Preview
Filing # 70290144 E-Filed 04/05/2018 12:48:04 PM
CLAM NO: FLA-0150826
ORDER #:160590
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
BILLY BAILEY AND MARIA BAILEY,
CASE NO. 2017-CA-7814»
Plaintiff(s),
VS.
DANA HANA FISHER, MESHULAM SHULY FISHER
AND ESURANCE PROPERTY AND CASUALTY
INSURANCE,
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 isby email, and ifno objection isreceived 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
ORLANDO ORTHOPAEDIC CLINIC
25 WEST CRYSTAL LAKE STREET, SUITE 200
ORLANDO, FL 32806
Medical Records Custodian for
NSI OF ORLANDO
1315 SOUTH ORANGE AVENUE, SUITE IB
ORLANDO, FL 32806
Medical Records Custodian •for
ORLANDO CENTER FOR OUTPATIENT SURGERY
1405 SOUTH ORANGE AVENUE, SUITE 400
ORLANDO, FL 32806
Page 1 of 3
CIAIM NO: FLA-0150826
ORDER 14: 160590
TOTAL PAGES: 3
Medical Records Custodian for
MELISSA BROWN PFIYSICAL THERAPY & SPORTS MEDICINE
1405 SOUTH ORANGE AVENUE, SUITE 101
ORLANDO, FL 32806
The above listed are not a party to this lawsuit and are requested to produce the items listed at
the tirne and place specified in the attached Subpoena(s).
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.
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES
INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES.
PLEASE BE GOVERNED ACCORDINGLY.
Page 2 of 3
CIAIM NO: NA-0150826
ORDER 4: 160590
TOTAL PAGES: 3
•
t
I HEREBY CERTIFY that on the day of M7-R.6H, 2018, a true and correct copy
of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been
furnished by email to:
KATHLEEN S. DAVIES, ESQ. PAUL M. THOMPSON, ESQ.
THE DAVIES LAW FIRM, LLC THOMPSON & EVANGELO, P.A.
126 EAST JEFFERSON STREET 1485 INTERNATIONAL PARKWAY, SUITE 1051
ORLANDO FL 32801 LAKE MARY FL 32746
kdavies@thedavieslawfirrn.com Paul@thompsonevangelolaw.corn
klaube@thedavieslawfirm.corn sstoutAthompsonevangelolaw.com
Areynolds@thompsonevangelolaw.corn
CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT
150 SOUTH PALMETTO AVENUE, SUITE 200
DAYTONA BEACH, FL 32114
Telephone: 386-257-1755
Fax: 386-252-5601
By:
JULIA PINNELL EW
FL Bar No. 0899
PRINCIPAL EM L20
L FOR SERVICE OF PLEADINGS:
servicejp*ameron1iodges2.com
Secondary: Imorsep,cameronhodges2.corn
Attorney for Defendant(s)
ESURANCE PROPERTY AND CASUALTY
INSURANCE
Page 3 of 3
CLAIM NO: FLA-0150826
ORDER 4: 160590
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
BILLY BAILEY AND MARIA BAILEY,
CASE NO. 2017-CA-7814-
Plaintifi(s), 0
VS.
DANA RANA FISHER, MESHULAM SHULY FISHER.
AND ESURANCE PROPERTY AND CASUALTY
INSURANCE,
Defendant(s),
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
ORLANDO ORTHOPAEDIC CLINIC 407-254-2500
25 WEST CRYSTAL LAKE STREET, SUITE 200
ORLANDO, FL 32806
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, 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 al)
CLAIM NO: FLA-0150826
ORDER #: 160590
TOTAL, PAGES: 3
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, T() 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.BA1LEY, MARIA; AKA: MARIA
PEREZ; DOB: 09/08/1984
IF COPY CHARGES EXCEED S500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX
LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN
OBTAINING THESE RECORDS BEFORE CREATING COPIES.
These iterns will be inspected and may be copied at that tirne. You will not be required to surrender the
original iterns.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, 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 thissubpoena at any time before
production by giving written notice to the attorney whose name appears on thissubpoena. THIS WILL
NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
lf 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 rnay 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: FLA-0150826
ORDER 160590
'IOTA], PAGES: 3
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
to obtain patient health information and that the representations below are true
requirements
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 litigationor 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.
