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Filing # 107215587 E-Filed 05/07/2020 07:51:30 PM
AFFIDAVIT OF SERVICE
State of Florida County of Broward
Case Number: CACE19022586 (09) Court Date: 4/29/2020
Plaintiff:
ARIELLE ABRAMOVITZ
vs.
Defendant:
EARL SAWISCH
For:
ANICK A. FORCIER, ESQUIRE
Law Office of Michael W. Carroll (FTL)
Fla Bar No: 43899
3230 W. Commercial Bivd., Suite 400
Ft. Lauderdale, FL 33309
Received by THE SUBPOENA, SUMMONS & AFFIDAVIT CO. to be served on DR. MATTHEW WASHKO RECORD
CUSTODIAN, 2499 GLADES ROAD, SUITE 210, BOCA RATON, FL 33431.
|, LUISA MIJARES, being duly sworn, depose and say that on the 10th day of March, 2020 at 2:40 pm, |:
AUTHORIZED: served a true copy of the SUBPOENA DUCES TECUM(Pursuant to F.R.C.P. 1.351(c), effective
1/1/2011, this Subpoena may be served by mail or by hand delivery by a commercial delivery service) and
NOTICE OF PRODUCTION FROM NON PARTY with the date and hour of service endorsed thereon by me, to:
EMPLOYEE - PHONE 561-513-8380,
Additional Information pertaining to this Service:
3/10/2020 2:40 pm 2499 GLADES ROAD, SUITE 210, BOCA RATON, FL 33431 - EMPLOYEE - PHONE
561-513-8380
THE AFFIANT, being duly sworn, states: | certify that | am over the age of 18, have no interest in the above action,
and { am authorized by law, in good standing, to serve process in the judicial circuit in which the process was served.
: LUISA MIYARES
Subscribed and Sworn to before me by the affiant who is Process Server
persgnally known to me.
ote.
THE SUBPOENA, SUMMONS & AFFIDAVIT CO.
P. O. Box 398457
Miami Beach, FL 33139
(305) 757-5738
sare toiggars ne foamy
TO RUDINA DAKA tt
tary Public State o) 2228 || Our Job Serial Number: LDC-2020002615
ai { Ref: ABRAMOVITZ 193403004 AAF
Copyright © 1992-2020 Database Services, Inc. - Process Server's Toolbox VB. 1c
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/07/2020 07:50:47 PM.****IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
ARIELLE ABRAMOVITZ,,
Plaintiff,
v.
CASE NO: CACE19022586 (09)
EARL SAWISCH, CIVIL DIVISION
Defendant.
/
SUBPOENA DUCES TECUM
(Pursuant to F.R.C.P.1.351(c), effective 1/1/2011, this
Subpoena may be served by mail or by hand delivery by a commercial delivery service)
THE STATE OF FLORIDA:
TO: Record Custodian
Dr. Matthew Washko
2499 Glades Road Suite 210
Boca Raton, FL 33431
YOU ARE COMMANDED to appear at/mail records to Anick A. Forcier, Esq., Law Offices of Michael W.
Carroll, 3230 West Commercial Blvd., Suite 400, Fort Lauderdale, FL 33309 at the date and time noted below
and to have with you at that time, regarding the below named individual, the following:
DATE: April 29, 2020
TIME: 10:00 a.m.
RE: ARIELLE ABRAMOVITZ ssv: ror
YOUR ENTIRE FILE(S) WITH ALL CONTENTS FOR ANY AND ALL TREATMENT, including but not
limited to:
1. Complete copies of bills (paid and unpaid) with records of payments and/or charge offs, computer
printouts, etc.
2. Reports of X rays, MRIs, Scans, etc. as well as duplicate copies of X rays, CT scan films and MRI films.
(lease call this office first to advise of the duplication cost as well as the date of film and/or fax your invoice
for duplication setting forth the details of the particular film, i.e., date, type and what was filmed, including
your Tax ID No.). If any films have been checked out or released to any individuals and/or entities, please
provide the sign out sheet describing the film no longer in your possession, including the date the film was
released and to who it was released.
3. Any and all sign in sheets, telephone messages, prescriptions, computer printouts, hand written notes,
and insurance information.
4, Any and all records (this includes outside records from other providers or entities in your possession), log
in/sign in sheets, patient questionnaires, computerized records and records on microfilm/microfiche) pertaining to
Emergency Room treatment, in-patient treatment, out-patient treatment, including any and all medical and
chiropractic records, admission reports, consultation reports, initial evaluations, interim evaluations, final evaluations,
discharge summaries, clinical charts, clinical records, medical histories, chiropractic histories, patient questionnaire
forms, reports of physical examination, narrative reports, and reports, notes on attendance, charts, all correspondence,
letters, telephone messages, notes, claim forms, lien letters, letters of protection, diagnostic test results and studies, AND
ANY AND ALL RECORDS WHATSOEVER YOU MAY HAVE regarding the above named individual,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 (if copies are expected to exceed $50.00,
please contact our office for authorization). 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: qd) appear as specified; OR
(2) furnish the records instead of appearing as provided above; OR
@) 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 these attorneys or the Court, you shall respond to this Subpoena as directed,
DATED this 16th day of March, 2020
By:
ANICK A. FORCIER, ESQUIRE
Attorneys for Defendant
Law Offices of Michael W. Carroll
3230 West Commeréial Blvd., Suite 400+ .
Fort Lauderdale, FL 33309
(954) 233-9179 (Asst.)
