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Charlotte County Clerk
1095882 Date : 04/28/00 - 12:11:26 id: 14
Case#: 00000120CA vill 0003
(OMeGeley
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
SALLY SIMON, as Personal Representative
of the Estate of MICHAEL SIMON,
Plaintiff,
vs. Case No. 00-120 CA
MARK ASPERILLA, M.D., MARK ASPERILLA, M.D.
P.A., a Florida Corporation, DALE GREENBERG, M.D.,
RONALD CONSTINE, M.D., LEVY, BAKER, CONSTINE
&GREENBERG, M.D., P.A., a Florida Corporation,
SAMUEL ESTEPA, M.D., PRIMARY CARE PHYSICIANS,
INC., a Florida Corporation, THOMAS K. WANZY, M.D.,
THOMAS K. WANZY, M.D., P.A., a Florida Corporation,
BALA K. NANDIGAM, M.D., CHARLOTTE MEDICAL
ASSOCIATES, P.A., a Florida Corporation, MOIDEN
MOOPEN, M.D., MOIDEN MOOPEN, M.D., P.A., a
Florida Corporation, CARLOS E. MAAS, M.D.,
CARLOS E. MAAS, M.D., P.A., a Florida Corporation,
NASIR KHALIDI, M.D., NASIR KHALIDI & SAKINA
KHALIDI, M.D., P.A., a Florida Corporation, ST. JOSEPHS
EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M.D., CHRIS MICKELSON., M.D.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
(Records may be mailed in lieu of appearance
THE STATE OF FLORIDA,
TO: Records Custodian
Sarasota Plastic Surgery
YOU ARE COMMANDED to appear at the law offices of GEORGE, HARTZ,
LUNDEEN, & FULMER, 2000 Main Street, Huntington Plaza, Suite 402, Ft. Myers,
FL 33901, during normal business hours, on or before ten days after receipt of this
Subpoena, and to have with you at that time and place the following:
ANY AND ALL RECORDS IN YOUR POSSESSION FORM INCEPTION OF SERVICE,
INCLUDING BUT NOT LIMITED TO:ANY AND ALL records, documents, charts, papers, microfilmed
documents, x-rays reports (films may be ordered at a later date}, bill
for services rendered whether paid or unpaid, emergency room reports,
and any and all other evidence relating to the examination, treatment,
care, diagnosis, physical and mental condition of MICHAEL SIMON,
sh DOB: 05/25/42 from the inception of your
records to the present. If the reproduction cost exceeds $25.00
please contact Anne Armstrong.
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 these copies upon the payment in advance of the
reasonable | cost of preparation. m: i or deliv c th
Pilots name appears on this subpo 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.
If you fail to:
(1) appear as specified, or
(2) furnish the records instead of appearing as provided above,
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed by the attorneys whose
names appear on this subpoena and unless excused from this subpoena by the
attorneys or the court, you shall respond to this subpoena as directed.
patep on___-/F _- _, 2000.
Attorneys:
GEORGE, HARTZ, LUNDEEN
& FULMER
Attorneys for Defendant
2000 Main Street By:
Huntington Plaza, Suite 402 CRAIG R. STEVENS
Ft. Myers, FL 33901 FLORIDA BAR NO. 608149
Tele: (941) 337-7787 (for the Court)
Fax: (941) 337-4303
blo: Ltsq Chesney.
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