JULIA PINNELL, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 0899429
CAMERON, HODGES, COLEMAN, LAPOINTE
& WRIGHT
SUITE 200
By:
150 SOUTH PALMETTO AVENUE,
DAYTONA BEACH, FL 32114 j For the Court
Telephone: 386-257-1755
Page (3 of 3)
(LAIM NO: FLA-0150826
ORDER 4: 160590
ToTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
BILLY BAILEY AND MARIA BAILEY,
CASE NO. 2017-CA-7814-
PIaintiff(s), 0
VS.
DANA HANA FISHER, MESHULAM SHULY FISHER
AND ESURANCE PROPERTY AND CASUALTY
INSURANCE,
Defendant(s),
1
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
NSI OF ORLANDO 407-999-9977
1315 SOUTH ORANGE AVENUE, SUITE 113
ORLANDO, FL 32806
YOU ARE COMMANDED to produce without deposition and deliver by rnail or fax c/o Compex Legal
Services, Inc. located at 8130 Anderson Road, Suite 302, Tampa, FL 33634, Fax: 888-531-2922, 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: FLA-0150826
ORDER #: 160590
TOTAL PAGES: 3
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, MR1 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.BAILEY, MARIA; AKA: MARIA
PEREZ; DOB: 09/08/1984
IF COPY CHARGES EXCEED 5500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX
LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN
OBTAINING THESE RECORDS BEFORE CREATING COPIES.
These items will be inspected and rnay be copied at that time. You will not be required to surrender the
original iterns.You may comply with this subpoena by providing legible copies of the items to be
produced to COMPEX LEGAL SERVICES, INC., tbe agent of the attorney whose name appears
on this subpoena, 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 iscomplete." 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 rnay condition the preparation of the copies upon the payrnent 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
shallrespond to this subpoena as directed.
Page (2 of 3)
CLAIM NO: FLA-0150826
ORDER #:160590
Tarni PAGES: 3
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 isrequested 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.
JULIA PINNELL, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 0899429
CAMERON, HODGES, COLEMAN, LAPOINTE .1
& WRIGHT
150 SOUTH PALMETTO AVENUE, SUITE 200
By: At,
DAYTONA BEACH, FL 32114 \ F. the Court
Telephone: 386-257-1755
Page (3 of 3)
CLAIM NO: FLA-0150826
ORDER #:160590
TOTAL PAGES: 3
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
BILLY BAILEY AND MARIA BAILEY,
CASE NO. 2017-CA-7814-
Plaintiff(s), 0
vs.
DANA HANA FISHER, MESHULAM SHULY FISHER
AND ESURANCE PROPERTY AND CASUALTY
INSURANCE,
Defendant(s),
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
'TO: RECORDS CUSTODIAN FOR
ORLANDO CENTER FOR OUTPATIENT SURGERY 407-426-8331
1405 SOUTH ORANGE AVENUE, SUITE 400
ORLANDO, FL 32806
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, after
ten (10) days from the date of service of this subpoena, and to have with you at that tirne 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 C.HARTS
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 (I of 3)
CLAIM NO: FLA-0150826
ORDER #: 160590
TOTAL PAGES: 3
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.BAILEY, MARIA; AKA: MARIA
PEREZ; DOB: 09/08/1984
IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX
LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN
OBTAINING THESE RECORDS BEFORE CREATING COPIES.
These iterns 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, 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, Filrns,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 thissubpoena at any tirnebefore
production by giving written notice to the attorney whose name appears on thissubpoena. 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 frorn this subpoena by the attorney or the Court, you
shallrespond to this subpoena as directed.
Page (2 of 3)
CLAIM NO: FLA-0150826
ORDER #1: 160590
•TurAL PAGES: 3
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. l 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 litigationor proceeding in which
the protected health information isrequested 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,
JULIA PINNELL, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 0899429
..---
CAMERON, HODGES, COLEMAN, LAPOINTE
& WRIGHT
150 SOUTH PALMETTO AVENUE, SUITE 200
By: A -
DAYTONA
Telephone:
BEACH, FL 32114
386-257-1755
KF'• r the Court
Page (3 of 3)
CLAIM NO: FLA-0150826
ORDER #/: 160590
.form. PAGES: 3
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR. ORANGE COUNTY, FLORIDA
CIVIL DIVISION
BILLY BAILEY AND MARIA BAILEY,
CASE NO. 2017-CA-7814-
Plaintiff(s), 0
VS.
