez@forthepeople.com
lgonzalez@forthepeople.com
sserrano@forthepeople.com
LAW OFFICES OF ROBERT J. SMITH
390 NORTH ORANGE AVENUE, SUITE 895
ORLANDO, FL 32801
Telephone: 407-236-0558
Fax: 877-437-1334
By:
MICHELLE GERJEL, ESQ.
FL Bar No. 0838772
PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS:
OrlandoLegal@Allstate.com
Attorney for Defendant(s)
ALLSTATE FIRE AND CASUALTY INS. CO.
Page 2 of 2
CLAIM NO: 0256939547.1
ORDER #: I15609
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
LORRAINE BRADSHAW,
CASE NO. 2017-CA-003987-O
Plaintiff(s),
vs.
A L L S TAT E FIRE AND C A S UA LT Y
INSURANCE COMPANY,
Defendant(s),
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
NEUROSKELETAL IMAGING (NSI) 321-409-9990
2222 SOUTH HARBOR CITY BOULEVARD, SUITE 520
MELBOURNE, FL 32901
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal
Services, Inc. located at 8130 Anderson Road, Suite 302, Tampa, FL 33634, Fax: 888-531-2922 and
to the c/o LAWRENCE GONZALEZ, II, ESQ., MORGAN & MORGAN, P.A., 20 NORTH
ORANGE AVENUE, SUITE 1600, 16TH FLOOR, ORLANDO, FL 32801, after ten (10) days from
the date of service of this subpoena, and to have with you at that time and place the following:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT (PAPER, ELECTRONIC OR
DIGITAL IMAGE, CD ROM, DVD, HARD DRIVE, SCANNED DOCUMENTS AND EMAIL
CORRESPONDENCE OR ANY OTHER FORM OR METHOD) INCLUDING, BUT NOT
LIMITED TO, ALL OFFICE, EMERGENCY ROOM, INPATIENT AND OUTPATIENT CHARTS
AND RECORDS (INCLUDING THE FRONT, BACK AND INSIDE OF ANY PAPER FILE
JACKETS), LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB
REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS,
INCLUDING SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND
DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS,
Page (1 of 3)
CLAIM NO: 0256939547.1
ORDER #: I15609
AND INSURANCE DOCUMENTS;
ANY AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE
CODES INCLUDING ALL CPT AND ICD-9 CODING AND ALL HCFA AND UB92 BILLS, TO
INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS
WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S
RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, ANY
INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS
BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION;
COPIES OF ALL ORIGINAL X-RAY FILMS, MRI AND CT SCANS AND ANY OTHER IMAGES
MAINTAINED, INCLUDING DATES AND BODY PARTS, RADIOLOGICAL REPORTS AND
PHOTOGRAPHS PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE
PATIENT, REGARDLESS OF TREATMENT DATE.BRADSHAW, LORRAINE; AKA: NOT
PROVIDED; DOB:
SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX
LEGAL SERVICES, INC. AT 888-531-2919, AND MORGAN & MORGAN, P.A. AT 407-420-1414
WITH A LIST OF ADDITIONAL DATES AND/OR CHARGES INVOLVED IN OBTAINING
THESE RECORDS BEFORE CREATING COPIES.
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 COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears
on this subpoena, and to MORGAN & MORGAN, P.A. on or before the scheduled date of
production. "The records requested will be used for this litigation only and will be returned or
destroyed after litigation is complete." Please contact Compex Legal Services, Inc. directly and send all
Medical Records, Bills, Films, and all other items necessary for compliance to:
COMPEX LEGAL SERVICES, INC., 8130 Anderson Road, Suite 302, Tampa, FL 33634, Tel:
888-531-2919, Fax: 310-618-5467
You may condition the preparation of the copies upon the payment in advance of the reasonable cost of
preparation. 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 by the attorney whose
name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you
shall respond to this subpoena as directed.
