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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
SALLY SIMON, as Personal
Representative of the Estate of
Michael Simon,
Plaintiff, Case No. 00-120 CA
vs.
ah
oe
oe
MARK ASPERILLA, M.D., eg.
MARK ASPERILLA, M.D., P.A., co ee
a Florida Corporation, DALE
2%
\\
os
GREENBERG, M.D., RONALD om
CONSTINE, M.D., LEVY BAKER, ae
CONSTINE & GREENBERG, M.D.
P.A., a Florida Corporation, SAMUEL
ESTEPA, M.D., PRIMARY CARE & i
oe
7
PHYSICIANS, INC., a Florida Corporation,
THOMAS K, WANZY, M.D., THOMAS
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.,
mT
MOIDEN MOOPEN, M.D., P.A., a xTtO
oy
Florida Corporation, CARLOS E. MAAS, oj
M.D., CARLOS MAAS, M_D., P.A., a
Florida Corporation, NASIR KHALIDI, M.D.,
NASIR KHALIDI, M.D., & SAKINA
KHALIDI, M.D., P.A., a Florida Corporation,
ST. JOSEPH’S EMERGENCY MEDICAL
PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M.D., CHRIS
MICKELSON, M_D.,
Defendants,
/
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
notice, if service is by delivery, or 15 days from the date of service, if service is by mail, and if
no objection is received from any party, the undersigned will issue or apply to the clerk of this
court for issuance of the attached subpoenas directed to the records custodians of :
Bon Secours St. Joseph's Hospital
Jose I. Cabrera, M.D.
Charlotte Chiropractic Clinic
Charlotte Co. Emergency Medical Serivces
les oe
Fawcett Memorial Hospital
Healthsouth of Sarasota
Murdock Family Medicine
O. Sambandam, M_D., P.A., F.A.C.C., F.A.C.P.
Sarasota Memorial Hospital
Sarasota Plastic Surgery
Vascular Associates of Sarasota
The above listed are not parties to this lawsuit and are requested to produce the items
listed at the time and place specified in the attached subpoenas. If you wish to receive copies of
these documents, please advise the undersigned, in writing, and the same will be provided, at a
cost for photocopies, upon receipt.
CERTIFICATE OF SERVICE
Le
THEREBY TIFY that a true and correct copy of the foregoing has been furnished by
U.S. Mail on this “Alay of February, 2000, to:
Thomas A. Culmo, Esquire
Grove Professional Building
2950 S.W. 27th Ave.
Suite 100
Miami, FL 33133
Dennis A. Koltun, Esquire
7101 S.W. 102nd Ave.
Miami, FL 33173
Wicker, Smith, Tutan, O'Hara,
McCoy, Graham & Ford, P.A.
Attorneys for the Defendant, Dr. Khalidi
Post Office Box 2152, Tampa, FL 33601-2152
100 North Tampa Street, Suite 3650
Tampa, Florida 33602
=
Fax: 813-222-3938
ohn C. Hamilton, Esqrfire
LA
eer tenneen en
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
SALLY SIMON, as Personal
Representative of the Estate of
Michael Simon,
Plaintiff, Case No. 00-120 CA
vs.
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
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, MLD., P.A., a
Florida Corporation, CARLOS E. MAAS,
M.D., CARLOS MAAS, M_D., P.A., a
Florida Corporation, NASIR KHALIDI, M.D.,
NASIR KHALIDI, M.D., & SAKINA
KHALIDI, M_.D., P.A., a Florida Corporation,
ST. JOSEPH’S EMERGENCY MEDICAL
PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M.D., CHRIS
MICKELSON, M.D.,
Defendants.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT
OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers
TO: Records Custodian of:
Bon Secours St. Joseph's Hospital
2500 Harbor Blvd.
Port Charlotte, FL. 33952-5396
YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford,
P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to
have with you at that time and place the records pertaining to the following person or persons:
Name : Michael Simon
Date of Birth : May 25, 1942
SSN
Copies of any and all records from the date of commencement of such records to the present, regardless of
the date thereof pertaining to the above-identified person, including, but not limited to:
* Reports * Correspondence
* Orders * Patient History Questionnaires
_
* Summaries * Handwritten and typewritten notes
* Charts * Memoranda
* Consultation Reports * Counseling records/reports
* Test results * Hospital admission records
* Emergency Room records * Out-Patient records
* Flight Transport records * Prescriptions
* Radiation Therapy records * Rehabilitation records
* Lab tests/reports * Pathology reports
* Medication records * Statements and bills
* Disability statements * Psychological records
* Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.)
* Videotapes
* EEG and Brain Mapping Studies- inchiding: 1) The exact name, model number, and manufacturer of the
machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age
range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the
Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was
used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the
exact parts from which the Brain Mappings were made.
* X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or
imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans
etc however, please provide the reports of such studies initially so a determination can be made regarding
which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your
care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to
whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of
how old, including anything that might be on microfilm/micro-fiche or kept at another location.
TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND
EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document
or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify
the person, pursuant to whose instructions the documents or things were not produced, by name, address, and
employer. 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 ime and place specified above. You have tie cight te object to the production pursuant to this Subpoena at any
time before production by giving written notice to the attomey 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 to appear by the following attorney, and unless excused from this
subpoena by this attorney or the court, you shall respond to this subpoena as directed.
Dated POO
Wicker, Smith, Tutan, O'Hara,
McCoy, Graham & Ford, P.A.
Attomeys for the Defendant, Nasir Khatidt, M.D.
Post Office Box 2152, Tampa, Florida 33601-2152
100 North Tampa Street S 1650
Tampa, Fl
813-222-3939
aX: 813-222-393:
By.
Hamilton, Esquire:
Floy Bar No. 223743
In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to participate in this
proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650,
‘Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding.
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
SALLY SIMON, as Personal
Representative of the Estate of
Michael Simon,
Plaintiff, Case No. 00-120 CA
vs,
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
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_LD., P.A., a
Florida Corporation, CARLOS E. MAAS,
M.D., CARLOS MAAS, M_D., P.A., a
Florida Corporation, NASIR KHALIDI, M.D.,
NASIR KHALIDI, M.D., & SAKINA
KHALIDI, M_D., P.A., a Florida Corporation,
ST. JOSEPH’S EMERGENCY MEDICAL
PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M.D., CHRIS
MICKELSON, M.D.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT
OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers
TO: Records Custodian of:
Jose {. Cabrera, M.D.
2525 Harber Blvd.
Suite 303
Port Charlotte, FL 33952
YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford,
P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to
have with you at that time and place the records pertaining to the following person or persons:
Name : Michael Simon
Date of Birth : May 25, 1942
SSN
Copies of any and all records from the date of commencement of such records to the present, regardless of
the date thereof pertaining to the above-identified person, including, but not limited to:
* Reports * Correspondence
* Orders * Patient History Questionnaires
* Summaries * Handwritten and typewritten notes
* Charts * Memoranda
* Consultation Reports * Counseling records/reports
* Test results * Hospital admission records
* Emergency Room records * Out-Patient records
* Flight Transport records * Prescriptions
* Radiation Therapy records * Rehabilitation records
* Lab tests/reports * Pathology reports
* Medication records * Statements and bills
* Disability statements * Psychological records
* Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.)
* Videotapes
* EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the
machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age
range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the
Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was
used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the
exact parts from which the Brain Mappings were made.
* X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or
imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans
ete however, please provide the reports of such studies initially so a determination can be made regarding
which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your
care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to
whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of
how old, including anything that might be on microfilm/micro-fiche or kept at another location.
TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND
EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document
or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify
the person, pursuant to whose instructions the documents or things were not produced, by name, address, and
employer. 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 attomey 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. 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 to appear by the following attorney, and unless excused from this
subpoena by this attorney or the court, you shall respond to this subpoena as directed.
Dated 00
Wicker, Smith, Tutan, O'Hara,
McCoy, Graham & Ford, P.A.
Attorneys for the Defendant, Nasir Khalidi, M.D.
Post Office Box 2152, Tampa, Florida 33601-2152
100 North Tampa Street Suite 3650
Tampa, Florida 33602
Tel: 813-222-3939
Fax: pl 222-3938
By,
JohnC. Hantilton, Esqu
Florida Bar No. 223743
In accordance with the Americans with Disabilitles Act, persons with disabilities needing special accommodation to participate in this
proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650,
Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding.
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
SALLY SIMON, as Personal
Representative of the Estate of
Michael Simon,
Plaintiff, Case No. 00-120 CA
vs.
MARK ASPERILLA, MLD. ,
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
WANZY, M_LD., P.A., a Florida Corporation,
BALA K. NANDIGAM, M.D., CHARLOTTE
MEDICAL ASSOCIATES, P.A., a Florida
Corporation, MO[DEN MOOPEN, M.D.,
te
MOIDEN MOOPEN, M.D., P.A., 2
Florida Corporation, CARLOS E. MAAS,
M.D., CARLOS MAAS, M_D., P.A.,a
Florida Corporation, NASIR KHALIDI, M.D.,
NASIR KHALIDI, M.D., & SAKINA
KHALIDI, M_D., P.A., a Florida Corporation,
ST. JOSEPH’S EMERGENCY MEDICAL
PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M.D., CHRIS
MICKELSON, M_D.,
Defendants.
i
SUBPOENA DUCES TECUM WITHOUT DEPOSITION.
NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT
OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers
TO: Records Custodian of:
Charlotte Chiropractic Clinic
4065 Tamiami Trail
Port Charlotte, FL 33952
YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford,
P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to
have with you at that time and place the records pertaining to the following person or persons:
Name : Michael Simon
Date of Birth : May 25, 1942
SSN
Copies of any and all records from the date of commencement of such records to the present, regardless of
the date thereof pertaining to the above-identified person, including, but not limited to:
* Reports * Correspondence
* Orders * Patient History Questionnaires
* Summaries * Handwritten and typewritten notes
* Charts * Memoranda
* Consultation Reports * Counseling records/reports
* Test results * Hospital admission records
* Emergency Room records * Out-Patient records
* Flight Transport records * Prescriptions
* Radiation Therapy records * Rehabilitation records
* Lab tests/reports * Pathology reports
* Medication records * Statements and bills
* Disability statements * Psychological records
* Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.)
