Preview
Filing # 105924594 E-Filed 04/06/2020 04:43:19 PM
IN THE CIRCUIT COURT OF THE 19"
JUDICIAL CIRCUIT OF FLORIDA,
IN AND FOR MARTIN COUNTY,
FLORIDA
FREDERIC CHARLES GREER, III, and CASE NO. 2019-000015-CA
MELISSA ANNE GREER, as Husband and Wife,
and FREDERIC CHARLES GREER, III, and
MELISSA ANNE GREER, individually,
Plaintiffs,
vs.
MARTIN MEMORIAL MEDICAL CENTER, INC.
d/b/a MARTIN MEDICAL CENTER, a Florida
Corporation, KUNAL CHAUDHRY, M.D, and
CARDIOLOGY ASSOCIATES OF STUART, P.A.,
a Florida Profit Corporation,
Defendants.
/
MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a
MARTIN MEDICAL CENTER’S NOTICE OF N -PARTY PRODUCTION
YOU ARE HEREBY NOTIFIED that Defendant, MARTIN MEMORIAL MEDICAL
CENTER, INC. d/b/a MARTIN MEDICAL CENTER, by and through the undersigned
counsel, pursuant to Rule 1.351 (b), Fla.R.Civ.P., and files this Notice that after ten days (10)
days from the date of this Notice, if no objection is received from any party, Defendant will issue
the attached subpoenas directed to the following Records Custodian(s):
1. AdventHealth Orlando f/k/a Florida Hospital Orlando
601 E. Rollins Street
Orlando, FL 32803
Attn: PATHOLOGY DEPARTMENT
AdventHealth Medical Group Transplant at Orlando f/k/a
Florida Hospital Transplant Institute
2415 N. Orange Avenue, Suite 700
Orlando, FL 32804
Attn: PATHOLOGY DEPARTMENT
Electronically Filed Martin 04/06/2020 04:43 PM
GREER, MMMC, ET AL
CASE NO. 2019-000015-CA
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this 6'" day of April, 2020, a copy of the foregoing was
served via the Florida E-Filing Portal to the parties on the attached service list.
STEARNS WEAVER MILLER
WEISSLER ALHADEFF & SITTERSON, P.A.
Attorneys for Defendant MMMC
200 East Las Olas Blvd., Suite 2100
Fort Lauderdale, FL 33301
Telephone: (954) 462-9500
Facsimile: (954) 462-9567
By: Gace $-——
THOMAS G. AUBIN, ESQUIRE
FBN: 008060
taubin @stearnsweaver.com
MATTHEW S. PODOLNICK, ESQUIRE
FBN: 112126
mpodolnick @stearnsweaver.com
GREER. MMMC, ET AL
CASE NO. 2019-000015-CA
SERVICE LIST
Peter J. Somera Jr., Esq. Keith J. Puya, Esq.
Paul M. Silva, M.D., Esq. Hector R. Buigas, Esq.
Somera & Silva, LLP Law Offices of Keith J. Puya, P.A.
2255 Glades Road, Suite 232W 4880 Donald Ross Road, Suite 225
Boca Raton, FL 33431 Palm Beach Gardens, FL 33418
Phone: (561) 981-8881 Phone: (561) 408-3772
Fax: (561) 981-8887 Fax: (561) 408-3759
pleadings @somerasilva.com eservice@ puyalaw.con
litigation @somerasilva.con Attorneys for Defendants Kunal Chaudhry,
Attorneys for Plaintiffs M.D. and Cardiology Associates of Stuart,
PA.
Dinah Stein, Esq. Adam Richardson, Esq.
Hicks, Poerter, Ebenfeld & Stein Burlington & Rockenbach, P.A.
