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AFFIDAVIT PROOF OF SERVICE
Attorney:Craig R. Stevens Case:00-120 CA
Address : 2000 Main St. Ste:402 Type:Subpoena /D.T./Without Depo
City :Fort Myers,Fl 33901 Court:Circuit
Type Of Serve PLAINTIFF: Sally Simon as Personal Represenative
of the estate of Michael Simon
Individual { } vs.
Substitute { DEFENDANT:Mark Asperilla,M.D. , et al
Not Found { }
Before me the undersigned authority appeared , who duly being sworn, deposes and says
that : William Chambers
is over the age of cighteen ( 18 ) years. And is not a party to the within action or proceeding. 1 recieved
this writ on the 19th = dayof June, 2000.
And served same on: Englewood Pharmacy / Records Custodian
The within named respondent at_2 1S _P .M on the al day of June, 2000.
INDIVIDUAL
By delivering to the within named ( Defendant , Witness , Respondent ) a true copy of this writ with the
time and date of service endorsed thereon by me and at the same time I delivered to the within named a
copy of the plaintiff's pleading as furnished by the plaintiff.
By leaving a true copy of the writ with date and hour of service endorsed thereon by me and a copy of
the plaintiff's initial pleading as furnished by the plaintiff at the within named ( Defendant , Witness ,
Respondent ) usual place of abode with some person of the family then and there residing above the age
of t5 years of age.
To wit! G: Chow
mp tow
And informing Such person of their contents,
NOT FOUND
And hereby return same anserved for reason that after diligent search and inquiry, the within named
( Defendant , Witness , Respondent
) could not be found.
Served at: 900 East Pine . Englewood, Florida
ro
ss
Further Affiant Sayeth Not
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Affiant: William Chambers #0023
SS
Appointed Pursuant To F.S.48,021 xe as oe 2
Notary Not Required Pursuant To F.S.92.525 me!
se =o
ae? 2
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., f 2¢ “
RONALD CONSTINE, M.D., LEVY, BAKER, CONSTINE ta
&GREENBERG, M.D., P.A., a Florida Corporation, Doty Pa
SAMUEL ESTEPA, M.D., PRIMARY CARE PHYSICIANS,
INC., a Florida Corporation, THOMAS K. WANZY, M.D., aie Ee
THOMAS K. WANZY, W.D., P.A., a Florida Corporation, eae BzB
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
Englewood Pharmacy
900 East Pine
Englewood, FL
941/475-3784
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 pharmaceutical, medical, hospital and health care
records, memoranda, charts, correspondence, and any and ail records
whatsoever you may have in your possession pertaining to the
pharmaceutical history of MICHAEL SIMON, SSN: Dos:
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. 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 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.
DATED on_\P7H , 2000.
Attorneys:
GEORGE, HARTZ, LUNDEEN /
& FULMER \ | |
Attorneys for Defendant
2000 Main Street By
Huntington Piaza, Suite 402 GRAIG R. STEVENS
Ft. Myers, FL 33901 FLORIDA BAR NO. 608149
Tele: (941) 337-7787 (for the Court)
Fax: (941) 337-4303
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AFFIDAVIT PROOF OF SERVICE Attorney:Craig R. Stevens Case:00-120 CA Address : 2000 Main St. Ste:402 Type:Subpoena /D.T./Without Depo City :Fort Myers,Fl 33901 Court:Circuit Type Of Serve PLAINTIFF: Sally Simon as Personal Represenative of the estate of Michael Simon Individual { } vs. Substitute { DEFENDANT:Mark Asperilla,M.D. , et al Not Found { } Before me the undersigned authority appeared , who duly being sworn, deposes and says that : William Chambers is over the age of cighteen ( 18 ) years. And is not a party to the within action or proceeding. 1 recieved this writ on the 19th = dayof June, 2000. And served same on: Englewood Pharmacy / Records Custodian The within named respondent at_2 1S _P .M on the al day of June, 2000. INDIVIDUAL By delivering to the within named ( Defendant , Witness , Respondent ) a true copy of this writ with the time and date of service endorsed thereon by me and at the same time I delivered to the within named a copy of the plaintiff's pleading as furnished by the plaintiff. By leaving a true copy of the writ with date and hour of service endorsed thereon by me and a copy of the plaintiff's initial pleading as furnished by the plaintiff at the within named ( Defendant , Witness , Respondent ) usual place of abode with some person of the family then and there residing above the age of t5 years of age. To wit! G: Chow mp tow And informing Such person of their contents, NOT FOUND And hereby return same anserved for reason that after diligent search and inquiry, the within named ( Defendant , Witness , Respondent ) could not be found. Served at: 900 East Pine . Englewood, Florida ro ss Further Affiant Sayeth Not oo we & == \) oe e. \\ ws Affiant: William Chambers #0023 SS Appointed Pursuant To F.S.48,021 xe as oe 2 Notary Not Required Pursuant To F.S.92.525 me! se =o ae? 2 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., f 2¢ “ RONALD CONSTINE, M.D., LEVY, BAKER, CONSTINE ta &GREENBERG, M.D., P.A., a Florida Corporation, Doty Pa SAMUEL ESTEPA, M.D., PRIMARY CARE PHYSICIANS, INC., a Florida Corporation, THOMAS K. WANZY, M.D., aie Ee THOMAS K. WANZY, W.D., P.A., a Florida Corporation, eae BzB 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 Englewood Pharmacy 900 East Pine Englewood, FL 941/475-3784 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 pharmaceutical, medical, hospital and health care records, memoranda, charts, correspondence, and any and ail records whatsoever you may have in your possession pertaining to the pharmaceutical history of MICHAEL SIMON, SSN: Dos: 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. 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 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. DATED on_\P7H , 2000. Attorneys: GEORGE, HARTZ, LUNDEEN / & FULMER \ | | Attorneys for Defendant 2000 Main Street By Huntington Piaza, Suite 402 GRAIG R. STEVENS Ft. Myers, FL 33901 FLORIDA BAR NO. 608149 Tele: (941) 337-7787 (for the Court) Fax: (941) 337-4303