* Videotapes
* EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the
machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age
range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the
Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was
used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the
exact parts from which the Brain Mappings were made.
* X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or
imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans
etc however, please provide the reports of such studies initially so a determination can be made regarding
which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your
care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to
whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of
how old, including anything that might be on microfilm/micro-fiche or kept at another location.
TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND
EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document
or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify
the person, pursuant to whose instructions the documents or things were not produced, by name, address, and
employer. 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 attomey 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 attormey 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 to appear by the following attomey, and unless excused from this
subpoena by this attorney or the court, you shall respond to this subpoena as directed.
Dated 00
Wicker, Smith, Tutan, O'Hara,
McCoy, Graham & Ford, P.A.
Attomeys for the Defendant, Nasir Khalidi, M.D.
Post Office Box 2152, Tampa, Florida 33601-2152
100 North Tampa Street Suite 3650
Tampa, Florida 33602
Tel: 813-222-3939
Fax: AS bi,
By
John C. Hamilton, Esquire
Florida Bar No. 223743
In accordance with the Amertcans with Disabilities Act, persons with disabilities needing special accommodation to participate in this
proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650,
Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding.
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
SALLY SIMON, as Personal
Representative of the Estate of
Michael Simon,
Plaintiff, Case No. 00-120 CA
vs.
MARK ASPERILLA, MLD. ,
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
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.,
we
MOIDEN MOOPEN, M._D., P.A., a
Florida Corporation, CARLOS E. MAAS,
M.D., CARLOS MAAS, M.D., P.A., a
Florida Corporation, NASIR KHALIDI, M.D.,
NASIR KHALIDI, M.D., & SAKINA
KHALIDI, M_D., P.A., a Florida Corporation,
ST. JOSEPH’S EMERGENCY MEDICAL
PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M_D., CHRIS
MICKELSON, M.D.,
Defendants.
/
SUBPOENA DUCES TECUM. OUT DEPOSITION
NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT
OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers
TO: Records Custodian of:
Charlotte Co. Emergency Medical Services
22429 Edgewater Dr.
Punta Gorda, FL 33980
YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford,
P.A,, 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to
have with you at that time and place the records pertaining to the following person or persons:
Name : Michael Simon
Date of Birth : May 25, 1942
SSN
Copies of any and ail records from the date of commencement of such records to the present, regardless of
the date thereof pertaining to the above-identified person, including, but not limited to:
* Reports * Correspondence
* Orders * Patient History Questionnaires
* Summaries * Handwritten and typewritten notes
* Charts * Memoranda
* Consultation Reports * Counseling records/reports
* Test results * Hospital admission records
* Emergency Room records * Out-Patient records
* Flight Transport records * Prescriptions
* Radiation Therapy records * Rehabilitation records
* Lab tests/reports * Pathology reports
* Medication records * Statements and bills
* Disability statements * Psychological records
* Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.)
* Videotapes
* EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the
machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age
tange, and behavioral state for the alleged normal values the above-referenced patient was compared to during the
Brain Mappings & EEG's; 3) All replications of ail Brain Mappings and Evoked Potentials in color (if color was
used); 4) Copies of all actual original EEG’s from which the Brain Mappings were made with indications of the
exact parts from which the Brain Mappings were made.
* X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or
imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans
etc however, please provide the reports of such studies initially so a determination can be made regarding
which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your
care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to
whom this subpoena is directed, be produced. This subpoeya encompasses all documents and things, regardless of
how old, including anything that might be on microfilm/miero-fiche or kept at another location.
TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND
EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document
or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify
the person, pursuant to whose instructions the documents or things were not produced, by name, address, and
employer. 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 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 to appear by the following attorney, and unless excused from this
subpoena by this attorney or the court, you shall respond to this subpoena as directed.
Dated 00
Wicker, Smith, Tutan, O'Hara,
McCoy, Graham & Ford, P.A.
Attorneys for the Defendant, Nasir Khalidi, M.D.
Post Office Box 2152, Tampa, Florida 33601-2152
100 North Tampa Street Suite 3650
‘Tampa, Florida 33602
Tel 813-222-3039
Fax: 39:
By. he of ye
John C. familton, Esquire
Florida Bar No. 223743
In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to participate in this
proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650,
Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding.
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA.
SALLY SIMON, as Personal
Representative of the Estate of
Michael Simon,
Plaintiff, Case No. 00-120 CA
vs.