799 Brickell Plaza, 9"" Floor 444 West Railroad Avenue
Miami, FL 33131 West Palm Beach, FL 33401
Phone: (305) 375-8171 Tel: 561-721-0400
dstein@mhickslaw.com ajr@FLAppellateLaw.com
Attorneys for Defendants Kunal Chaudhry, fa@FLAppellateLaw.cor
M.D. and Cardiology Associates of Stuart, Appellate attorneys for Plaintiffs
PA,
#8328499 v1
IN THE CIRCUIT COURT OF THE 19"
JUDICIAL CIRCUIT OF FLORIDA,
IN AND FOR MARTIN COUNTY,
FLORIDA
CASE NO. 2019-000015-CA
FREDERIC CHARLES GREER, III, and RECORDS MAY BE MAILED OR
MELISSA ANNE GREER, as Husband and Wife, EMAILED IN LIEU OF
and FREDERIC CHARLES GREER, III, and APPEARANCE,
MELISSA ANNE GREER, individually, PLEASE CALL OR EMAIL
KATIA NETTO
Plaintiffs, WITH ANY QUESTIONS OR
COMMENTS:
vs.
(954) 462-9505
KNETTO@STEARNSWEAVER.COM
MARTIN MEMORIAL MEDICAL CENTER, INC.
d/b/a MARTIN MEDICAL CENTER, a Florida
Corporation, KUNAL CHAUDHRY, M.D. and
CARDIOLOGY ASSOCIATES OF STUART, P.A.,
a Florida Profit Corporation,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
PURSUANT TO F.R.C.P. 1.351
(Records may be mailed in lieu of appearance)
THE STATE OF FLORIDA
TO: Records Custodian and/or Representative of
AdventHealth Medical Group Transplant at Orlando f/k/a
Florida Hospital Transplant Institute
2415 N. Orange Avenue, Suite 700
Orlando, FL 32804
Attn: PATHOLOGY DEPARTMENT
(407) 303-2474
YOU ARE COMMANDED to appear at law offices of STEARNS WEAVER
MILLER WEISSLER ALHADEFF & SITTERSON, P.A., 200 E. Las Olas Boulevard, Suite
2100, Fort Lauderdale, FL 33301, on Thursday, April 30, 2020, at 10:00 A.M. and to have with
you at that time and place the following:
YOUR COMPLETE FILE, from the front cover to the back cover, all inclusive,
including but not limited to any and all pathology reports, recuts of the tissue or any other tissue
sent to pathology, complete set of representative pathology/histology slides recuts and paraffin
blocks, surgical pathology specimen, cytology slides with corresponding reports,
immunohistochemistry slides with corresponding reports, staining slides with corresponding
reports, pertaining to FREDERIC CHARLES GREER, III, DOB: XX/XX/1965, SS
XM. admissions beginning on September 1, 2017 to present date. If it is determi
there is not sufficient block material to permit recuts, then Defendant requests that the available
7
slides be sent or delivered to the undersigned Defendant's counsel pursuant to a chain of custody
procedure for non-destructive review/testing.
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 the 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 following attorney and unless
excused from this subpoena by this attorney of the Court, you shall respond to this subpoena as
directed.
HIPAA ASSURANCES
Pursuant to the regulations regarding the privacy of health information promulgated
under the authority of the Health Insurance Portability and Accountability Act ("HIPAA"), 45
C.P.R. §164.512(e)(ii)(A), the requestor herein provides the following satisfactory assurances
that reasonable efforts have been made to notify the individual who is the subject of the health
information requested in this Subpoena. Specifically:
a. The individual who is the subject of the health records requested by this Subpoena
is a party to this litigation and has put his or her health status in question, or this
action is being brought on his or her behalf by his or her legal representative.
The individual who is the subject of this request for health information, through
his or her attorney, was notified in writing of this request (copy of notice
attached) for the individual's health records pursuant to Florida Rules of Civil
Procedure 1.351, to object to this request.
The undersigned certifies that the individual who is the subject of this request for
health information has not filed any objections to this request for his or her health
information.
DATED this day of April, 2020.
