Preview
Filing # 61405110 E-Filed 09/06/2017 04:35:02 PM
83260-5/ess/61211886
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
JOHN D. HINTON,
Plaintiff, CASE NO. 2017-CA-004883-0
VS.
UNIVERSAL STUDIOS WATER
PARKS FLORIDA, LLC d/b/a WET 'N
WILD,
Defendant.
/
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if
service isby delivery, or 15 days from the date of service, if service is by e-mail, and if
no objection is received from any party, the undersigned will issue or apply to the clerk of
this court for issuance of the attached subpoenas directed to:
Deep Agee, DDS
400 Semoran Blvd, #100
Casselberry, FL 32707
Care Spot
136 Parliament Loop, Suite 1020
Lake Mary, FL 32746
Elaine Lawless, RN
540 South Hunt Club Blvd
Apopka, FL 32803
Jose Costas, D.M.D.
225 S. Westmonte Dr
Altamonte Springs, FL 32703
who are not parties and whose addresses are indicated on the attached subpoenas, to
produce the items listed at the time and place specified in the subpoena.
CASE NO. 2017-CA-004883-0
WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida
ePortal to: Jackson W. Adams, Esquire, jadams@whkpa.com,
msaad@whkpa.com; on this 6thday of September, 2017.
/s/ Michael C. Tyson
Michael C. Tyson, Esquire
Florida Bar No. 865760
WICKER SMITH O'HARA MCCOY & FORD, P.A.
Attorneys for Universal Studios Water Parks Florida,
LLC d/b/a Wet 'n Wild
390 N. Orange Ave., Suite 1000
Orlando, FL 32801
Phone: (407) 843-3939
Fax: (407) 649-8118
ORLcrtpleadings@wickersmith.com
83260-5/ess/61211893
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
JOHN D. HINTON,
Plaintiff, CASE NO. 2017-CA-004883-0
VS.
UNIVERSAL STUDIOS WATER
PARKS FLORIDA, LLC d/b/a WET 'N
WILD,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Deep Agee, DDS
400 Semoran Blvd, #100
Casselberry, FL 32707
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 15
daysnotice to object our obtaining these records and this exact form has been provided to the
patient and/or the patienfs legal counsel.
YOU ARE COMMANDED to do one of the following at your option:
Mail legible copies of the documents listed below to Post Office Box 2753, Orlando, FL
32802 by October 6, 2017, or fifteen (15) days from the date this subpoena is
served; or
2. Appear at 390 North Orange Avenue, Suite 1000, Orlando, Florida 32801 with legible
copies of the documents listed below on October 6, 2017. PLEASE CONTACT THE
UNDERSIGNED'S OFFICE SHOULD YOU CHOOSE TO APPEAR.
DOCUMENTS TO BE PRODUCED: Your complete PATIENT CHART and PATIENT BILLING
RECORDS, including any and allrecords in your possession regarding the person named below
whether stored on paper or electronically, including but not limited to the items listed on the
attached Exhibit A.
****
PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN
YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES
****
AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS.
IF COPY COSTS WILL EXCEED $100.00, FEE APPROVAL MUST BE OBTAINED FROM
OUR OFFICE BEFORE ANY COPIES ARE MADE, OR WE WILL NOT BE RESPONSIBLE
FOR PAYING YOUR BILL FOR THE COPIES.
NAME: John Hinton
DOB: XX/XX/XXXX
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible
copies of the items to be produced to the attorney whose name appears on this
subpoena on or before the scheduled date of production. You may condition the
preparation of the copies upon the payment in advance of the reasonable cost of preparation.
You may mail or deliver the copies to the attorney whose name 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 must respond to this
subpoena as directed.
DATED on September, 2017
Michael C. Tyson, Esquire
For the Court
Florida Bar No. 865760
WICKER, SMITH, O'HARA,
McCOY & FORD, P.A.
Attorneys for Universal Studios Water Parks
Florida, LLC d/b/a Wet 'n Wild
390 N. Orange Ave., Suite 1000
Orlando, FL 32801
Phone: (407) 843-3939
Fax: (407) 649-8118
ORLcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to
participate in this proceeding should contact the undersigned attorneys secretary at the address and phone number
given above not later thanseven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-800-955-8770 via
Florida Relay Service.