Page (2 of 3)
CLAIM NO: 0256939547.1
ORDER #: I15609
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. I have made a good faith attempt to provide written notice to the above-named patient,
through counsel, of intent to obtain the patient's health information pursuant to this
subpoena;
2. The written notice provided sufficient information about this litigation or proceeding in which
the protected health information is requested to permit the patient to raise an objection to
the court or administrative tribunal; and
3. The time of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
________ No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
________ tribunal and the disclosures being sought are consistent with such resolutions.
MICHELLE GERJEL, ESQ. Dated: ____________________
Attorney for Defendant(s)
FL Bar No. 0838772
LAW OFFICES OF ROBERT J. SMITH
390 NORTH ORANGE AVENUE, SUITE 895
By:
ORLANDO, FL 32801
For the Court
Telephone: 407-236-0558
Page (3 of 3)
CLAIM NO: 0256939547.1
ORDER #: I15609
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
LORRAINE BRADSHAW,
CASE NO. 2017-CA-003987-O
Plaintiff(s),
vs.
A L L S TAT E FIRE AND C A S UA LT Y
INSURANCE COMPANY,
Defendant(s),
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
WALGREENS CORPORATION 217-554-8949
1901 EAST VOORHEES STREET, MAIL STOP 735
DANVILLE, IL 61834
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal
Services, Inc. located at 8130 Anderson Road, Suite 302, Tampa, FL 33634, Fax: 888-531-2922 and
to the c/o LAWRENCE GONZALEZ, II, ESQ., MORGAN & MORGAN, P.A., 20 NORTH
ORANGE AVENUE, SUITE 1600, 16TH FLOOR, ORLANDO, FL 32801, after ten (10) days from
the date of service of this subpoena, and to have with you at that time and place the following:
ANY AND ALL PRESCRIPTION AND PHARMACY RECORDS, INCLUDING BUT NOT
LIMITED TO, CD ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED
DOCUMENTS AND ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR
DIGITALLY, AND OTHER MEMORANDA PERTAINING TO THE ISSUANCE AND SALE OF
PRESCRIPTION DRUGS TO THE PATIENT, INCLUDING ALL ORIGINAL DOCTORS
PRESCRIPTION FORMS, PAYMENT HISTORY, AND ANY OTHER PHARMACY RECORDS
INCLUDING BUT NOT LIMITED TO PAYMENT HISTORY PERTAINING TO THE PATIENT
REGARDLESS OF TREATMENT OR PRESCRIPTION DATE.BRADSHAW, LORRAINE; AKA:
Page (1 of 3)
CLAIM NO: 0256939547.1
ORDER #: I15609
NOT PROVIDED; DOB:
SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX
LEGAL SERVICES, INC. AT 888-531-2919, AND MORGAN & MORGAN, P.A. AT 407-420-1414
WITH A LIST OF ADDITIONAL DATES AND/OR CHARGES INVOLVED IN OBTAINING
THESE RECORDS BEFORE CREATING COPIES.
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 COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears
on this subpoena, and to MORGAN & MORGAN, P.A. on or before the scheduled date of
production. "The records requested will be used for this litigation only and will be returned or
destroyed after litigation is complete." Please contact Compex Legal Services, Inc. directly and send all
Medical Records, Bills, Films, and all other items necessary for compliance to:
COMPEX LEGAL SERVICES, INC., 8130 Anderson Road, Suite 302, Tampa, FL 33634, Tel:
888-531-2919, Fax: 310-618-5467
You may condition the preparation of the copies upon the payment in advance of the reasonable cost of
preparation. 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 by the attorney whose
name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you
shall respond to this subpoena as directed.
Page (2 of 3)
CLAIM NO: 0256939547.1
ORDER #: I15609
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. I have made a good faith attempt to provide written notice to the above-named patient,
through counsel, of intent to obtain the patient's health information pursuant to this
subpoena;
2. The written notice provided sufficient information about this litigation or proceeding in which
the protected health information is requested to permit the patient to raise an objection to
the court or administrative tribunal; and
3. The time of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
________ No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
________ tribunal and the disclosures being sought are consistent with such resolutions.
MICHELLE GERJEL, ESQ. Dated: ____________________
Attorney for Defendant(s)
FL Bar No. 0838772
LAW OFFICES OF ROBERT J. SMITH
390 NORTH ORANGE AVENUE, SUITE 895
By:
ORLANDO, FL 32801
For the Court
Telephone: 407-236-0558
Page (3 of 3)
CLAIM NO: 0256939547.1
ORDER #: I15609
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
LORRAINE BRADSHAW,
CASE NO. 2017-CA-003987-O
Plaintiff(s),
vs.