DANA NANA FISHER, MESHULAM SHULY FISHER
AND ESURANCE PROPERTY AND CASUALTY
INSURANCE,
Defendant(s),
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
MELISSA BROWN PHYSICAL THERAPY & SPORTS MEDICINE 407-522-4525
1405 SOUTH ORANGE AVENUE, SUITE 101
ORLANDO, FL 32806
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, 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: FLA-0150826
ORDER #: 160590
TOTAL PAGES: 3
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 1CD-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 SAH) INFORMATION;
COPIES OF ALL ORIGINAL X-RAY FILMS, MR1 AND CT SCANS AND ANY OTHER IMAGES
INCLUDING DATES AND BODY PARTS, RADIOLOGICAL REPORTS AND
MAINTAINED,
PHOTOGRAPHS PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE
REGARDLESS OF TREATMENT DATE.BA1LEY, MARIA; AKA: MARIA
PATIENT,
PEREZ; DOB: 09/08/1984
IF COPY CHARGES EXCEED 5500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX
LEGAL INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN
SERVICES,
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
legible copies of the items to be
original items. You may comply with this subpoena by providing
to COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears
produced
on this subpoena, on or before the scheduled date of production. "The records requested will be
will be returned destroyed after litigation is complete," Please
used for this litigation only and or
Services, inc. directly and send all Medical Records, Bills, Films, and all other
contact Compex Legal
items necessary for compliance to:
LEGAL INC., 8130 Anderson Road, Suite 302, Tampa, FL 33634, Tel:
COMPEX SERVICES,
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
the production pursuant to thissubpoena at tiine before
preparation. You have the right to object to any
WILL
production by giving written notice to the attorney whose name appears on this subpoena. THIS
NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
lf you fail to:(1) appear as specified; or (2) furnish the records instead of appearing as provided above; or
be in of You subpoenaed by the attorney whose
(3) object to this subpoena, you may conternpt court. are
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: FLA-0150826
ORDER 4:160590
rurn].. PAGES: 3
CERTIFICATE OF NOTICE
and Accountability Act of 1996 (HIPAA), 45
Pursuant to the Health Insurance Portability
I certify that I have complied with the regulations and
CFR Parts 160 and 164, hereby
obtain health information and that the representations below are true
requirements to patient
and correct:
1. I have made a good faith attempt to provide written notice to the above-named patient,
counsel, of intent to obtain the patient's health information pursuant to this
through
subpoena;
2. The written notice provided sufficient information about this litigation or proceeding in which
the health information is requested to permit the patient to raise an objection to
protected
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.
JULIA PINNELL, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 0899429
CAMERON, HODGES, COLEMAN, LAPOINTE
& WRIGHT \
By:
150 SOUTH PALMETTO AVENUE, SUITE 200
FL 32114
For the Court
DAYTONA BEACH,
Telephone: 386-257-1755
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Filing # 70290144 E-Filed 04/05/2018 12:48:04 PM CLAM NO: FLA-0150826 ORDER #:160590 TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION BILLY BAILEY AND MARIA BAILEY, CASE NO. 2017-CA-7814» Plaintiff(s), VS. DANA HANA FISHER, MESHULAM SHULY FISHER AND ESURANCE PROPERTY AND CASUALTY INSURANCE, 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 isby email, and ifno objection isreceived 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 ORLANDO ORTHOPAEDIC CLINIC 25 WEST CRYSTAL LAKE STREET, SUITE 200 ORLANDO, FL 32806 Medical Records Custodian for NSI OF ORLANDO 1315 SOUTH ORANGE AVENUE, SUITE IB ORLANDO, FL 32806 Medical Records Custodian •for ORLANDO CENTER FOR OUTPATIENT SURGERY 1405 SOUTH ORANGE AVENUE, SUITE 400 ORLANDO, FL 32806 Page 1 of 3 CIAIM NO: FLA-0150826 ORDER 14: 160590 TOTAL PAGES: 3 Medical Records Custodian for MELISSA BROWN PFIYSICAL THERAPY & SPORTS MEDICINE 1405 SOUTH ORANGE AVENUE, SUITE 101 ORLANDO, FL 32806 The above listed are not a party to this lawsuit and are requested to produce the items listed at the tirne and place specified in the attached Subpoena(s). 