"EXHIBIT A'
PLEASE CHECK OFF THE FOLLOWING ITEMS YOU HAVE LOCATED AND ARE
PRODUCING PURSUANT TO THIS SUBPOENA:
The Complete Medical Chart, including all Medical Records
Medical Bills/Lien Information
Office Notes
Telephone Notes or Slips
Reports of Surgical Procedures
NursesNotes
Doctors' Notes and Orders
Therapy Notes
Photographs
ACTUAL X-Rays/MRI Films/CT Scans/Ultrasounds/Heart
Catheterizations/Echocardiograms/EKG/EEG/ECG
Cardiology/X-Ray/MRI/CT Scan/Ultrasound Reports
Psychiatric/Psychological Evaluations
HIV/Drug Test Results
Diagnostic Test Results
Laboratory Results
Patient Questionnaires
Patient History Forms
Insurance Claim Forms
Workers' Compensation Claim Forms
Incident/Accident Memoranda or Forms
Emergency Care Documents
Correspondence to or from any source
Memoranda from any source
Medical Records from other providers or facilities
Consultation Reports
Prescriptions, Pharmaceutical Records, Requests or Orders
Consent Forms
Computer/electronic stored records
Written Instructions to Patient/Responsible Party
EMS/Ambulance Records
Admission Records
Outpatient Records
RECORDS CHECK MADE BY:
WICKER SMITH O'HARA
McCOY & FORD, P.A.
390 N. Orange Ave., Suite 1000
Post Office Box 2753
Orlando, FL 32802-2753
(407) 317-2152
83260-5/ess/61211893
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
JOHN D. HINTON,
Plaintiff, CASE NO. 2017-CA-004883-0
VS.
UNIVERSAL STUDIOS WATER
PARKS FLORIDA, LLC d/b/a WET 'N
WILD,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Care Spot
136 Parliament Loop, Suite 1020
Lake Mary, FL 32746
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 15
daysnotice to object our obtaining these records and this exact form has been provided to the
patient and/or the patienfs legal counsel.
YOU ARE COMMANDED to do one of the following at your option:
Mail legible copies of the documents listed below to Post Office Box 2753, Orlando, FL
32802 by October 6, 2017, or fifteen (15) days from the date this subpoena is
served; or
2. Appear at 390 North Orange Avenue, Suite 1000, Orlando, Florida 32801 with legible
copies of the documents listed below on October 6, 2017. PLEASE CONTACT THE
UNDERSIGNED'S OFFICE SHOULD YOU CHOOSE TO APPEAR.
DOCUMENTS TO BE PRODUCED: Your complete PATIENT CHART and PATIENT BILLING
RECORDS, including any and allrecords in your possession regarding the person named below
whether stored on paper or electronically, including but not limited to the items listed on the
attached Exhibit A.
****
PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN
YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES
****
AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS.
IF COPY COSTS WILL EXCEED $100.00, FEE APPROVAL MUST BE OBTAINED FROM
OUR OFFICE BEFORE ANY COPIES ARE MADE, OR WE WILL NOT BE RESPONSIBLE
FOR PAYING YOUR BILL FOR THE COPIES.
NAME: John Hinton
DOB: XX/XX/XXXX
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible
copies of the items to be produced to the attorney whose name appears on this
subpoena on or before the scheduled date of production. You may condition the
preparation of the copies upon the payment in advance of the reasonable cost of preparation.
You may mail or deliver the copies to the attorney whose name 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 must respond to this
subpoena as directed.
DATED on September, 2017
Michael C. Tyson, Esquire
For the Court
Florida Bar No. 865760
WICKER, SMITH, O'HARA,
McCOY & FORD, P.A.
Attorneys for Universal Studios Water Parks
Florida, LLC d/b/a Wet 'n Wild
390 N. Orange Ave., Suite 1000
Orlando, FL 32801
Phone: (407) 843-3939
Fax: (407) 649-8118
ORLcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to
participate in this proceeding should contact the undersigned attorneys secretary at the address and phone number
given above not later thanseven (7) days prior tothe proceeding. If hearing impaired, (TDD) 1-800-955-8770 via
Florida Relay Service.