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
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., 2
Florida Corporation, CARLOS E. MAAS,
M.D., CARLOS MAAS, M.D., P.A., a
Florida Corporation, NASIR KHALIDI, M_D.,
NASIR KHALIDI, M.D., & SAKINA
KHALIDI, M.D., P.A., a Florida Corporation,
ST. JOSEPH’S EMERGENCY MEDICAL
PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M_D., CHRIS
MICKELSON, M.D.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT
OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers
TO: Records Custodian of:
Fawcett Memorial Hospital
20298 Olean Boulevard
Port Charlotte, FL 33952
YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford,
P.A,, 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to
have with you at that time and place the records pertaining to the following person or persons:
Name : Michael Simon
Date of Birth
SSN
Copies of any and all records from the date of commencement of such records to the present, regardless of
the date thereof pertaining to the above-identified person, including, but not limited to:
* Reports “ Correspondence
* Orders * Patient History Questionnaires
* Summaries * Handwritten and typewritten notes
* Charts * Memoranda
* Consultation Reports * Counseling records/reports
* Test results * Hospital admission records
* Emergency Room records * Out-Patient records
* Flight Transport records * Prescriptions
* Radiation Therapy records * Rehabilitation records
* Lab tests/reports * Pathology reports
* Medication records * Statements and bills
* Disability statements * Psychological records
* Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.)
* Videotapes
* EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the
machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age
range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the
Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was
used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the
exact parts from which the Brain Mappings were made.
* X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or
imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans
etc however, please provide the reports of such studies initially so a determination can be made regarding
which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your
care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to
whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of
how old, including anything that might be on microfilm/miexo-fiche or kept at another location.
TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND
EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document
or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify
the person, pursuant to whose instructions the documents or things were not produced, by name, address, and
employer. 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 attommey 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 attomey whose name appears on ihis 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 to appear by the following attorney, and unless excused from this
subpoena by this attorney or the court, you shall respond to this subpoena as directed.
Dated 00
Wicker, Smith, Tutan, O'Hara,
McCoy, Graham & Ford, P.A.
Attomeys for the Defendant, Nasir Khalidi, M.D.
Post Office Box 2152, Tampa. Florida 33601-2152
100 North Tampa Street Suite 3650
Tampa, Florida 33602
Tel: 813-222-3939
813-222-393:
By, ‘) ut
Joho C. Hamilton, Esquire
Florida Bar No. 223743
In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to parti te in this
proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A.. Suite 3650,
Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding.
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
SALLY SIMON, as Personal
Representative of the Estate of
Michael Simon,
Plaintiff, Case No. 00-120 CA
vs.
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
WANZY, M_D., P.A., a Florida Corporation,
BALA K. NANDIGAM, M.D., CHARLOTTE
MEDICAL ASSOCIATES, P.A., a Florida
Corporation, MOIDEN MOOPEN, M_LD., “
MOIDEN MOOPEN, M.D., P.A., a
Florida Corporation, CARLOS E. MAAS,
M.D., CARLOS MAAS, M.D., P.A.,a
Florida Corporation, NASIR KHALIDI, M.D.,
NASIR KHALIDI, M.D., & SAKINA
KHALIDI, M.D., P.A., a Florida Corporation,
ST. JOSEPH’S EMERGENCY MEDICAL
PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M.D., CHRIS
MICKELSON, M_D.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT
OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers
TO: Records Custodian of:
Healthsouth of Sarasota
3251 Proctor Road
Sarasota, FL 34231
YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford,
P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to
have with you at that time and place the records pertaining to the following person or persons:
Name : Michael Simon
Date of Birth : a 1942
SSN
Copies of any and all records from the date of commencement of such records to the present, regardless of
the date thereof pertaining to the above-identified person, including, but not limited to:
* Reports * Correspondence
* Orders ™ Patient History Questionnaires
* Summaries * Handwritten and typewritten notes
* Charts * Memoranda.
* Consultation Reports * Counseling records/reports
* Test results * Hospital admission records
* Emergency Room records * Out-Patient records
* Flight Transport records * Prescriptions
* Radiation Therapy records * Rehabilitation records
* Lab tests/reports * Pathology reports
* Medication records * Statements and bills
* Disability statements * Psychological records
* Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.)
* Videotapes
* EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the
machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age
range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the
Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was
used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the
exact parts from which the Brain Mappings were made.
* X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and ail other radiological or
imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans
etc however, please provide the reports of such studies initially so a determination can be made regarding
which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your
care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to
whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of
how old, including anything that might be on microfilm/micro-fiche or kept at another location.
TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND
EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document
or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify
the person, pursuant to whose instructions the documents or things were not produced, by name, address, and
employer. 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 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 to appear by the following attorney, and unless excused from this
subpoena by this attorney or the court, you shall respond to this subpoena as directed.
Dated 00
Wicker, Smith, Tutan, O'Hara,
McCoy, Graham & Ford, P.A.
Attomeys for the Defendant, Nasir Khalidi, M.D.
Post Office Box 2152, Tampa, Florida 33601-2152
100 North Tampa Street Suite 3650
Tampa, Florida 33602
Tel: 813-222-3939
Fax: 813-223-393:
By, (
John C. Hamilton, Esquire
fy
Florida Bar No. 223743
In accordance with the Americans with Disabilities Act, persons with disabilities needing speciat accommodation to participate in this
proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650,
Tampa, Florida, 33602, (813) 222-3939, not tater than seven days prior to the proceeding.
