Preview
Filing # 125166992 E-Filed 04/19/2021 01:44:06 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-1106AN
Plaintiff(s),
VS.
CYNTHIA M. FOERSTER AND CYNTHIA M.
FOERSTER AND CHAPP, INC.
Defendant(s),
DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS
FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
Notice, service is by email, and if no objection is received 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:
Insurance Records Custodian for
AMICA MUTUAL INSURANCE COMPANY C/O CHIEF FINANCIAL OFFICER
200 EAST GAINES STREET
TALLAHASSEE, FL 32399
The above listed are not a party to this lawsuit and are requested to produce the items listed at
the time 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 $200.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 AND MORGAN & MORGAN, P.A. AT
407-452-6982 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE
RECORDS BEFORE CREATING COPIES.
PLEASE BE GOVERNED ACCORDINGLY.
Page lof 2
I HEREBY CERTIFY that on the 19th day of April, 2021 a true and correct copy
of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been
furnished by email to:
MANUEL STEFAN, ESQ.
MORGAN & MORGAN, P.A.
4495 SOUTH SEMORAN BLVD.
ORLANDO, FL 32822
MSTEFAN@FORTHEPEOPLE.COM
LAW OFFICES OF SANTEIRO & GARRISON
6300 UNIVERSITY PARKWAY, SUITE 101
SARASOTA, FL 34240-8424
Telephone: 800-226-3224 Ext 1021
Fax:
By: _/S/ Jorge Santeiro
JORGE SANTEIRO, ESQ.
FL BAR NO. 66230
PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS:
JSANTEIRO@FCCI-GROUP.COM
SSMITHS@FCCI-GROUP.COM
Attorney for Defendant(s)
CHAPP, INC.
Page 2 of 2
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-1106AN
Plaintiff(s),
VS.
CYNTHIA M. FOERSTER AND CYNTHIA M.
FOERSTER AND CHAPP, INC.
Defendant(s),
a
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
AMICA MUTUAL INSURANCE COMPANY C/O CHIEF FINANCIAL OFFICER MAIN:
800-622-6422, M: 800-622-6422
200 EAST GAINES STREET
TALLAHASSEE, FL 32399
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
$88-531.2922 and Morgan & Morgan, P.A.. at 4495 South Semoran Blvd... Orlando, FL
32822, Email: mstefan@forthepeople.com, after ten (10) days from the date of service of this
subpoena, and to have with you at that time and place the followmg:
SCOPE OF RECORDS LIMITED TO: 08/14/2017 TO PRESENT ONLY
ANY AND ALL RECORDS MAINTAINED IN THE PIP FILE.
INCLUDING, BUT NOT LIMITED TO ANY AND ALL RECORDS FOR THE 8-14-2017
INCIDENT. ALL NON-PRIVILEGED PORTIONS OF THEIR FILE INCLUDING
CRASH REPORT, MEDICAL AND BILLING RECORDS, PHOTOS, VEHICLE
REPAIR ESTIMATES, PIP AND OCCUPATIONAL THERAPY MEDICAL PAYOUT
AMOUNTS AND ANY BI PAYMENT AMOUNT.
XIAO SHENG YUE ; DOB: aml ssn: aaa
Page 1 of 3
IF COPY CHARGES EXCEED $200.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 AND MORGAN &
MORGAN, P.A. AT 407-452-6982 WITH A LIST OF THE CHARGES INVOLVED
IN 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 original items. You may comply with this subpeena by providing legible
copies of the items to be produced to COMPEX LEGAL SERVICES, INC., and
MORGAN & MORGAN, P.A., 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 send all Medical Records, Bills, Films, and all other items
necessary for compliance to:
COMPEX LEGAL SERVICES, INC., 5481 W. WATERS AVE. SUITE 108, TAMPA,
FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
and
Morgan & Morgan, P.A., 4495 South Semoran Blvd., Orlando, FL 32822
Tel: 407-452-6982, Fax: 407-572-0124
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 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 shall respond to this subpoena as directed.
Page 2 of 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and
requirements to cbtain patient health information and that the representations below are true
and correct:
1. | 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 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.