"EXHIBIT A'
PLEASE CHECK OFF THE FOLLOWING ITEMS YOU HAVE LOCATED AND ARE
PRODUCING PURSUANT TO THIS SUBPOENA:
The Complete Medical Chart, including all Medical Records
Medical Bills/Lien Information
Office Notes
Telephone Notes or Slips
Reports of Surgical Procedures
NursesNotes
Doctors' Notes and Orders
Therapy Notes
Photographs
ACTUAL X-Rays/MRI Films/CT Scans/Ultrasounds/Heart
Catheterizations/Echocardiograms/EKG/EEG/ECG
Cardiology/X-Ray/MRI/CT Scan/Ultrasound Reports
Psychiatric/Psychological Evaluations
HIV/Drug Test Results
Diagnostic Test Results
Laboratory Results
Patient Questionnaires
Patient History Forms
Insurance Claim Forms
Workers' Compensation Claim Forms
Incident/Accident Memoranda or Forms
Emergency Care Documents
Correspondence to or from any source
Memoranda from any source
Medical Records from other providers or facilities
Consultation Reports
Prescriptions, Pharmaceutical Records, Requests or Orders
Consent Forms
Computer/electronic stored records
Written Instructions to Patient/Responsible Party
EMS/Ambulance Records
Admission Records
Outpatient Records
RECORDS CHECK MADE BY:
WICKER SMITH O'HARA
McCOY & FORD, P.A.
390 N. Orange Ave., Suite 1000
Post Office Box 2753
Orlando, FL 32802-2753
(407) 317-2152
83260-5/ess/61211893
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
JOHN D. HINTON,
Plaintiff, CASE NO. 2017-CA-004883-0
VS.
UNIVERSAL STUDIOS WATER
PARKS FLORIDA, LLC d/b/a WET 'N
WILD,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Elaine Lawless, RN
540 South Hunt Club Blvd
Apopka, FL 32803
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 15
daysnotice to object our obtaining these records and this exact form has been provided to the
patient and/or the patient's legal counsel.
YOU ARE COMMANDED to do one of the following at your option:
Mail legible copies of the documents listed below to Post Office Box 2753, Orlando, FL
32802 by October 6, 2017, or fifteen (15) days from the date this subpoena is
served; or
2. Appear at 390 North Orange Avenue, Suite 1000, Orlando, Florida 32801 with legible
copies of the documents listed below on October 6, 2017. PLEASE CONTACT THE
UNDERSIGNED'S OFFICE SHOULD YOU CHOOSE TO APPEAR.
DOCUMENTS TO BE PRODUCED: Your complete PATIENT CHART and PATIENT BILLING
RECORDS, including any and allrecords in your possession regarding the person named below
whether stored on paper or electronically, including but not limited to the items listed on the
attached Exhibit A.
****
PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN
YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES
****
AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS.
IF COPY COSTS WILL EXCEED $100.00, FEE APPROVAL MUST BE OBTAINED FROM
OUR OFFICE BEFORE ANY COPIES ARE MADE, OR WE WILL NOT BE RESPONSIBLE
FOR PAYING YOUR BILL FOR THE COPIES.
NAME: John Hinton
DOB: XX/XX/XXXX
These items will be inspected and may be copied at that time. You willnot be required to
surrender the original items. You may comply with this subpoena by providing legible
copies of the items to be produced to the attorney whose name appears on this
subpoena on or before the scheduled date of production. You may condition the
preparation of the copies upon the payment in advance of the reasonable cost of preparation.
You may mail or deliver the copies to the attorney whose name 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 must respond to this
subpoena as directed.
DATED on September, 2017
Michael C. Tyson, Esquire
For the Court
Florida Bar No. 865760
WICKER, SMITH, O'HARA,
McCOY & FORD, P.A.
Attorneys for Universal Studios Water Parks
Florida, LLC d/b/a Wet 'n Wild
390 N. Orange Ave., Suite 1000
Orlando, FL 32801
Phone: (407) 843-3939
Fax: (407) 649-8118
ORLcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to
participate in this proceeding should contact the undersigned attorneys secretary at the address and phone number
given above not later thanseven (7) days prior tothe proceeding. If hearing impaired, (TDD) 1-800-955-8770 via
Florida Relay Service.
"EXHIBIT A'
PLEASE CHECK OFF THE FOLLOWING ITEMS YOU HAVE LOCATED AND ARE
PRODUCING PURSUANT TO THIS SUBPOENA:
The Complete Medical Chart, including all Medical Records
Medical Bills/Lien Information
Office Notes
Telephone Notes or Slips
Reports of Surgical Procedures
NursesNotes
Doctors' Notes and Orders
Therapy Notes
Photographs
ACTUAL X-Rays/MRI Films/CT Scans/Ultrasounds/Heart
Catheterizations/Echocardiograms/EKG/EEG/ECG
Cardiology/X-Ray/MRI/CT Scan/Ultrasound Reports
Psychiatric/Psychological Evaluations
HIV/Drug Test Results
Diagnostic Test Results
Laboratory Results
Patient Questionnaires
Patient History Forms
Insurance Claim Forms
Workers' Compensation Claim Forms
Incident/Accident Memoranda or Forms
Emergency Care Documents
Correspondence to or from any source
Memoranda from any source
Medical Records from other providers or facilities
Consultation Reports
Prescriptions, Pharmaceutical Records, Requests or Orders
Consent Forms
Computer/electronic stored records
Written Instructions to Patient/Responsible Party
EMS/Ambulance Records
Admission Records
Outpatient Records
RECORDS CHECK MADE BY:
WICKER SMITH O'HARA
McCOY & FORD, P.A.