A L L S TAT E FIRE AND C A S UA LT Y
INSURANCE COMPANY,
Defendant(s),
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
ABILITY REHABILITATION 407-880-8438
20 SOUTH PARK AVENUE, SUITE A
APOPKA, FL 32703
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal
Services, Inc. located at 8130 Anderson Road, Suite 302, Tampa, FL 33634, Fax: 888-531-2922 and
to the c/o LAWRENCE GONZALEZ, II, ESQ., MORGAN & MORGAN, P.A., 20 NORTH
ORANGE AVENUE, SUITE 1600, 16TH FLOOR, ORLANDO, FL 32801, after ten (10) days from
the date of service of this subpoena, and to have with you at that time and place the following:
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT (PAPER, ELECTRONIC OR
DIGITAL IMAGE, CD ROM, DVD, HARD DRIVE, SCANNED DOCUMENTS AND EMAIL
CORRESPONDENCE OR ANY OTHER FORM OR METHOD) INCLUDING, BUT NOT
LIMITED TO, ALL OFFICE, EMERGENCY ROOM, INPATIENT AND OUTPATIENT CHARTS
AND RECORDS (INCLUDING THE FRONT, BACK AND INSIDE OF ANY PAPER FILE
JACKETS), LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB
REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS,
INCLUDING SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND
DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS,
Page (1 of 3)
CLAIM NO: 0256939547.1
ORDER #: I15609
AND INSURANCE DOCUMENTS;
ANY AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE
CODES INCLUDING ALL CPT AND ICD-9 CODING AND ALL HCFA AND UB92 BILLS, TO
INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS
WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S
RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, ANY
INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS
BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER
GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION;
COPIES OF ALL ORIGINAL X-RAY FILMS, MRI AND CT SCANS AND ANY OTHER IMAGES
MAINTAINED, INCLUDING DATES AND BODY PARTS, RADIOLOGICAL REPORTS AND
PHOTOGRAPHS PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE
PATIENT, REGARDLESS OF TREATMENT DATE.BRADSHAW, LORRAINE; AKA: NOT
PROVIDED; DOB:
SSN:
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX
LEGAL SERVICES, INC. AT 888-531-2919, AND MORGAN & MORGAN, P.A. AT 407-420-1414
WITH A LIST OF ADDITIONAL DATES AND/OR CHARGES INVOLVED IN OBTAINING
THESE RECORDS BEFORE CREATING COPIES.
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 COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears
on this subpoena, and to MORGAN & MORGAN, P.A. on or before the scheduled date of
production. "The records requested will be used for this litigation only and will be returned or
destroyed after litigation is complete." Please contact Compex Legal Services, Inc. directly and send all
Medical Records, Bills, Films, and all other items necessary for compliance to:
COMPEX LEGAL SERVICES, INC., 8130 Anderson Road, Suite 302, Tampa, FL 33634, Tel:
888-531-2919, Fax: 310-618-5467
You may condition the preparation of the copies upon the payment in advance of the reasonable cost of
preparation. 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 by the attorney whose
name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you
shall respond to this subpoena as directed.
Page (2 of 3)
CLAIM NO: 0256939547.1
ORDER #: I15609
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. I have made a good faith attempt to provide written notice to the above-named patient,
through counsel, of intent to obtain the patient's health information pursuant to this
subpoena;
2. The written notice provided sufficient information about this litigation or proceeding in which
the protected health information is requested to permit the patient to raise an objection to
