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IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
SALLY SIMON, as Personal Representative
of the Estate of Michael Simon,
Plaintiff,
vs. Case No. 00-120 CA
MARK ASPIRILLA, M.D., MARK ASPIRILLA, M.D,
P.A., a Florida Corporation, DALE GREENGERG, 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, TOMAS K. WAS2NY, M.D.,
TOMAS K. WASZNY, M.D., P.A., a Florida Corporation,
BALA K. NANDIGAM, M.D., CHARLOTTE MEDICAL
ASSOCIATES, P.A., a Florida Corporation, MOODEN
MOOPEN., M.D., MOIDEN MOOPEN, M.D., P.A., a ae
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, S”. JOSEPHS aa
EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M.D., CHRIS MICKELSCN, M.D.,
Defendants. Do
! - Lt
SUBPOENA DUCES TECUM WIT! TION on
THE STATE OF FLORIDA:
TO: Medical Records Custodian for
Lakeside Terrace Skilled Nursing Center
5640 Rand Blvd.
Sarasota, Florida 34238
YOU ARE COMMANDED to appear at 3400 S. Tamiami Trail, Ste. 302 in
Sarasota, Florida, on Friday, April 14, 2000 at 10:00 a.m., and to have with you at that
time and place the following:
1. Any and all medical documents, including patient charts, copies of any
writing or markings on the folders containing the patient charts, previous treating
physician’s records, phone log records, appointment book records, e-mail,
computer records or orders, photographs, photograph negatives, x-ray films,
scans, tracings, request slips and radiology reports in your possession, custody
Charlotte County Clerk
C1079055 Date : 03/29/00 - 15:53:18 id: 8
Case#: 00000120CA Pages: 0003
ior control concerning the medical diagnosis, prognosis, care or treatment of
Michael Simon, DOB: 05/25/42, SSN No:
2. Any and all documents in your possassion, custody or control concerning
charges and payments for the medical care and treatment of Michael Simon.
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 attorneys 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 attorneys 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 attorneys 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; or
(3) object to this subpoena, y'ou 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.
DATED on 3-10 4999, 2000 |
BAR 3ARA SCOTT
As Clerk ofthe Court
By: _ ES ha Ton.
Claudia Rosenkoetter
Fla. Bar No: 311073
FOGLEMAN & ROSENKOETTER, P.A.
3400 S. Tamiami Trail, Suite 302
Sarasota, Florida 34239
(941) 365-4400
Attorney for Defendants Nandigam and
Charlotte Medical Associates, P.A.Subpoena Duces Ticcum Without Deposition CIRCUIT/CHARLOTTE 00 120 CA
COUNTY
TYPE OF PROCESS COURT CASE NUMBER
RE: SALLY SIMON, as Personal Representative of the Estate of Michael
Simon
VS. MARK ASPIRILLA, M.D. et. al.
ATTY: FOGLEMAN & ROSENKOETTER SERVE: MED. REC. CUST. FOR LAKESIDE
TERRACE SKILLED NURSING CENTER
3400 S. TAMIAMI TRAIL, STE. 302 5640 RAND BLVD.
SARASOTA, FL 34239 SARASOTA, FL 34238
Received this process gn ______ March 17, 7000.00 and... Served....same on
— MED. REC. CUST, FOR LAKESIDE TERRACE SKILLED ___ TRACY HARBILAS __, ___Witness _
at_2:30PM > om ach 20, 2000 ._____.» in __Sarasota _County, Plorida..
_X INDIVIDUAL SERVICE: By serving upon the withinnam:d ___— Witness ——spurrsuant to FS. 48.031(1). a
true copy of this process with the date and hour of service endorsed thereon by me and a true copy of complaint, petition,
or other initial pleading or paper (SEE COMMENTS).
—— SUBSTITUTE SERVICE: By serving a truc copy of this process with the date and hour of service endorsed thereon by
me anda copy of complaint, petition, or other initial pleading or paper (SEE COMMENTS), at the within named,
Witness... usual place of abode with a person residing therein who is 15 years or older pursuant to F.S. 48.03 1(1),
to wit ————
8. 49.03 1(2)(a), to spouse of
Witness... at
or pursuant to F, §. 48.031{2)(b), to
Defendant business, and informing such person of their contents.
or pursuant to
manager of
—__—«SCORPORATE SERVICE: By serving a tue copy of this process and a copy of the complaint, petition, or other
initial pleading or paper (SEE COMMENTS) upon as
of said corporation pursuant to____. F. S. 48.081;
F. £, 48.091; or F. S. 48.101.
F. S. 48.081(2); F, 8, 48.0813),
—— PARTNERSHIP SERVICE: By serving a true copy of this process and a copy of the complaint, petition, or other
initial pleading or paper (SEE COMMENTS) upon partner, or
upon a designated employee or person in charge of partnership pursuant
ta FS. 48.06104); __ FS. 48.061(2); or ES. 48.961).
— NON-SERVICE: After diligent search and inquiry failed to find said Witness in _ Sarasota County, Florida.
—— —Ss-:d COM MENTS:
SWORN and SUBSCRIBED to before me on_ Mare 21, 2000 Ray Feliciano #0134
who is personally known to me. a
nit : a < .
ae nance ————
Notary Public Certified Process Server
NOTARY PUBLIC «STATE OF FLORIDA Twelfth Judicial Circuit
con eEN NYDICK
COMMISSION # CCat4oa3,
EXPIRES 3/5/2002
BONDED THRU ASA 1-388 NOTARY?