390 N. Orange Ave., Suite 1000
Post Office Box 2753
Orlando, FL 32802-2753
(407) 317-2152
83260-5/ess/61211893
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
JOHN D. HINTON,
Plaintiff, CASE NO. 2017-CA-004883-0
VS.
UNIVERSAL STUDIOS WATER
PARKS FLORIDA, LLC d/b/a WET 'N
WILD,
Defendant.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION**
**IF REQUESTED RECORDS ARE MAILED IN PRIOR
TO DEPOSITION DATE, YOU NEED NOT APPEAR
THE STATE OF FLORIDA:
TO: Records Custodian of:
Jose Costas, D.M.D.
225 S. Westmonte Dr
Altamonte Springs, FL 32703
HIPAA COMPLIANCE
In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 15
daysnotice to object our obtaining these records and this exact form has been provided to the
patient and/or the patient's legal counsel.
YOU ARE COMMANDED to do one of the following at your option:
Mail legible copies of the documents listed below to Post Office Box 2753, Orlando, FL
32802 by October 6, 2017, or fifteen (15) days from the date this subpoena is
served; or
2. Appear at 390 North Orange Avenue, Suite 1000, Orlando, Florida 32801 with legible
copies of the documents listed below on October 6, 2017. PLEASE CONTACT THE
UNDERSIGNED'S OFFICE SHOULD YOU CHOOSE TO APPEAR.
DOCUMENTS TO BE PRODUCED: Your complete PATIENT CHART and PATIENT BILLING
RECORDS, including any and allrecords in your possession regarding the person named below
whether stored on paper or electronically, including but not limited to the items listed on the
attached Exhibit A.
****
PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN
YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES
****
AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS.
IF COPY COSTS WILL EXCEED $100.00, FEE APPROVAL MUST BE OBTAINED FROM
OUR OFFICE BEFORE ANY COPIES ARE MADE, OR WE WILL NOT BE RESPONSIBLE
FOR PAYING YOUR BILL FOR THE COPIES.
NAME: John Hinton
DOB: XX/XX/XXXX
These items will be inspected and may be copied at that time. You willnot be required to
surrender the original items. You may comply with this subpoena by providing legible
copies of the items to be produced to the attorney whose name appears on this
subpoena on or before the scheduled date of production. You may condition the
preparation of the copies upon the payment in advance of the reasonable cost of preparation.
You may mail or deliver the copies to the attorney whose name 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 must respond to this
subpoena as directed.
DATED on September, 2017
Michael C. Tyson, Esquire
For the Court
Florida Bar No. 865760
WICKER, SMITH, O'HARA,
McCOY & FORD, P.A.
Attorneys for Universal Studios Water Parks
Florida, LLC d/b/a Wet 'n Wild
390 N. Orange Ave., Suite 1000
Orlando, FL 32801
Phone: (407) 843-3939
Fax: (407) 649-8118
ORLcrtpleadings@wickersmith.com
In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to
participate in this proceeding should contact the undersigned attorneys secretary at the address and phone number
given above not later thanseven (7) days prior tothe proceeding. If hearing impaired, (TDD) 1-800-955-8770 via
Florida Relay Service.
"EXHIBIT A'
PLEASE CHECK OFF THE FOLLOWING ITEMS YOU HAVE LOCATED AND ARE
PRODUCING PURSUANT TO THIS SUBPOENA:
The Complete Medical Chart, including all Medical Records
Medical Bills/Lien Information
Office Notes
Telephone Notes or Slips
Reports of Surgical Procedures
NursesNotes
Doctors' Notes and Orders
Therapy Notes
Photographs
ACTUAL X-Rays/MRI Films/CT Scans/Ultrasounds/Heart
Catheterizations/Echocardiograms/EKG/EEG/ECG
Cardiology/X-Ray/MRI/CT Scan/Ultrasound Reports
Psychiatric/Psychological Evaluations
HIV/Drug Test Results
Diagnostic Test Results
Laboratory Results
Patient Questionnaires
Patient History Forms
Insurance Claim Forms
Workers' Compensation Claim Forms
Incident/Accident Memoranda or Forms
Emergency Care Documents
Correspondence to or from any source
Memoranda from any source
Medical Records from other providers or facilities
Consultation Reports
Prescriptions, Pharmaceutical Records, Requests or Orders
Consent Forms
Computer/electronic stored records
Written Instructions to Patient/Responsible Party
EMS/Ambulance Records
Admission Records
Outpatient Records
RECORDS CHECK MADE BY:
WICKER SMITH O'HARA
McCOY & FORD, P.A.