the court or administrative tribunal; and
3. The time of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
________ No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
________ tribunal and the disclosures being sought are consistent with such resolutions.
MICHELLE GERJEL, ESQ. Dated: ____________________
Attorney for Defendant(s)
FL Bar No. 0838772
LAW OFFICES OF ROBERT J. SMITH
390 NORTH ORANGE AVENUE, SUITE 895
By:
ORLANDO, FL 32801
For the Court
Telephone: 407-236-0558
Page (3 of 3)
Preview
Filing # 64998906 E-Filed 12/05/2017 04:22:25 PM CLAIM NO: 0256939547.1 ORDER #: I15609 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION LORRAINE BRADSHAW, CASE NO. 2017-CA-003987-O Plaintiff(s), vs. A L L S TAT E FIRE AND C A S UA LT Y INSURANCE COMPANY, Defendant(s), DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS FROM NON-PARTY YOU ARE HEREBY NOTIFIED that after fifteen (15) days from the date of service of this Notice, service is by email, and if no objection is received from any party, the undersigned will issue or apply to the Clerk of this court for the issuance of the attached Subpoena(s) directed to the following: Medical Records Custodian for NEUROSKELETAL IMAGING (NSI) 2222 SOUTH HARBOR CITY BOULEVARD, SUITE 520 MELBOURNE, FL 32901 Records Custodian for WALGREENS CORPORATION 1901 EAST VOORHEES STREET, MAIL STOP 735 DANVILLE, IL 61834 Medical Records Custodian for ABILITY REHABILITATION 20 SOUTH PARK AVENUE, SUITE A APOPKA, FL 32703 The above listed are not a party to this lawsuit and are requested to produce the items listed at the time and place specified in the attached Subpoena(s). Page 1 of 2 CLAIM NO: 0256939547.1 ORDER #: I15609 If you wish to receive copies of these documents, please advise the undersigned, in writing, and same will be provided, at a cost for photocopies, upon receipt. PLEASE BE GOVERNED ACCORDINGLY. I HEREBY CERTIFY that on December 5, 2017, a true and correct copy of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been furnished by email to: LAWRENCE GONZALEZ, II, ESQ MORGAN & MORGAN, P.A. 20 NORTH ORANGE AVENUE, SUITE 1600, 16TH FLOOR ORLANDO FL 32801 mcoriano-lopez@forthepeople.com lgonzalez@forthepeople.com sserrano@forthepeople.com LAW OFFICES OF ROBERT J. SMITH 390 NORTH ORANGE AVENUE, SUITE 895 ORLANDO, FL 32801 Telephone: 407-236-0558 Fax: 877-437-1334 By: MICHELLE GERJEL, ESQ. FL Bar No. 0838772 PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS: OrlandoLegal@Allstate.com Attorney for Defendant(s) ALLSTATE FIRE AND CASUALTY INS. CO. Page 2 of 2 CLAIM NO: 0256939547.1 ORDER #: I15609 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION LORRAINE BRADSHAW, CASE NO. 2017-CA-003987-O Plaintiff(s), vs. A L L S TAT E FIRE AND C A S UA LT Y INSURANCE COMPANY, Defendant(s), SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR NEUROSKELETAL IMAGING (NSI) 321-409-9990 2222 SOUTH HARBOR CITY BOULEVARD, SUITE 520 MELBOURNE, FL 32901 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at 8130 Anderson Road, Suite 302, Tampa, FL 33634, Fax: 888-531-2922 and to the c/o LAWRENCE GONZALEZ, II, ESQ., MORGAN & MORGAN, P.A., 20 NORTH ORANGE AVENUE, SUITE 1600, 16TH FLOOR, ORLANDO, FL 32801, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT (PAPER, ELECTRONIC OR DIGITAL IMAGE, CD ROM, DVD, HARD DRIVE, SCANNED DOCUMENTS AND EMAIL CORRESPONDENCE OR ANY OTHER FORM OR METHOD) INCLUDING, BUT NOT LIMITED TO, ALL OFFICE, EMERGENCY ROOM, INPATIENT AND OUTPATIENT CHARTS AND RECORDS (INCLUDING THE FRONT, BACK AND INSIDE OF ANY PAPER FILE JACKETS), LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, INCLUDING SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS, Page (1 of 3) CLAIM NO: 0256939547.1 ORDER #: I15609 AND INSURANCE DOCUMENTS; ANY AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9 CODING AND ALL HCFA AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; COPIES OF ALL ORIGINAL X-RAY FILMS, MRI AND CT SCANS AND ANY OTHER IMAGES MAINTAINED, INCLUDING DATES AND BODY PARTS, RADIOLOGICAL REPORTS AND PHOTOGRAPHS PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT, REGARDLESS