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
SALLY SIMON, as Personal
Representative of the Estate of
Michael Simon,
Plaintiff, Case No. 00-120 CA
vs.
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
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_LD., P.A., a
Florida Corporation, CARLOS E. MAAS,
M.D., CARLOS MAAS, M.D., P.A., a
Florida Corporation, NASIR KHALIDI, M.D.,
NASIR KHALIDI, M.D., & SAKINA
KHALIDI, M.D., P.A., a Florida Corporation,
ST. JOSEPH’S EMERGENCY MEDICAL
PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M.D., CHRIS
MICKELSON, M_D.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT
OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers
TO: Records Custodian of:
Murdock Family Medicine
1649 Tamiami Trial
Murdock, FL 33948
YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford,
P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to
have with you at that time and place the records pertaining to the following person or persons:
Name : Michael Simon
Date of Birth : May 25, 1942
SSN
Copies of any and all records from the date of commencement of such records to the present, regardless of
the date thereof pertaining to the a
Preview
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Plaintiff, Case No. 00-120 CA vs. ah oe oe MARK ASPERILLA, M.D., eg. MARK ASPERILLA, M.D., P.A., co ee a Florida Corporation, DALE 2% \\ os GREENBERG, M.D., RONALD om CONSTINE, M.D., LEVY BAKER, ae CONSTINE & GREENBERG, M.D. P.A., a Florida Corporation, SAMUEL ESTEPA, M.D., PRIMARY CARE & i oe 7 PHYSICIANS, INC., a Florida Corporation, THOMAS K, WANZY, M.D., THOMAS 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., mT MOIDEN MOOPEN, M.D., P.A., a xTtO oy Florida Corporation, CARLOS E. MAAS, oj M.D., CARLOS MAAS, M_D., P.A., a Florida Corporation, NASIR KHALIDI, M.D., NASIR KHALIDI, M.D., & SAKINA KHALIDI, M.D., P.A., a Florida Corporation, ST. JOSEPH’S EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M.D., CHRIS MICKELSON, M_D., Defendants, / NOTICE OF PRODUCTION FROM NON-PARTY YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this notice, if service is by delivery, or 15 days from the date of service, if service is by mail, and if no objection is received from any party, the undersigned will issue or apply to the clerk of this court for issuance of the attached subpoenas directed to the records custodians of : Bon Secours St. Joseph's Hospital Jose I. Cabrera, M.D. Charlotte Chiropractic Clinic Charlotte Co. Emergency Medical Serivces les oe Fawcett Memorial Hospital Healthsouth of Sarasota Murdock Family Medicine O. Sambandam, M_D., P.A., F.A.C.C., F.A.C.P. Sarasota Memorial Hospital Sarasota Plastic Surgery Vascular Associates of Sarasota The above listed are not parties to this lawsuit and are requested to produce the items listed at the time and place specified in the attached subpoenas. If you wish to receive copies of these documents, please advise the undersigned, in writing, and the same will be provided, at a cost for photocopies, upon receipt. CERTIFICATE OF SERVICE Le THEREBY TIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail on this “Alay of February, 2000, to: Thomas A. Culmo, Esquire Grove Professional Building 2950 S.W. 27th Ave. Suite 100 Miami, FL 33133 Dennis A. Koltun, Esquire 7101 S.W. 102nd Ave. Miami, FL 33173 Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A. Attorneys for the Defendant, Dr. Khalidi Post Office Box 2152, Tampa, FL 33601-2152 100 North Tampa Street, Suite 3650 Tampa, Florida 33602 = Fax: 813-222-3938 ohn C. Hamilton, Esqrfire LA eer tenneen en IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Plaintiff, Case No. 00-120 CA vs. 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 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, MLD., P.A., a Florida Corporation, CARLOS E. MAAS, M.D., CARLOS MAAS, M_D., P.A., a Florida Corporation, NASIR KHALIDI, M.D., NASIR KHALIDI, M.D., & SAKINA KHALIDI, M_.D., P.A., a Florida Corporation, ST. JOSEPH’S EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M.D., CHRIS MICKELSON, M.D., Defendants. SUBPOENA DUCES TECUM WITHOUT DEPOSITION NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers TO: Records Custodian of: Bon Secours St. Joseph's Hospital 2500 Harbor Blvd. Port Charlotte, FL. 33952-5396 YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to have with you at that time and place the records pertaining to the following person or persons: Name : Michael Simon Date of Birth : May 25, 1942 SSN Copies of any and all records from the date of commencement of such records to the present, regardless of the date thereof pertaining to the above-identified person, including, but not limited to: * Reports * Correspondence * Orders * Patient History Questionnaires _ * Summaries * Handwritten and typewritten notes * Charts * Memoranda * Consultation Reports * Counseling records/reports * Test results * Hospital admission records * Emergency Room records * Out-Patient records * Flight Transport records * Prescriptions * Radiation Therapy records * Rehabilitation records * Lab tests/reports * Pathology reports * Medication records * Statements and bills * Disability statements * Psychological records * Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.) * Videotapes * EEG and Brain Mapping Studies- inchiding: 1) The exact name, model number, and manufacturer of the machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the exact parts from which the Brain Mappings were made. * X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans etc however, please provide the reports of such studies initially so a determination can be made regarding which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of how old, including anything that might be on microfilm/micro-fiche or kept at another location. TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify the person, pursuant to whose instructions the documents or things were not produced, by name, address, and employer. 