390 N. Orange Ave., Suite 1000
Post Office Box 2753
Orlando, FL 32802-2753
(407) 317-2152
Preview
Filing # 61405110 E-Filed 09/06/2017 04:35:02 PM 83260-5/ess/61211886 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA JOHN D. HINTON, Plaintiff, CASE NO. 2017-CA-004883-0 VS. UNIVERSAL STUDIOS WATER PARKS FLORIDA, LLC d/b/a WET 'N WILD, Defendant. / NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service isby delivery, or 15 days from the date of service, if service is by e-mail, and if no objection is received from any party, the undersigned will issue or apply to the clerk of this court for issuance of the attached subpoenas directed to: Deep Agee, DDS 400 Semoran Blvd, #100 Casselberry, FL 32707 Care Spot 136 Parliament Loop, Suite 1020 Lake Mary, FL 32746 Elaine Lawless, RN 540 South Hunt Club Blvd Apopka, FL 32803 Jose Costas, D.M.D. 225 S. Westmonte Dr Altamonte Springs, FL 32703 who are not parties and whose addresses are indicated on the attached subpoenas, to produce the items listed at the time and place specified in the subpoena. CASE NO. 2017-CA-004883-0 WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida ePortal to: Jackson W. Adams, Esquire, jadams@whkpa.com, msaad@whkpa.com; on this 6thday of September, 2017. /s/ Michael C. Tyson Michael C. Tyson, Esquire Florida Bar No. 865760 WICKER SMITH O'HARA MCCOY & FORD, P.A. Attorneys for Universal Studios Water Parks Florida, LLC d/b/a Wet 'n Wild 390 N. Orange Ave., Suite 1000 Orlando, FL 32801 Phone: (407) 843-3939 Fax: (407) 649-8118 ORLcrtpleadings@wickersmith.com 83260-5/ess/61211893 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA JOHN D. HINTON, Plaintiff, CASE NO. 2017-CA-004883-0 VS. UNIVERSAL STUDIOS WATER PARKS FLORIDA, LLC d/b/a WET 'N WILD, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Deep Agee, DDS 400 Semoran Blvd, #100 Casselberry, FL 32707 HIPAA COMPLIANCE In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 15 daysnotice to object our obtaining these records and this exact form has been provided to the patient and/or the patienfs legal counsel. YOU ARE COMMANDED to do one of the following at your option: Mail legible copies of the documents listed below to Post Office Box 2753, Orlando, FL 32802 by October 6, 2017, or fifteen (15) days from the date this subpoena is served; or 2. Appear at 390 North Orange Avenue, Suite 1000, Orlando, Florida 32801 with legible copies of the documents listed below on October 6, 2017. PLEASE CONTACT THE UNDERSIGNED'S OFFICE SHOULD YOU CHOOSE TO APPEAR. DOCUMENTS TO BE PRODUCED: Your complete PATIENT CHART and PATIENT BILLING RECORDS, including any and allrecords in your possession regarding the person named below whether stored on paper or electronically, including but not limited to the items listed on the attached Exhibit A. **** PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES **** AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS. IF COPY COSTS WILL EXCEED $100.00, FEE APPROVAL MUST BE OBTAINED FROM OUR OFFICE BEFORE ANY COPIES ARE MADE, OR WE WILL NOT BE RESPONSIBLE FOR PAYING YOUR BILL FOR THE COPIES. NAME: John Hinton DOB: XX/XX/XXXX These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name 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 must respond to this subpoena as directed. DATED on September, 2017 Michael C. Tyson, Esquire For the Court Florida Bar No. 865760 WICKER, SMITH, O'HARA, McCOY & FORD, P.A. Attorneys for Universal Studios Water Parks Florida, LLC d/b/a Wet 'n Wild 390 N. Orange Ave., Suite 1000 Orlando, FL 32801 Phone: (407) 843-3939 Fax: (407) 649-8118 ORLcrtpleadings@wickersmith.com In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the undersigned attorneys secretary at the address and phone number given above not later thanseven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-800-955-8770 via Florida Relay Service. "EXHIBIT A' PLEASE CHECK OFF THE FOLLOWING ITEMS YOU HAVE LOCATED AND ARE PRODUCING PURSUANT TO THIS SUBPOENA: The Complete Medical Chart, including all Medical Records Medical Bills/Lien