OF TREATMENT DATE.BRADSHAW, LORRAINE; AKA: NOT PROVIDED; DOB: SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919, AND MORGAN & MORGAN, P.A. AT 407-420-1414 WITH A LIST OF ADDITIONAL DATES AND/OR CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears on this subpoena, and to MORGAN & MORGAN, P.A. on or before the scheduled date of production. "The records requested will be used for this litigation only and will be returned or destroyed after litigation is complete." Please contact Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC., 8130 Anderson Road, Suite 302, Tampa, FL 33634, Tel: 888-531-2919, Fax: 310-618-5467 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page (2 of 3) CLAIM NO: 0256939547.1 ORDER #: I15609 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. I have made a good faith attempt to provide written notice to the above-named patient, through counsel, of intent to obtain the patient's health information pursuant to this subpoena; 2. The written notice provided sufficient information about this litigation or proceeding in which the protected health information is requested to permit the patient to raise an objection to the court or administrative tribunal; and 3. The time of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) ________ No objections were filed; or All objections filed by the patient were resolved by the court or administrative ________ tribunal and the disclosures being sought are consistent with such resolutions. MICHELLE GERJEL, ESQ. Dated: ____________________ Attorney for Defendant(s) FL Bar No. 0838772 LAW OFFICES OF ROBERT J. SMITH 390 NORTH ORANGE AVENUE, SUITE 895 By: ORLANDO, FL 32801 For the Court Telephone: 407-236-0558 Page (3 of 3) CLAIM NO: 0256939547.1 ORDER #: I15609 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION LORRAINE BRADSHAW, CASE NO. 2017-CA-003987-O Plaintiff(s), vs. A L L S TAT E FIRE AND C A S UA LT Y INSURANCE COMPANY, Defendant(s), SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR WALGREENS CORPORATION 217-554-8949 1901 EAST VOORHEES STREET, MAIL STOP 735 DANVILLE, IL 61834 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at 8130 Anderson Road, Suite 302, Tampa, FL 33634, Fax: 888-531-2922 and to the c/o LAWRENCE GONZALEZ, II, ESQ., MORGAN & MORGAN, P.A., 20 NORTH ORANGE AVENUE, SUITE 1600, 16TH FLOOR, ORLANDO, FL 32801, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ANY AND ALL PRESCRIPTION AND PHARMACY RECORDS, INCLUDING BUT NOT LIMITED TO, CD ROM, TAPE DRIVE, FLOPPY DRIVE, HARD DRIVE, SCANNED DOCUMENTS AND ALL OTHER DOCUMENTS STORED ELECTRONICALLY OR DIGITALLY, AND OTHER MEMORANDA PERTAINING TO THE ISSUANCE AND SALE OF PRESCRIPTION DRUGS TO THE PATIENT, INCLUDING ALL ORIGINAL DOCTORS PRESCRIPTION FORMS, PAYMENT HISTORY, AND ANY OTHER PHARMACY RECORDS INCLUDING BUT NOT LIMITED TO PAYMENT HISTORY PERTAINING TO THE PATIENT REGARDLESS OF TREATMENT OR PRESCRIPTION DATE.BRADSHAW, LORRAINE; AKA: Page (1 of 3) CLAIM NO: 0256939547.1 ORDER #: I15609 NOT PROVIDED; DOB: SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919, AND MORGAN & MORGAN, P.A. AT 407-420-1414 WITH A LIST OF ADDITIONAL DATES AND/OR CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears on this subpoena, and to MORGAN & MORGAN, P.A. on or before the scheduled date of production. "The records requested will be used for this litigation only and will be returned or destroyed after litigation is complete." Please contact Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC., 8130 Anderson Road, Suite 302, Tampa, FL 33634, Tel: 888-531-2919, Fax: 310-618-5467 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page (2 of 3) CLAIM NO: 0256939547.1 ORDER #: I15609 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. I have made a good faith attempt to provide written notice to the above-named patient, through counsel, of intent to obtain the patient's health information pursuant to this subpoena; 2. The written notice provided sufficient information about this litigation or proceeding in which the protected health information is