JORGE SANTEIRO, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 66230
LAW OFFICES OF SANTEIRO & GARRISON
6300 UNIVERSITY PARKWAY, SUITE 101 By: /s/ Jorge Santeiro
SARASOTA, FL 34240-8424 For the Court
Telephone: 800-226-3224 Ext 1021
Page 3 of3
Preview
Filing # 125166992 E-Filed 04/19/2021 01:44:06 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-1106AN Plaintiff(s), VS. CYNTHIA M. FOERSTER AND CYNTHIA M. FOERSTER AND CHAPP, INC. Defendant(s), DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS FROM NON-PARTY YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this Notice, service is by email, and if no objection is received 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: Insurance Records Custodian for AMICA MUTUAL INSURANCE COMPANY C/O CHIEF FINANCIAL OFFICER 200 EAST GAINES STREET TALLAHASSEE, FL 32399 The above listed are not a party to this lawsuit and are requested to produce the items listed at the time 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 $200.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 AND MORGAN & MORGAN, P.A. AT 407-452-6982 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. PLEASE BE GOVERNED ACCORDINGLY. Page lof 2 I HEREBY CERTIFY that on the 19th day of April, 2021 a true and correct copy of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been furnished by email to: MANUEL STEFAN, ESQ. MORGAN & MORGAN, P.A. 4495 SOUTH SEMORAN BLVD. ORLANDO, FL 32822 MSTEFAN@FORTHEPEOPLE.COM LAW OFFICES OF SANTEIRO & GARRISON 6300 UNIVERSITY PARKWAY, SUITE 101 SARASOTA, FL 34240-8424 Telephone: 800-226-3224 Ext 1021 Fax: By: _/S/ Jorge Santeiro JORGE SANTEIRO, ESQ. FL BAR NO. 66230 PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS: JSANTEIRO@FCCI-GROUP.COM SSMITHS@FCCI-GROUP.COM Attorney for Defendant(s) CHAPP, INC. Page 2 of 2 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-1106AN Plaintiff(s), VS. CYNTHIA M. FOERSTER AND CYNTHIA M. FOERSTER AND CHAPP, INC. Defendant(s), a SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR AMICA MUTUAL INSURANCE COMPANY C/O CHIEF FINANCIAL OFFICER MAIN: 800-622-6422, M: 800-622-6422 200 EAST GAINES STREET TALLAHASSEE, FL 32399 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: $88-531.2922 and Morgan & Morgan, P.A.. at 4495 South Semoran Blvd... Orlando, FL 32822, Email: mstefan@forthepeople.com, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the followmg: SCOPE OF RECORDS LIMITED TO: 08/14/2017 TO PRESENT ONLY ANY AND ALL RECORDS MAINTAINED IN THE PIP FILE. INCLUDING, BUT NOT LIMITED TO ANY AND ALL RECORDS FOR THE 8-14-2017 INCIDENT. ALL NON-PRIVILEGED PORTIONS OF THEIR FILE INCLUDING CRASH REPORT, MEDICAL AND BILLING RECORDS, PHOTOS, VEHICLE REPAIR ESTIMATES, PIP AND OCCUPATIONAL THERAPY MEDICAL PAYOUT AMOUNTS AND ANY BI PAYMENT AMOUNT. XIAO SHENG YUE ; DOB: aml ssn: aaa Page 1 of 3 IF COPY CHARGES EXCEED $200.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 AND MORGAN & MORGAN, P.A. AT 407-452-6982 WITH A LIST OF THE CHARGES INVOLVED IN 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 original items. You may comply with this subpeena by providing legible copies of the items to be produced to COMPEX LEGAL SERVICES, INC., and MORGAN & MORGAN, P.A., 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 send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC., 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 and Morgan & Morgan, P.A., 4495 South Semoran Blvd., Orlando, FL 32822 Tel: 407-452-6982, Fax: 407-572-0124 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 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 shall respond to this subpoena as directed. Page 2 of 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, | hereby certify that | have complied with the regulations and requirements to cbtain patient health information and that the representations below are true and correct: 1. | 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 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. JORGE SANTEIRO, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 66230 LAW OFFICES OF SANTEIRO & GARRISON 6300 UNIVERSITY PARKWAY, SUITE 101 By: /s/ Jorge Santeiro SARASOTA, FL 34240-8424 For the Court Telephone: 800-226-3224 Ext 1021 Page 3 of3