Information Office Notes Telephone Notes or Slips Reports of Surgical Procedures NursesNotes Doctors' Notes and Orders Therapy Notes Photographs ACTUAL X-Rays/MRI Films/CT Scans/Ultrasounds/Heart Catheterizations/Echocardiograms/EKG/EEG/ECG Cardiology/X-Ray/MRI/CT Scan/Ultrasound Reports Psychiatric/Psychological Evaluations HIV/Drug Test Results Diagnostic Test Results Laboratory Results Patient Questionnaires Patient History Forms Insurance Claim Forms Workers' Compensation Claim Forms Incident/Accident Memoranda or Forms Emergency Care Documents Correspondence to or from any source Memoranda from any source Medical Records from other providers or facilities Consultation Reports Prescriptions, Pharmaceutical Records, Requests or Orders Consent Forms Computer/electronic stored records Written Instructions to Patient/Responsible Party EMS/Ambulance Records Admission Records Outpatient Records RECORDS CHECK MADE BY: WICKER SMITH O'HARA McCOY & FORD, P.A. 390 N. Orange Ave., Suite 1000 Post Office Box 2753 Orlando, FL 32802-2753 (407) 317-2152 83260-5/ess/61211893 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA JOHN D. HINTON, Plaintiff, CASE NO. 2017-CA-004883-0 VS. UNIVERSAL STUDIOS WATER PARKS FLORIDA, LLC d/b/a WET 'N WILD, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Care Spot 136 Parliament Loop, Suite 1020 Lake Mary, FL 32746 HIPAA COMPLIANCE In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 15 daysnotice to object our obtaining these records and this exact form has been provided to the patient and/or the patienfs legal counsel. YOU ARE COMMANDED to do one of the following at your option: Mail legible copies of the documents listed below to Post Office Box 2753, Orlando, FL 32802 by October 6, 2017, or fifteen (15) days from the date this subpoena is served; or 2. Appear at 390 North Orange Avenue, Suite 1000, Orlando, Florida 32801 with legible copies of the documents listed below on October 6, 2017. PLEASE CONTACT THE UNDERSIGNED'S OFFICE SHOULD YOU CHOOSE TO APPEAR. DOCUMENTS TO BE PRODUCED: Your complete PATIENT CHART and PATIENT BILLING RECORDS, including any and allrecords in your possession regarding the person named below whether stored on paper or electronically, including but not limited to the items listed on the attached Exhibit A. **** PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES **** AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS. IF COPY COSTS WILL EXCEED $100.00, FEE APPROVAL MUST BE OBTAINED FROM OUR OFFICE BEFORE ANY COPIES ARE MADE, OR WE WILL NOT BE RESPONSIBLE FOR PAYING YOUR BILL FOR THE COPIES. NAME: John Hinton DOB: XX/XX/XXXX These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name 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 must respond to this subpoena as directed. DATED on September, 2017 Michael C. Tyson, Esquire For the Court Florida Bar No. 865760 WICKER, SMITH, O'HARA, McCOY & FORD, P.A. Attorneys for Universal Studios Water Parks Florida, LLC d/b/a Wet 'n Wild 390 N. Orange Ave., Suite 1000 Orlando, FL 32801 Phone: (407) 843-3939 Fax: (407) 649-8118 ORLcrtpleadings@wickersmith.com In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the undersigned attorneys secretary at the address and phone number given above not later thanseven (7) days prior tothe proceeding. If hearing impaired, (TDD) 1-800-955-8770 via Florida Relay Service. "EXHIBIT A' PLEASE CHECK OFF THE FOLLOWING ITEMS YOU HAVE LOCATED AND ARE PRODUCING PURSUANT TO THIS SUBPOENA: The Complete Medical Chart, including all Medical Records Medical Bills/Lien Information Office Notes Telephone Notes or Slips Reports of Surgical Procedures NursesNotes Doctors' Notes and Orders Therapy Notes Photographs ACTUAL X-Rays/MRI Films/CT Scans/Ultrasounds/Heart Catheterizations/Echocardiograms/EKG/EEG/ECG Cardiology/X-Ray/MRI/CT Scan/Ultrasound Reports Psychiatric/Psychological Evaluations HIV/Drug Test Results Diagnostic Test Results Laboratory Results Patient Questionnaires Patient History Forms Insurance Claim Forms Workers' Compensation Claim Forms