requested to permit the patient to raise an objection to the court or administrative tribunal; and 3. The time of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) ________ No objections were filed; or All objections filed by the patient were resolved by the court or administrative ________ tribunal and the disclosures being sought are consistent with such resolutions. MICHELLE GERJEL, ESQ. Dated: ____________________ Attorney for Defendant(s) FL Bar No. 0838772 LAW OFFICES OF ROBERT J. SMITH 390 NORTH ORANGE AVENUE, SUITE 895 By: ORLANDO, FL 32801 For the Court Telephone: 407-236-0558 Page (3 of 3) CLAIM NO: 0256939547.1 ORDER #: I15609 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION LORRAINE BRADSHAW, CASE NO. 2017-CA-003987-O Plaintiff(s), vs. A L L S TAT E FIRE AND C A S UA LT Y INSURANCE COMPANY, Defendant(s), SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR ABILITY REHABILITATION 407-880-8438 20 SOUTH PARK AVENUE, SUITE A APOPKA, FL 32703 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at 8130 Anderson Road, Suite 302, Tampa, FL 33634, Fax: 888-531-2922 and to the c/o LAWRENCE GONZALEZ, II, ESQ., MORGAN & MORGAN, P.A., 20 NORTH ORANGE AVENUE, SUITE 1600, 16TH FLOOR, ORLANDO, FL 32801, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT (PAPER, ELECTRONIC OR DIGITAL IMAGE, CD ROM, DVD, HARD DRIVE, SCANNED DOCUMENTS AND EMAIL CORRESPONDENCE OR ANY OTHER FORM OR METHOD) INCLUDING, BUT NOT LIMITED TO, ALL OFFICE, EMERGENCY ROOM, INPATIENT AND OUTPATIENT CHARTS AND RECORDS (INCLUDING THE FRONT, BACK AND INSIDE OF ANY PAPER FILE JACKETS), LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, INCLUDING SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS, Page (1 of 3) CLAIM NO: 0256939547.1 ORDER #: I15609 AND INSURANCE DOCUMENTS; ANY AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9 CODING AND ALL HCFA AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; COPIES OF ALL ORIGINAL X-RAY FILMS, MRI AND CT SCANS AND ANY OTHER IMAGES MAINTAINED, INCLUDING DATES AND BODY PARTS, RADIOLOGICAL REPORTS AND PHOTOGRAPHS PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT, REGARDLESS OF TREATMENT DATE.BRADSHAW, LORRAINE; AKA: NOT PROVIDED; DOB: SSN: IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919, AND MORGAN & MORGAN, P.A. AT 407-420-1414 WITH A LIST OF ADDITIONAL DATES AND/OR CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. 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 COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears on this subpoena, and to MORGAN & MORGAN, P.A. on or before the scheduled date of production. "The records requested will be used for this litigation only and will be returned or destroyed after litigation is complete." Please contact Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC., 8130 Anderson Road, Suite 302, Tampa, FL 33634, Tel: 888-531-2919, Fax: 310-618-5467 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. 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 by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page (2 of 3) CLAIM NO: 0256939547.1 ORDER #: I15609 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. I have made a good faith attempt to provide written notice to the above-named patient, through counsel, of intent to obtain the patient's health information pursuant to this subpoena; 2. The written notice provided sufficient information about this litigation or proceeding in which the protected health information is requested to permit the patient to raise an objection to the court or administrative tribunal; and 3. The time of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) ________ No objections were filed; or All objections filed by the patient were resolved by the court or administrative ________ tribunal and the disclosures being sought are consistent with such resolutions. MICHELLE GERJEL, ESQ. Dated: ____________________ Attorney for Defendant(s) FL Bar No. 0838772 LAW OFFICES OF ROBERT J. SMITH 390 NORTH ORANGE AVENUE, SUITE 895 By: ORLANDO, FL 32801 For the Court Telephone: 407-236-0558 Page (3 of 3)