STEARNS WEAVER MILLER
WEISSLER ALHADEFF & SITTERSON, P.A.
Attorneys for Defendant MMMC
200 East Las Olas Boulevard, Suite 2100
Fort Lauderdale, Florida 33301
Phone: (954) 462-9500
Fax: (954) 462-9567
By: flyd 2.
THOMAS G. AUBIN, ESQUIRE
FBN: 008060
taubin @stearnsweaver.com
MATTHEW S. PODOLNICK, ESQUIRE
FBN: 112126
mpodolnick @ stearnsweaver.com
FOR THE COURT
#8322098 v1
IN THE CIRCUIT COURT OF THE 19"
JUDICIAL CIRCUIT OF FLORIDA,
IN AND FOR MARTIN’ COUNTY,
FLORIDA
CASE NO. 2019-000015-CA
FREDERIC CHARLES GREER, III, and RECORDS MAY BE MAILED OR
MELISSA ANNE GREER, as Husband and Wife, EMAILED IN LIEU OF
and FREDERIC CHARLES GREER, III, and APPEARANCE.
MELISSA ANNE GREER, individually, PLEASE CALL OR EMAIL
KATIA NETTO
Plaintiffs, WITH ANY QUESTIONS OR
COMMENTS:
vs.
(954) 462-9505
KNETTO@STEARNS WEAVER.COM
MARTIN MEMORIAL MEDICAL CENTER, INC.
d/b/a MARTIN MEDICAL CENTER, a Florida
Corporation, KUNAL CHAUDHRY, M.D. and
CARDIOLOGY ASSOCIATES OF STUART, P.A.,
a Florida Profit Corporation,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
PURSUANT TO F.R.C.P. 1.351
(Records may be mailed in lieu of appearance)
THE STATE OF FLORIDA
TO: Records Custodian and/or Representative of
AdventHealth Orlando f/k/a Florida Hospital Orlando
601 E. Rollins Street
Orlando, FL 32803
Attn: PATHOLOGY DEPARTMENT
(407) 303-5600
YOU ARE COMMANDED to appear at law offices of STEARNS WEAVER MILLER
WEISSLER ALHADEFF & SITTERSON, P.A., 200 E. Las Olas Boulevard, Suite 2100, Fort
Lauderdale, FL 33301, on Thursday, April 30, 2020, at 10:00 A.M. and to have with you at
that time and place the following:
YOUR COMPLETE FILE, from the front cover to the back cover, all inclusive,
including but not limited to any and all pathology reports, recuts of the tissue or any other tissue
sent to pathology, complete set of representative pathology/histology slides recuts and paraffin
blocks, surgical pathology specimen, cytology slides with corresponding reports,
immunohistochemistry slides with corresponding reports, staining slides with corresponding
reports, pertaining to FREDERIC CHARLES GREER, III, DOB: XX/XX/1965, SSN i!
x admissions beginning on September 1, 2017 to present date. If it is determined that
there is not sufficient block material to permit recuts, then Defendant requests that the available
slides be sent or delivered to the undersigned Defendant's counsel pursuant to a chain of custody
procedure for non-destructive review/testing.
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 the 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 following attorney and unless
excused from this subpoena by this attorney of the Court, you shall respond to this subpoena as
directed.
HIPAA ASSURANCES
Pursuant to the regulations regarding the privacy of health information promulgated
under the authority of the Health Insurance Portability and Accountability Act ("HIPAA"), 45
C.F.R. §164.512(e)(ii)(A), the requestor herein provides the following satisfactory assurances
that reasonable efforts have been made to notify the individual who is the subject of the health
information requested in this Subpoena. Specifically:
a. The individual who is the subject of the health records requested by this Subpoena
is a party to this litigation and has put his or her health status in question, or this
action is being brought on his or her behalf by his or her legal representative.
The individual who is the subject of this request for health information, through
his or her attorney, was notified in writing of this request (copy of notice
attached) for the individual's health records pursuant to Florida Rules of Civil
Procedure 1.351, to object to this request.