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 ime and place specified above. You have tie cight te object to the production pursuant to this Subpoena at any time before production by giving written notice to the attomey 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. Dated POO Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A. Attomeys for the Defendant, Nasir Khatidt, M.D. Post Office Box 2152, Tampa, Florida 33601-2152 100 North Tampa Street S 1650 Tampa, Fl 813-222-3939 aX: 813-222-393: By. Hamilton, Esquire: Floy Bar No. 223743 In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to participate in this proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650, ‘Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding. IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Plaintiff, Case No. 00-120 CA vs, 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 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_LD., P.A., a Florida Corporation, CARLOS E. MAAS, M.D., CARLOS MAAS, M_D., P.A., a Florida Corporation, NASIR KHALIDI, M.D., NASIR KHALIDI, M.D., & SAKINA KHALIDI, M_D., P.A., a Florida Corporation, ST. JOSEPH’S EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M.D., CHRIS MICKELSON, M.D., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers TO: Records Custodian of: Jose {. Cabrera, M.D. 2525 Harber Blvd. Suite 303 Port Charlotte, FL 33952 YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to have with you at that time and place the records pertaining to the following person or persons: Name : Michael Simon Date of Birth : May 25, 1942 SSN Copies of any and all records from the date of commencement of such records to the present, regardless of the date thereof pertaining to the above-identified person, including, but not limited to: * Reports * Correspondence * Orders * Patient History Questionnaires * Summaries * Handwritten and typewritten notes * Charts * Memoranda * Consultation Reports * Counseling records/reports * Test results * Hospital admission records * Emergency Room records * Out-Patient records * Flight Transport records * Prescriptions * Radiation Therapy records * Rehabilitation records * Lab tests/reports * Pathology reports * Medication records * Statements and bills * Disability statements * Psychological records * Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.) * Videotapes * EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the exact parts from which the Brain Mappings were made. * X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans ete however, please provide the reports of such studies initially so a determination can be made regarding which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of how old, including anything that might be on microfilm/micro-fiche or kept at another location. TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify the person, pursuant to whose instructions the documents or things were not produced, by name, address, and employer. 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 attomey 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. 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. Dated 00 Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A. Attorneys for the Defendant, Nasir Khalidi, M.D. Post Office Box 2152, Tampa, Florida 33601-2152 100 North Tampa Street Suite 3650 Tampa, Florida 33602 Tel: 813-222-3939 Fax: pl 222-3938 By, JohnC. Hantilton, Esqu Florida Bar No. 223743 In accordance with the Americans with Disabilitles Act, persons with disabilities needing special accommodation to participate in this proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650, Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding. IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Plaintiff, Case No. 00-120 CA vs. MARK ASPERILLA, MLD. , 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 WANZY, M_LD., P.A., a Florida Corporation, BALA K. NANDIGAM, M.D., CHARLOTTE MEDICAL ASSOCIATES, P.A., a Florida Corporation, MO[DEN MOOPEN, M.D., te MOIDEN MOOPEN, M.D., P.A., 2 Florida Corporation, CARLOS E. MAAS, M.D., CARLOS MAAS, M_D., P.A.,a Florida Corporation, NASIR KHALIDI, M.D., NASIR KHALIDI, M.D., & SAKINA KHALIDI, M_D., P.A., a Florida Corporation, ST. JOSEPH’S EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M.D., CHRIS MICKELSON, M_D., Defendants. i SUBPOENA DUCES TECUM WITHOUT DEPOSITION. NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers TO: Records Custodian of: Charlotte Chiropractic Clinic 4065 Tamiami Trail Port Charlotte, FL 33952 YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to have with you at that time and place the records pertaining to the following person or persons: Name : Michael Simon Date of Birth : May 25, 1942 SSN Copies of any and all records from the date of commencement of such records to the present, regardless of the date thereof pertaining to the above-identified person, including, but not limited to: * Reports * Correspondence * Orders * Patient History Questionnaires * Summaries * Handwritten and typewritten notes * Charts * Memoranda * Consultation Reports * Counseling records/reports * Test results * Hospital admission records * Emergency Room records * Out-Patient records * Flight Transport records * Prescriptions * Radiation Therapy records * Rehabilitation records * Lab tests/reports * Pathology reports * Medication records * Statements and bills * Disability statements * Psychological records * Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.) * Videotapes * EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the exact parts from which the Brain Mappings were made. * X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans etc however, please provide the reports of such studies initially so a determination can be made regarding which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of how old, including anything that might be on microfilm/micro-fiche or kept at another location. TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify the person, pursuant to whose instructions the documents or things were not produced, by name, address, and employer. 