Incident/Accident Memoranda or Forms Emergency Care Documents Correspondence to or from any source Memoranda from any source Medical Records from other providers or facilities Consultation Reports Prescriptions, Pharmaceutical Records, Requests or Orders Consent Forms Computer/electronic stored records Written Instructions to Patient/Responsible Party EMS/Ambulance Records Admission Records Outpatient Records RECORDS CHECK MADE BY: WICKER SMITH O'HARA McCOY & FORD, P.A. 390 N. Orange Ave., Suite 1000 Post Office Box 2753 Orlando, FL 32802-2753 (407) 317-2152 83260-5/ess/61211893 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA JOHN D. HINTON, Plaintiff, CASE NO. 2017-CA-004883-0 VS. UNIVERSAL STUDIOS WATER PARKS FLORIDA, LLC d/b/a WET 'N WILD, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Elaine Lawless, RN 540 South Hunt Club Blvd Apopka, FL 32803 HIPAA COMPLIANCE In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 15 daysnotice to object our obtaining these records and this exact form has been provided to the patient and/or the patient's legal counsel. YOU ARE COMMANDED to do one of the following at your option: Mail legible copies of the documents listed below to Post Office Box 2753, Orlando, FL 32802 by October 6, 2017, or fifteen (15) days from the date this subpoena is served; or 2. Appear at 390 North Orange Avenue, Suite 1000, Orlando, Florida 32801 with legible copies of the documents listed below on October 6, 2017. PLEASE CONTACT THE UNDERSIGNED'S OFFICE SHOULD YOU CHOOSE TO APPEAR. DOCUMENTS TO BE PRODUCED: Your complete PATIENT CHART and PATIENT BILLING RECORDS, including any and allrecords in your possession regarding the person named below whether stored on paper or electronically, including but not limited to the items listed on the attached Exhibit A. **** PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES **** AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS. IF COPY COSTS WILL EXCEED $100.00, FEE APPROVAL MUST BE OBTAINED FROM OUR OFFICE BEFORE ANY COPIES ARE MADE, OR WE WILL NOT BE RESPONSIBLE FOR PAYING YOUR BILL FOR THE COPIES. NAME: John Hinton DOB: XX/XX/XXXX These items will be inspected and may be copied at that time. You willnot be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name 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 must respond to this subpoena as directed. DATED on September, 2017 Michael C. Tyson, Esquire For the Court Florida Bar No. 865760 WICKER, SMITH, O'HARA, McCOY & FORD, P.A. Attorneys for Universal Studios Water Parks Florida, LLC d/b/a Wet 'n Wild 390 N. Orange Ave., Suite 1000 Orlando, FL 32801 Phone: (407) 843-3939 Fax: (407) 649-8118 ORLcrtpleadings@wickersmith.com In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the undersigned attorneys secretary at the address and phone number given above not later thanseven (7) days prior tothe proceeding. If hearing impaired, (TDD) 1-800-955-8770 via Florida Relay Service. "EXHIBIT A' PLEASE CHECK OFF THE FOLLOWING ITEMS YOU HAVE LOCATED AND ARE PRODUCING PURSUANT TO THIS SUBPOENA: The Complete Medical Chart, including all Medical Records Medical Bills/Lien Information Office Notes Telephone Notes or Slips Reports of Surgical Procedures NursesNotes Doctors' Notes and Orders Therapy Notes Photographs ACTUAL X-Rays/MRI Films/CT Scans/Ultrasounds/Heart Catheterizations/Echocardiograms/EKG/EEG/ECG Cardiology/X-Ray/MRI/CT Scan/Ultrasound Reports Psychiatric/Psychological Evaluations HIV/Drug Test Results Diagnostic Test Results Laboratory Results Patient Questionnaires Patient History Forms Insurance Claim Forms Workers' Compensation Claim Forms Incident/Accident Memoranda or Forms Emergency Care Documents Correspondence to or from any source Memoranda from any source Medical Records from other providers or facilities Consultation Reports Prescriptions, Pharmaceutical Records, Requests or Orders Consent Forms Computer/electronic stored records Written Instructions to Patient/Responsible Party EMS/Ambulance Records Admission Records Outpatient Records RECORDS CHECK MADE BY: WICKER SMITH O'HARA McCOY & FORD, P.A. 390 N. Orange Ave., Suite 1000 Post Office Box 2753 Orlando, FL 32802-2753 (407) 317-2152 83260-5/ess/61211893 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA JOHN D. HINTON, Plaintiff, CASE NO. 2017-CA-004883-0 VS. UNIVERSAL STUDIOS WATER PARKS FLORIDA, LLC d/b/a WET 'N WILD, Defendant. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION** **IF REQUESTED RECORDS ARE MAILED IN PRIOR TO DEPOSITION DATE, YOU NEED NOT APPEAR THE STATE OF FLORIDA: TO: Records Custodian of: Jose Costas, D.M.D. 225 S. Westmonte Dr Altamonte Springs, FL 32703 HIPAA COMPLIANCE In compliance with HIPAA Guidelines, this patient and/or his/her attorney has been given 15 daysnotice to object our obtaining these records and this exact form has been provided to the patient and/or the patient's legal counsel. YOU ARE COMMANDED to do one of the following at your option: Mail legible copies of the documents listed below to Post Office Box 2753, Orlando, FL 32802 by October 6, 2017, or fifteen (15) days from the date this subpoena is served; or 2. Appear at 390 North Orange Avenue, Suite 1000, Orlando, Florida 32801 with legible copies of the documents listed below on October 6, 2017. PLEASE CONTACT THE UNDERSIGNED'S OFFICE SHOULD YOU CHOOSE TO APPEAR. DOCUMENTS TO BE PRODUCED: Your complete PATIENT CHART and PATIENT BILLING RECORDS, including any and allrecords in your possession regarding the person named below whether stored on paper or electronically, including but not limited to the items listed on the attached Exhibit A. **** PLEASE DO NOT IMMEDIATELY REMIT COPIES OF ALL RADIOGRAPHIC STUDIES IN YOUR POSSESSION. WE WOULD REQUEST AN ITEMIZED LIST OF AVAILABLE STUDIES **** AND THE COST FOR DUPLICATION IN ORDER TO AVOID UNNECESSARY COSTS. IF COPY COSTS WILL EXCEED $100.00, FEE APPROVAL MUST BE OBTAINED FROM OUR OFFICE BEFORE ANY COPIES ARE MADE, OR WE WILL NOT BE RESPONSIBLE FOR PAYING YOUR BILL FOR THE COPIES. NAME: John Hinton DOB: XX/XX/XXXX These items will be inspected and may be copied at that time. You willnot be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name 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 must respond to this subpoena as directed. DATED on September, 2017 Michael C. Tyson, Esquire For the Court Florida Bar No. 865760 WICKER, SMITH, O'HARA, McCOY & FORD, P.A. Attorneys for Universal Studios Water Parks Florida, LLC d/b/a Wet 'n Wild 390 N. Orange Ave., Suite 1000 Orlando, FL 32801 Phone: (407) 843-3939 Fax: (407) 649-8118 ORLcrtpleadings@wickersmith.com In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the undersigned attorneys secretary at the address and phone number given above not later thanseven (7) days prior tothe proceeding. If hearing impaired, (TDD) 1-800-955-8770 via Florida Relay Service. "EXHIBIT A' PLEASE CHECK OFF THE FOLLOWING ITEMS YOU HAVE LOCATED AND ARE PRODUCING PURSUANT TO THIS SUBPOENA: The Complete Medical Chart, including all Medical Records Medical Bills/Lien Information Office Notes Telephone Notes or Slips Reports of Surgical Procedures NursesNotes Doctors' Notes and Orders Therapy Notes Photographs ACTUAL X-Rays/MRI Films/CT Scans/Ultrasounds/Heart Catheterizations/Echocardiograms/EKG/EEG/ECG Cardiology/X-Ray/MRI/CT Scan/Ultrasound Reports Psychiatric/Psychological Evaluations HIV/Drug Test Results Diagnostic Test Results Laboratory Results Patient Questionnaires Patient History Forms Insurance Claim Forms Workers' Compensation Claim Forms Incident/Accident Memoranda or Forms Emergency Care Documents Correspondence to or from any source Memoranda from any source Medical Records from other providers or facilities Consultation Reports Prescriptions, Pharmaceutical Records, Requests or Orders Consent Forms Computer/electronic stored records Written Instructions to Patient/Responsible Party EMS/Ambulance Records Admission Records Outpatient Records RECORDS CHECK MADE BY: WICKER SMITH O'HARA McCOY & FORD, P.A. 390 N. Orange Ave., Suite 1000 Post Office Box 2753 Orlando, FL 32802-2753 (407) 317-2152