Fax: (866) 841-8921
SERVICE DESIGNATIONS:
Primary: FtLauderdaleHC@Progressive.com
Secondary: aforciel@progressive.com
Florida Bar No. 43899
“Salaried Employees of Progressive Casualty Insurarrce Company”
Ronnie Wallace/Claim No: 193403004
Preview
Filing # 107215587 E-Filed 05/07/2020 07:51:30 PM AFFIDAVIT OF SERVICE State of Florida County of Broward Case Number: CACE19022586 (09) Court Date: 4/29/2020 Plaintiff: ARIELLE ABRAMOVITZ vs. Defendant: EARL SAWISCH For: ANICK A. FORCIER, ESQUIRE Law Office of Michael W. Carroll (FTL) Fla Bar No: 43899 3230 W. Commercial Bivd., Suite 400 Ft. Lauderdale, FL 33309 Received by THE SUBPOENA, SUMMONS & AFFIDAVIT CO. to be served on DR. MATTHEW WASHKO RECORD CUSTODIAN, 2499 GLADES ROAD, SUITE 210, BOCA RATON, FL 33431. |, LUISA MIJARES, being duly sworn, depose and say that on the 10th day of March, 2020 at 2:40 pm, |: AUTHORIZED: served a true copy of the SUBPOENA DUCES TECUM(Pursuant to F.R.C.P. 1.351(c), effective 1/1/2011, this Subpoena may be served by mail or by hand delivery by a commercial delivery service) and NOTICE OF PRODUCTION FROM NON PARTY with the date and hour of service endorsed thereon by me, to: EMPLOYEE - PHONE 561-513-8380, Additional Information pertaining to this Service: 3/10/2020 2:40 pm 2499 GLADES ROAD, SUITE 210, BOCA RATON, FL 33431 - EMPLOYEE - PHONE 561-513-8380 THE AFFIANT, being duly sworn, states: | certify that | am over the age of 18, have no interest in the above action, and { am authorized by law, in good standing, to serve process in the judicial circuit in which the process was served. : LUISA MIYARES Subscribed and Sworn to before me by the affiant who is Process Server persgnally known to me. ote. THE SUBPOENA, SUMMONS & AFFIDAVIT CO. P. O. Box 398457 Miami Beach, FL 33139 (305) 757-5738 sare toiggars ne foamy TO RUDINA DAKA tt tary Public State o) 2228 || Our Job Serial Number: LDC-2020002615 ai { Ref: ABRAMOVITZ 193403004 AAF Copyright © 1992-2020 Database Services, Inc. - Process Server's Toolbox VB. 1c *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/07/2020 07:50:47 PM.****IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA ARIELLE ABRAMOVITZ,, Plaintiff, v. CASE NO: CACE19022586 (09) EARL SAWISCH, CIVIL DIVISION Defendant. / SUBPOENA DUCES TECUM (Pursuant to F.R.C.P.1.351(c), effective 1/1/2011, this Subpoena may be served by mail or by hand delivery by a commercial delivery service) THE STATE OF FLORIDA: TO: Record Custodian Dr. Matthew Washko 2499 Glades Road Suite 210 Boca Raton, FL 33431 YOU ARE COMMANDED to appear at/mail records to Anick A. Forcier, Esq., Law Offices of Michael W. Carroll, 3230 West Commercial Blvd., Suite 400, Fort Lauderdale, FL 33309 at the date and time noted below and to have with you at that time, regarding the below named individual, the following: DATE: April 29, 2020 TIME: 10:00 a.m. RE: ARIELLE ABRAMOVITZ ssv: ror YOUR ENTIRE FILE(S) WITH ALL CONTENTS FOR ANY AND ALL TREATMENT, including but not limited to: 1. Complete copies of bills (paid and unpaid) with records of payments and/or charge offs, computer printouts, etc. 2. Reports of X rays, MRIs, Scans, etc. as well as duplicate copies of X rays, CT scan films and MRI films. (lease call this office first to advise of the duplication cost as well as the date of film and/or fax your invoice for duplication setting forth the details of the particular film, i.e., date, type and what was filmed, including your Tax ID No.). If any films have been checked out or released to any individuals and/or entities, please provide the sign out sheet describing the film no longer in your possession, including the date the film was released and to who it was released. 3. Any and all sign in sheets, telephone messages, prescriptions, computer printouts, hand written notes, and insurance information. 4, Any and all records (this includes outside records from other providers or entities in your possession), log in/sign in sheets, patient questionnaires, computerized records and records on microfilm/microfiche) pertaining to Emergency Room treatment, in-patient treatment, out-patient treatment, including any and all medical and chiropractic records, admission reports, consultation reports, initial evaluations, interim evaluations, final evaluations, discharge summaries, clinical charts, clinical records, medical histories, chiropractic histories, patient questionnaire forms, reports of physical examination, narrative reports, and reports, notes on attendance, charts, all correspondence, letters, telephone messages, notes, claim forms, lien letters, letters of protection, diagnostic test results and studies, AND ANY AND ALL RECORDS WHATSOEVER YOU MAY HAVE regarding the above named individual,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 (if copies are expected to exceed $50.00, please contact our office for authorization). 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: qd) appear as specified; OR (2) furnish the records instead of appearing as provided above; OR @) 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 these attorneys or the Court, you shall respond to this Subpoena as directed, DATED this 16th day of March, 2020 By: ANICK A. FORCIER, ESQUIRE Attorneys for Defendant Law Offices of Michael W. Carroll 3230 West Commeréial Blvd., Suite 400+ . Fort Lauderdale, FL 33309 (954) 233-9179 (Asst.) Fax: (866) 841-8921 SERVICE DESIGNATIONS: Primary: FtLauderdaleHC@Progressive.com Secondary: aforciel@progressive.com Florida Bar No. 43899 “Salaried Employees of Progressive Casualty Insurarrce Company” Ronnie Wallace/Claim No: 193403004