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 attomey 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 attormey 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 to appear by the following attomey, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. Dated 00 Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A. Attomeys for the Defendant, Nasir Khalidi, M.D. Post Office Box 2152, Tampa, Florida 33601-2152 100 North Tampa Street Suite 3650 Tampa, Florida 33602 Tel: 813-222-3939 Fax: AS bi, By John C. Hamilton, Esquire Florida Bar No. 223743 In accordance with the Amertcans with Disabilities Act, persons with disabilities needing special accommodation to participate in this proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650, Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding. IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Plaintiff, Case No. 00-120 CA vs. MARK ASPERILLA, MLD. , 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 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., we MOIDEN MOOPEN, M._D., P.A., a Florida Corporation, CARLOS E. MAAS, M.D., CARLOS MAAS, M.D., P.A., a Florida Corporation, NASIR KHALIDI, M.D., NASIR KHALIDI, M.D., & SAKINA KHALIDI, M_D., P.A., a Florida Corporation, ST. JOSEPH’S EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M_D., CHRIS MICKELSON, M.D., Defendants. / SUBPOENA DUCES TECUM. OUT DEPOSITION NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers TO: Records Custodian of: Charlotte Co. Emergency Medical Services 22429 Edgewater Dr. Punta Gorda, FL 33980 YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A,, 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to have with you at that time and place the records pertaining to the following person or persons: Name : Michael Simon Date of Birth : May 25, 1942 SSN Copies of any and ail records from the date of commencement of such records to the present, regardless of the date thereof pertaining to the above-identified person, including, but not limited to: * Reports * Correspondence * Orders * Patient History Questionnaires * Summaries * Handwritten and typewritten notes * Charts * Memoranda * Consultation Reports * Counseling records/reports * Test results * Hospital admission records * Emergency Room records * Out-Patient records * Flight Transport records * Prescriptions * Radiation Therapy records * Rehabilitation records * Lab tests/reports * Pathology reports * Medication records * Statements and bills * Disability statements * Psychological records * Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.) * Videotapes * EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age tange, and behavioral state for the alleged normal values the above-referenced patient was compared to during the Brain Mappings & EEG's; 3) All replications of ail Brain Mappings and Evoked Potentials in color (if color was used); 4) Copies of all actual original EEG’s from which the Brain Mappings were made with indications of the exact parts from which the Brain Mappings were made. * X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans etc however, please provide the reports of such studies initially so a determination can be made regarding which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to whom this subpoena is directed, be produced. This subpoeya encompasses all documents and things, regardless of how old, including anything that might be on microfilm/miero-fiche or kept at another location. TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify the person, pursuant to whose instructions the documents or things were not produced, by name, address, and employer. 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 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. Dated 00 Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A. Attorneys for the Defendant, Nasir Khalidi, M.D. Post Office Box 2152, Tampa, Florida 33601-2152 100 North Tampa Street Suite 3650 ‘Tampa, Florida 33602 Tel 813-222-3039 Fax: 39: By. he of ye John C. familton, Esquire Florida Bar No. 223743 In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to participate in this proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650, Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding. IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA. SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Plaintiff, Case No. 00-120 CA vs. 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 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., 2 Florida Corporation, CARLOS E. MAAS, M.D., CARLOS MAAS, M.D., P.A., a Florida Corporation, NASIR KHALIDI, M_D., NASIR KHALIDI, M.D., & SAKINA KHALIDI, M.D., P.A., a Florida Corporation, ST. JOSEPH’S EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M_D., CHRIS MICKELSON, M.D., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers TO: Records Custodian of: Fawcett Memorial Hospital 20298 Olean Boulevard Port Charlotte, FL 33952 YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A,, 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to have with you at that time and place the records pertaining to the following person or persons: Name : Michael Simon Date of Birth SSN Copies of any and all records from the date of commencement of such records to the present, regardless of the date thereof pertaining to the above-identified person, including, but not limited to: * Reports “ Correspondence * Orders * Patient History Questionnaires * Summaries * Handwritten and typewritten notes * Charts * Memoranda * Consultation Reports * Counseling records/reports * Test results * Hospital admission records * Emergency Room records * Out-Patient records * Flight Transport records * Prescriptions * Radiation Therapy records * Rehabilitation records * Lab tests/reports * Pathology reports * Medication records * Statements and bills * Disability statements * Psychological records * Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.) * Videotapes * EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the exact parts from which the Brain Mappings were made. * X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and all other radiological or imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans etc however, please provide the reports of such studies initially so a determination can be made regarding which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of how old, including anything that might be on microfilm/miexo-fiche or kept at another location. TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify the person, pursuant to whose instructions the documents or things were not produced, by name, address, and employer. 