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. IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. PLEASE BE GOVERNED ACCORDINGLY. Page 2 of 3 CIAIM NO: NA-0150826 ORDER 4: 160590 TOTAL PAGES: 3 • t I HEREBY CERTIFY that on the day of M7-R.6H, 2018, a true and correct copy of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been furnished by email to: KATHLEEN S. DAVIES, ESQ. PAUL M. THOMPSON, ESQ. THE DAVIES LAW FIRM, LLC THOMPSON & EVANGELO, P.A. 126 EAST JEFFERSON STREET 1485 INTERNATIONAL PARKWAY, SUITE 1051 ORLANDO FL 32801 LAKE MARY FL 32746 kdavies@thedavieslawfirrn.com Paul@thompsonevangelolaw.corn klaube@thedavieslawfirm.corn sstoutAthompsonevangelolaw.com Areynolds@thompsonevangelolaw.corn CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 150 SOUTH PALMETTO AVENUE, SUITE 200 DAYTONA BEACH, FL 32114 Telephone: 386-257-1755 Fax: 386-252-5601 By: JULIA PINNELL EW FL Bar No. 0899 PRINCIPAL EM L20 L FOR SERVICE OF PLEADINGS: servicejp*ameron1iodges2.com Secondary: Imorsep,cameronhodges2.corn Attorney for Defendant(s) ESURANCE PROPERTY AND CASUALTY INSURANCE Page 3 of 3 CLAIM NO: FLA-0150826 ORDER 4: 160590 TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION BILLY BAILEY AND MARIA BAILEY, CASE NO. 2017-CA-7814- Plaintifi(s), 0 VS. DANA RANA FISHER, MESHULAM SHULY FISHER. AND ESURANCE PROPERTY AND CASUALTY INSURANCE, Defendant(s), SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR ORLANDO ORTHOPAEDIC CLINIC 407-254-2500 25 WEST CRYSTAL LAKE STREET, SUITE 200 ORLANDO, FL 32806 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, 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 al) CLAIM NO: FLA-0150826 ORDER #: 160590 TOTAL, PAGES: 3 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, T() 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.BA1LEY, MARIA; AKA: MARIA PEREZ; DOB: 09/08/1984 IF COPY CHARGES EXCEED S500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. These iterns will be inspected and may be copied at that tirne. You will not be required to surrender the original iterns.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, 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 thissubpoena at any time before production by giving written notice to the attorney whose name appears on thissubpoena. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN. lf 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 rnay 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: FLA-0150826 ORDER 160590 'IOTA], PAGES: 3 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 to obtain patient health information and that the representations below are true requirements 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 litigationor 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. JULIA PINNELL, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 0899429 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT SUITE 200 By: 150 SOUTH PALMETTO AVENUE, DAYTONA BEACH, FL 32114 j For the Court Telephone: 386-257-1755 Page (3 of 3) (LAIM NO: FLA-0150826 ORDER 4: 160590 ToTAL PAGES: 3 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION BILLY BAILEY AND MARIA BAILEY, CASE NO. 2017-CA-7814- PIaintiff(s), 0 VS. DANA HANA FISHER, MESHULAM SHULY FISHER AND ESURANCE PROPERTY AND CASUALTY INSURANCE, Defendant(s), 1 SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR NSI OF ORLANDO 407-999-9977 1315 SOUTH ORANGE AVENUE, SUITE 113 ORLANDO, FL 32806 YOU ARE COMMANDED to produce without deposition and deliver by rnail or fax c/o Compex Legal Services, Inc. located at 8130 Anderson Road, Suite 302, Tampa, FL 33634, Fax: 888-531-2922, 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: FLA-0150826 ORDER #: 160590 TOTAL PAGES: 3 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, MR1 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.BAILEY, MARIA; AKA: MARIA PEREZ; DOB: 09/08/1984 IF COPY CHARGES EXCEED 5500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. These items will be inspected and rnay be copied at that time. You will not be required to surrender the original iterns.You may comply with this subpoena by providing legible copies of the items to be produced to COMPEX LEGAL SERVICES, INC., tbe agent of the attorney whose name appears on this subpoena, 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 iscomplete." 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 rnay condition the preparation of the copies upon the payrnent 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 shallrespond to this subpoena as directed. Page (2 of 3) CLAIM NO: FLA-0150826 ORDER #:160590 Tarni PAGES: 3 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 isrequested 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. JULIA PINNELL, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 0899429 CAMERON, HODGES, COLEMAN, LAPOINTE .1 & WRIGHT 150 SOUTH PALMETTO AVENUE, SUITE 200 By: At, DAYTONA BEACH, FL 32114 \ F. the Court Telephone: 386-257-1755 Page (3 of 3) CLAIM NO: FLA-0150826 ORDER #:160590 TOTAL PAGES: 3 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION BILLY BAILEY AND MARIA BAILEY, CASE NO. 2017-CA-7814- Plaintiff(s), 0 vs. DANA HANA FISHER, MESHULAM SHULY FISHER AND ESURANCE PROPERTY AND CASUALTY INSURANCE, Defendant(s), SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: 'TO: RECORDS CUSTODIAN FOR ORLANDO CENTER FOR OUTPATIENT SURGERY 407-426-8331 1405 SOUTH ORANGE AVENUE, SUITE 400 ORLANDO, FL 32806 