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IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Plaintiff, vs. Case No. 00-120 CA MARK ASPIRILLA, M.D., MARK ASPIRILLA, M.D, P.A., a Florida Corporation, DALE GREENGERG, 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, TOMAS K. WAS2NY, M.D., TOMAS K. WASZNY, M.D., P.A., a Florida Corporation, BALA K. NANDIGAM, M.D., CHARLOTTE MEDICAL ASSOCIATES, P.A., a Florida Corporation, MOODEN MOOPEN., M.D., MOIDEN MOOPEN, M.D., P.A., a ae 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, S”. JOSEPHS aa EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M.D., CHRIS MICKELSCN, M.D., Defendants. Do ! - Lt SUBPOENA DUCES TECUM WIT! TION on THE STATE OF FLORIDA: TO: Medical Records Custodian for Lakeside Terrace Skilled Nursing Center 5640 Rand Blvd. Sarasota, Florida 34238 YOU ARE COMMANDED to appear at 3400 S. Tamiami Trail, Ste. 302 in Sarasota, Florida, on Friday, April 14, 2000 at 10:00 a.m., and to have with you at that time and place the following: 1. Any and all medical documents, including patient charts, copies of any writing or markings on the folders containing the patient charts, previous treating physician’s records, phone log records, appointment book records, e-mail, computer records or orders, photographs, photograph negatives, x-ray films, scans, tracings, request slips and radiology reports in your possession, custody Charlotte County Clerk C1079055 Date : 03/29/00 - 15:53:18 id: 8 Case#: 00000120CA Pages: 0003 ior control concerning the medical diagnosis, prognosis, care or treatment of Michael Simon, DOB: 05/25/42, SSN No: 2. Any and all documents in your possassion, custody or control concerning charges and payments for the medical care and treatment of Michael Simon. 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 attorneys 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 attorneys 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 attorneys 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; or (3) object to this subpoena, y'ou 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. DATED on 3-10 4999, 2000 | BAR 3ARA SCOTT As Clerk ofthe Court By: _ ES ha Ton. Claudia Rosenkoetter Fla. Bar No: 311073 FOGLEMAN & ROSENKOETTER, P.A. 3400 S. Tamiami Trail, Suite 302 Sarasota, Florida 34239 (941) 365-4400 Attorney for Defendants Nandigam and Charlotte Medical Associates, P.A.Subpoena Duces Ticcum Without Deposition CIRCUIT/CHARLOTTE 00 120 CA COUNTY TYPE OF PROCESS COURT CASE NUMBER RE: SALLY SIMON, as Personal Representative of the Estate of Michael Simon VS. MARK ASPIRILLA, M.D. et. al. ATTY: FOGLEMAN & ROSENKOETTER SERVE: MED. REC. CUST. FOR LAKESIDE TERRACE SKILLED NURSING CENTER 3400 S. TAMIAMI TRAIL, STE. 302 5640 RAND BLVD. SARASOTA, FL 34239 SARASOTA, FL 34238 Received this process gn ______ March 17, 7000.00 and... Served....same on — MED. REC. CUST, FOR LAKESIDE TERRACE SKILLED ___ TRACY HARBILAS __, ___Witness _ at_2:30PM > om ach 20, 2000 ._____.» in __Sarasota _County, Plorida.. _X INDIVIDUAL SERVICE: By serving upon the withinnam:d ___— Witness ——spurrsuant to FS. 48.031(1). a true copy of this process with the date and hour of service endorsed thereon by me and a true copy of complaint, petition, or other initial pleading or paper (SEE COMMENTS). —— SUBSTITUTE SERVICE: By serving a truc copy of this process with the date and hour of service endorsed thereon by me anda copy of complaint, petition, or other initial pleading or paper (SEE COMMENTS), at the within named, Witness... usual place of abode with a person residing therein who is 15 years or older pursuant to F.S. 48.03 1(1), to wit ———— 8. 49.03 1(2)(a), to spouse of Witness... at or pursuant to F, §. 48.031{2)(b), to Defendant business, and informing such person of their contents. or pursuant to manager of —__—«SCORPORATE SERVICE: By serving a tue copy of this process and a copy of the complaint, petition, or other initial pleading or paper (SEE COMMENTS) upon as of said corporation pursuant to____. F. S. 48.081; F. £, 48.091; or F. S. 48.101. F. S. 48.081(2); F, 8, 48.0813), —— PARTNERSHIP SERVICE: By serving a true copy of this process and a copy of the complaint, petition, or other initial pleading or paper (SEE COMMENTS) upon partner, or upon a designated employee or person in charge of partnership pursuant ta FS. 48.06104); __ FS. 48.061(2); or ES. 48.961). — NON-SERVICE: After diligent search and inquiry failed to find said Witness in _ Sarasota County, Florida. —— —Ss-:d COM MENTS: SWORN and SUBSCRIBED to before me on_ Mare 21, 2000 Ray Feliciano #0134 who is personally known to me. a nit : a < . ae nance ———— Notary Public Certified Process Server NOTARY PUBLIC «STATE OF FLORIDA Twelfth Judicial Circuit con eEN NYDICK COMMISSION # CCat4oa3, EXPIRES 3/5/2002 BONDED THRU ASA 1-388 NOTARY?