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 attommey 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 attomey whose name appears on ihis 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. Dated 00 Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A. Attomeys for the Defendant, Nasir Khalidi, M.D. Post Office Box 2152, Tampa. Florida 33601-2152 100 North Tampa Street Suite 3650 Tampa, Florida 33602 Tel: 813-222-3939 813-222-393: By, ‘) ut Joho C. Hamilton, Esquire Florida Bar No. 223743 In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to parti te in this proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A.. Suite 3650, Tampa, Florida, 33602, (813) 222-3939, not later than seven days prior to the proceeding. IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Plaintiff, Case No. 00-120 CA vs. 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 WANZY, M_D., P.A., a Florida Corporation, BALA K. NANDIGAM, M.D., CHARLOTTE MEDICAL ASSOCIATES, P.A., a Florida Corporation, MOIDEN MOOPEN, M_LD., “ MOIDEN MOOPEN, M.D., P.A., a Florida Corporation, CARLOS E. MAAS, M.D., CARLOS MAAS, M.D., P.A.,a Florida Corporation, NASIR KHALIDI, M.D., NASIR KHALIDI, M.D., & SAKINA KHALIDI, M.D., P.A., a Florida Corporation, ST. JOSEPH’S EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M.D., CHRIS MICKELSON, M_D., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers TO: Records Custodian of: Healthsouth of Sarasota 3251 Proctor Road Sarasota, FL 34231 YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to have with you at that time and place the records pertaining to the following person or persons: Name : Michael Simon Date of Birth : a 1942 SSN Copies of any and all records from the date of commencement of such records to the present, regardless of the date thereof pertaining to the above-identified person, including, but not limited to: * Reports * Correspondence * Orders ™ Patient History Questionnaires * Summaries * Handwritten and typewritten notes * Charts * Memoranda. * Consultation Reports * Counseling records/reports * Test results * Hospital admission records * Emergency Room records * Out-Patient records * Flight Transport records * Prescriptions * Radiation Therapy records * Rehabilitation records * Lab tests/reports * Pathology reports * Medication records * Statements and bills * Disability statements * Psychological records * Records from other health care providers * Therapy records (P.T., O.T., Speech, etc.) * Videotapes * EEG and Brain Mapping Studies- including: 1) The exact name, model number, and manufacturer of the machine used for the Brain Mappings and EEG's; 2) The exact normal values including all relevant statistics, age range, and behavioral state for the alleged normal values the above-referenced patient was compared to during the Brain Mappings & EEG's; 3) All replications of all Brain Mappings and Evoked Potentials in color (if color was used); 4) Copies of all actual original EEG's from which the Brain Mappings were made with indications of the exact parts from which the Brain Mappings were made. * X-rays, MRIs, CT scans, Angiograms, Echocardiograms, Doppler studies, and ail other radiological or imaging studies. This request includes a request for QUALITY COPIES OF ALL X-RAYS, MRIs, CT scans etc however, please provide the reports of such studies initially so a determination can be made regarding which studies need to be copied. It is the intent of this subpoena that each and every document and thing in your care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to whom this subpoena is directed, be produced. This subpoena encompasses all documents and things, regardless of how old, including anything that might be on microfilm/micro-fiche or kept at another location. TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE COPIES OF EACH AND EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILE. If any document or thing is not produced, you are to identify that document or thing by date, title, author, and recipient; and identify the person, pursuant to whose instructions the documents or things were not produced, by name, address, and employer. 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 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 to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. Dated 00 Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A. Attomeys for the Defendant, Nasir Khalidi, M.D. Post Office Box 2152, Tampa, Florida 33601-2152 100 North Tampa Street Suite 3650 Tampa, Florida 33602 Tel: 813-222-3939 Fax: 813-223-393: By, ( John C. Hamilton, Esquire fy Florida Bar No. 223743 In accordance with the Americans with Disabilities Act, persons with disabilities needing speciat accommodation to participate in this proceeding should contact the above named attorney of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., Suite 3650, Tampa, Florida, 33602, (813) 222-3939, not tater than seven days prior to the proceeding. IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Plaintiff, Case No. 00-120 CA vs. 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 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_LD., P.A., a Florida Corporation, CARLOS E. MAAS, M.D., CARLOS MAAS, M.D., P.A., a Florida Corporation, NASIR KHALIDI, M.D., NASIR KHALIDI, M.D., & SAKINA KHALIDI, M.D., P.A., a Florida Corporation, ST. JOSEPH’S EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M.D., CHRIS MICKELSON, M_D., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION NOTE: IF THE COST OF THE RECORDS ARE MORE THAN $100.00 PLEASE CONTACT OUR OFFICE AT 813-222-3939 and ask for Diana W. Sowers TO: Records Custodian of: Murdock Family Medicine 1649 Tamiami Trial Murdock, FL 33948 YOU ARE COMMANDED to appear at the office of Wicker, Smith, Tutan, O'Hara, McCoy, Graham & Ford, P.A., 100 North Tampa Street, Suite 3650, Tampa, Florida 33602, Friday, March 24, 2000, at 10:00 a.m. and to have with you at that time and place the records pertaining to the following person or persons: Name : Michael Simon Date of Birth : May 25, 1942 SSN Copies of any and all records from the date of commencement of such records to the present, regardless of the date thereof pertaining to the a