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, after ten (10) days from the date of service of this subpoena, and to have with you at that tirne 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 C.HARTS 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 (I of 3) CLAIM NO: FLA-0150826 ORDER #: 160590 TOTAL PAGES: 3 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.BAILEY, MARIA; AKA: MARIA PEREZ; DOB: 09/08/1984 IF COPY CHARGES EXCEED $500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. These iterns 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, 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, Filrns,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 thissubpoena at any tirnebefore production by giving written notice to the attorney whose name appears on thissubpoena. 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 frorn this subpoena by the attorney or the Court, you shallrespond to this subpoena as directed. Page (2 of 3) CLAIM NO: FLA-0150826 ORDER #1: 160590 •TurAL PAGES: 3 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. l 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 litigationor proceeding in which the protected health information isrequested 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, JULIA PINNELL, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 0899429 ..--- CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT 150 SOUTH PALMETTO AVENUE, SUITE 200 By: A - DAYTONA Telephone: BEACH, FL 32114 386-257-1755 KF'• r the Court Page (3 of 3) CLAIM NO: FLA-0150826 ORDER #/: 160590 .form. PAGES: 3 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR. ORANGE COUNTY, FLORIDA CIVIL DIVISION BILLY BAILEY AND MARIA BAILEY, CASE NO. 2017-CA-7814- Plaintiff(s), 0 VS. DANA NANA FISHER, MESHULAM SHULY FISHER AND ESURANCE PROPERTY AND CASUALTY INSURANCE, Defendant(s), SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR MELISSA BROWN PHYSICAL THERAPY & SPORTS MEDICINE 407-522-4525 1405 SOUTH ORANGE AVENUE, SUITE 101 ORLANDO, FL 32806 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, 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: FLA-0150826 ORDER #: 160590 TOTAL PAGES: 3 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 1CD-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 SAH) INFORMATION; COPIES OF ALL ORIGINAL X-RAY FILMS, MR1 AND CT SCANS AND ANY OTHER IMAGES INCLUDING DATES AND BODY PARTS, RADIOLOGICAL REPORTS AND MAINTAINED, PHOTOGRAPHS PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE REGARDLESS OF TREATMENT DATE.BA1LEY, MARIA; AKA: MARIA PATIENT, PEREZ; DOB: 09/08/1984 IF COPY CHARGES EXCEED 5500.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN SERVICES, 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 legible copies of the items to be original items. You may comply with this subpoena by providing to COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears produced on this subpoena, on or before the scheduled date of production. "The records requested will be will be returned destroyed after litigation is complete," Please used for this litigation only and or Services, inc. directly and send all Medical Records, Bills, Films, and all other contact Compex Legal items necessary for compliance to: LEGAL INC., 8130 Anderson Road, Suite 302, Tampa, FL 33634, Tel: COMPEX SERVICES, 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 the production pursuant to thissubpoena at tiine before preparation. You have the right to object to any WILL production by giving written notice to the attorney whose name appears on this subpoena. THIS NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. lf you fail to:(1) appear as specified; or (2) furnish the records instead of appearing as provided above; or be in of You subpoenaed by the attorney whose (3) object to this subpoena, you may conternpt court. are 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: FLA-0150826 ORDER 4:160590 rurn].. PAGES: 3 CERTIFICATE OF NOTICE and Accountability Act of 1996 (HIPAA), 45 Pursuant to the Health Insurance Portability I certify that I have complied with the regulations and CFR Parts 160 and 164, hereby obtain health information and that the representations below are true requirements to patient and correct: 1. I have made a good faith attempt to provide written notice to the above-named patient, counsel, of intent to obtain the patient's health information pursuant to this through subpoena; 2. The written notice provided sufficient information about this litigation or proceeding in which the health information is requested to permit the patient to raise an objection to protected 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. JULIA PINNELL, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 0899429 CAMERON, HODGES, COLEMAN, LAPOINTE & WRIGHT \ By: 150 SOUTH PALMETTO AVENUE, SUITE 200 FL 32114 For the Court DAYTONA BEACH, Telephone: 386-257-1755 Page (3 of 3)