The undersigned certifies that the individual who is the subject of this request for
health information has not filed any objections to this request for his or her health
information.
DATED this day of April, 2020.
STEARNS WEAVER MILLER
WEISSLER ALHADEFF & SITTERSON, P.A.
Attorneys for Defendant MMMC
200 East Las Olas Boulevard, Suite 2100
Fort Lauderdale, Florida 33301
Phone: (954) 462-9500
Fax: (954) 462-9567
By: Pheu AOS
THOMAS G. AUBIN, ESQUIRE
FBN: 008060
taubin @stearn com
MATTHEW S. PODOLNICK, ESQUIRE
FBN: 112126
mpodolnick @stearnsweaver.com
FOR THE COURT
#8324145 v1
Preview
Filing # 105924594 E-Filed 04/06/2020 04:43:19 PM IN THE CIRCUIT COURT OF THE 19" JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR MARTIN COUNTY, FLORIDA FREDERIC CHARLES GREER, III, and CASE NO. 2019-000015-CA MELISSA ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, III, and MELISSA ANNE GREER, individually, Plaintiffs, vs. MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER, a Florida Corporation, KUNAL CHAUDHRY, M.D, and CARDIOLOGY ASSOCIATES OF STUART, P.A., a Florida Profit Corporation, Defendants. / MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER’S NOTICE OF N -PARTY PRODUCTION YOU ARE HEREBY NOTIFIED that Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER, by and through the undersigned counsel, pursuant to Rule 1.351 (b), Fla.R.Civ.P., and files this Notice that after ten days (10) days from the date of this Notice, if no objection is received from any party, Defendant will issue the attached subpoenas directed to the following Records Custodian(s): 1. AdventHealth Orlando f/k/a Florida Hospital Orlando 601 E. Rollins Street Orlando, FL 32803 Attn: PATHOLOGY DEPARTMENT AdventHealth Medical Group Transplant at Orlando f/k/a Florida Hospital Transplant Institute 2415 N. Orange Avenue, Suite 700 Orlando, FL 32804 Attn: PATHOLOGY DEPARTMENT Electronically Filed Martin 04/06/2020 04:43 PM GREER, MMMC, ET AL CASE NO. 2019-000015-CA CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 6'" day of April, 2020, a copy of the foregoing was served via the Florida E-Filing Portal to the parties on the attached service list. STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A. Attorneys for Defendant MMMC 200 East Las Olas Blvd., Suite 2100 Fort Lauderdale, FL 33301 Telephone: (954) 462-9500 Facsimile: (954) 462-9567 By: Gace $-—— THOMAS G. AUBIN, ESQUIRE FBN: 008060 taubin @stearnsweaver.com MATTHEW S. PODOLNICK, ESQUIRE FBN: 112126 mpodolnick @stearnsweaver.com GREER. MMMC, ET AL CASE NO. 2019-000015-CA SERVICE LIST Peter J. Somera Jr., Esq. Keith J. Puya, Esq. Paul M. Silva, M.D., Esq. Hector R. Buigas, Esq. Somera & Silva, LLP Law Offices of Keith J. Puya, P.A. 2255 Glades Road, Suite 232W 4880 Donald Ross Road, Suite 225 Boca Raton, FL 33431 Palm Beach Gardens, FL 33418 Phone: (561) 981-8881 Phone: (561) 408-3772 Fax: (561) 981-8887 Fax: (561) 408-3759 pleadings @somerasilva.com eservice@ puyalaw.con litigation @somerasilva.con Attorneys for Defendants Kunal Chaudhry, Attorneys for Plaintiffs M.D. and Cardiology Associates of Stuart, PA. Dinah Stein, Esq. Adam Richardson, Esq. Hicks, Poerter, Ebenfeld & Stein Burlington & Rockenbach, P.A. 799 Brickell Plaza, 9"" Floor 444 West Railroad Avenue Miami, FL 33131 West Palm Beach, FL 33401 Phone: (305) 375-8171 Tel: 561-721-0400 dstein@mhickslaw.com ajr@FLAppellateLaw.com Attorneys for Defendants Kunal Chaudhry, fa@FLAppellateLaw.cor M.D. and Cardiology Associates of Stuart, Appellate attorneys for Plaintiffs PA, #8328499 v1 IN THE CIRCUIT COURT OF THE 19" JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR MARTIN COUNTY, FLORIDA CASE NO. 2019-000015-CA FREDERIC CHARLES GREER, III, and RECORDS MAY BE MAILED OR MELISSA ANNE GREER, as Husband and Wife, EMAILED IN LIEU OF and FREDERIC CHARLES GREER, III, and APPEARANCE, MELISSA ANNE GREER, individually, PLEASE CALL OR EMAIL KATIA NETTO Plaintiffs, WITH ANY QUESTIONS OR COMMENTS: vs. (954) 462-9505 KNETTO@STEARNSWEAVER.COM MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER, a Florida Corporation, KUNAL CHAUDHRY, M.D. and CARDIOLOGY ASSOCIATES OF STUART, P.A., a Florida Profit Corporation, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION PURSUANT TO F.R.C.P. 1.351 (Records may be mailed in lieu of appearance) THE STATE OF FLORIDA TO: Records Custodian and/or Representative of AdventHealth Medical Group Transplant at Orlando f/k/a Florida Hospital Transplant Institute 2415 N. Orange Avenue, Suite 700 Orlando, FL 32804 Attn: PATHOLOGY DEPARTMENT (407) 303-2474 YOU ARE COMMANDED to appear at law offices of STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A., 200 E. Las Olas Boulevard, Suite 2100, Fort Lauderdale, FL 33301, on Thursday, April 30, 2020, at 10:00 A.M. and to have with you at that time and place the following: YOUR COMPLETE FILE, from the front cover to the back cover, all inclusive, including but not limited to any and all pathology reports, recuts of the tissue or any other tissue sent to pathology, complete set of representative pathology/histology slides recuts and paraffin blocks, surgical pathology specimen, cytology slides with corresponding reports, immunohistochemistry slides with corresponding reports, staining slides with corresponding reports, pertaining to FREDERIC CHARLES GREER, III, DOB: XX/XX/1965, SS XM. admissions beginning on September 1, 2017 to present date. If it is determi there is not sufficient block material to permit recuts, then Defendant requests that the available 7 slides be sent or delivered to the undersigned Defendant's counsel pursuant to a chain of custody procedure for non-destructive review/testing. 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 the 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 following attorney and unless excused from this subpoena by this attorney of the Court, you shall respond to this subpoena as directed. HIPAA ASSURANCES Pursuant to the regulations regarding the privacy of health information promulgated under the authority of the Health Insurance Portability and Accountability Act ("HIPAA"), 45 C.P.R. §164.512(e)(ii)(A), the requestor herein provides the following satisfactory assurances that reasonable efforts have been made to notify the individual who is the subject of the health information requested in this Subpoena. Specifically: a. The individual who is the subject of the health records requested by this Subpoena is a party to this litigation and has put his or her health status in question, or this action is being brought on his or her behalf by his or her legal representative. The individual who is the subject of this request for health information, through his or her attorney, was notified in writing of this request (copy of notice attached) for the individual's health records pursuant to Florida Rules of Civil Procedure 1.351, to object to this request. The undersigned certifies that the individual who is the subject of this request for health information has not filed any objections to this request for his or her health information. DATED this day of April, 2020. STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A. Attorneys for Defendant MMMC 200 East Las Olas Boulevard, Suite 2100 Fort Lauderdale, Florida 33301 Phone: (954) 462-9500 Fax: (954) 462-9567 By: flyd 2. THOMAS G. AUBIN, ESQUIRE FBN: 008060 taubin @stearnsweaver.com MATTHEW S. PODOLNICK, ESQUIRE FBN: 112126 mpodolnick @ stearnsweaver.com FOR THE COURT #8322098 v1 IN THE CIRCUIT COURT OF THE 19" JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR MARTIN’ COUNTY, FLORIDA CASE NO. 2019-000015-CA FREDERIC CHARLES GREER, III, and RECORDS MAY BE MAILED OR MELISSA ANNE GREER, as Husband and Wife, EMAILED IN LIEU OF and FREDERIC CHARLES GREER, III, and APPEARANCE. MELISSA ANNE GREER, individually, PLEASE CALL OR EMAIL KATIA NETTO Plaintiffs, WITH ANY QUESTIONS OR COMMENTS: vs. (954) 462-9505 KNETTO@STEARNS WEAVER.COM MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER, a Florida Corporation, KUNAL CHAUDHRY, M.D. and CARDIOLOGY ASSOCIATES OF STUART, P.A., a Florida Profit Corporation, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION PURSUANT TO F.R.C.P. 1.351 (Records may be mailed in lieu of appearance) THE STATE OF FLORIDA TO: Records Custodian and/or Representative of AdventHealth Orlando f/k/a Florida Hospital Orlando 601 E. Rollins Street Orlando, FL 32803 Attn: PATHOLOGY DEPARTMENT (407) 303-5600 YOU ARE COMMANDED to appear at law offices of STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A., 200 E. Las Olas Boulevard, Suite 2100, Fort Lauderdale, FL 33301, on Thursday, April 30, 2020, at 10:00 A.M. and to have with you at that time and place the following: YOUR COMPLETE FILE, from the front cover to the back cover, all inclusive, including but not limited to any and all pathology reports, recuts of the tissue or any other tissue sent to pathology, complete set of representative pathology/histology slides recuts and paraffin blocks, surgical pathology specimen, cytology slides with corresponding reports, immunohistochemistry slides with corresponding reports, staining slides with corresponding reports, pertaining to FREDERIC CHARLES GREER, III, DOB: XX/XX/1965, SSN i! x admissions beginning on September 1, 2017 to present date. If it is determined that there is not sufficient block material to permit recuts, then Defendant requests that the available slides be sent or delivered to the undersigned Defendant's counsel pursuant to a chain of custody procedure for non-destructive review/testing. 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 the 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 following attorney and unless excused from this subpoena by this attorney of the Court, you shall respond to this subpoena as directed. HIPAA ASSURANCES Pursuant to the regulations regarding the privacy of health information promulgated under the authority of the Health Insurance Portability and Accountability Act ("HIPAA"), 45 C.F.R. §164.512(e)(ii)(A), the requestor herein provides the following satisfactory assurances that reasonable efforts have been made to notify the individual who is the subject of the health information requested in this Subpoena. Specifically: a. The individual who is the subject of the health records requested by this Subpoena is a party to this litigation and has put his or her health status in question, or this action is being brought on his or her behalf by his or her legal representative. The individual who is the subject of this request for health information, through his or her attorney, was notified in writing of this request (copy of notice attached) for the individual's health records pursuant to Florida Rules of Civil Procedure 1.351, to object to this request. The undersigned certifies that the individual who is the subject of this request for health information has not filed any objections to this request for his or her health information. DATED this day of April, 2020. STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A. Attorneys for Defendant MMMC 200 East Las Olas Boulevard, Suite 2100 Fort Lauderdale, Florida 33301 Phone: (954) 462-9500 Fax: (954) 462-9567 By: Pheu AOS THOMAS G. AUBIN, ESQUIRE FBN: 008060 taubin @stearn com MATTHEW S. PODOLNICK, ESQUIRE FBN: 112126 mpodolnick @stearnsweaver.com FOR THE COURT #8324145 v1