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Filing # 132948813 E-Filed 08/18/2021 03:28:03 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
XIAO SHENG YUE,
Plaintiff,
CASE NO.: 2020-CA-1106AN
v.
CYNTHIA M. FOERSTER AND
CHAPP, INC.,
Defendants.
eee
NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the Defendants, CYNTHIA M. FOERSTER and CHAPP,
INC., by and through the undersigned counsel, will take the video deposition set forth below:
DEPONENT DATE/TIME LOCATION
Marc I. Sharfman, M.D. Thursday, October 14, 2021 Via Zoom By U.S.
3:00 p.m. Legal Support ZOOM
(details to be provided
at least 24-hours prior
to the deposition)
The deponent shall produce all documents set forth in the attached Exhibit “A” at the time
of the deposition. This deposition will be conducted upon oral examination before U.S. Legal
Support, Court Reporter, and a Notary Public in and for the State of Florida at Large, or some other
officer duly authorized by law to take depositions. The deposition is being taken for the purpose
of discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted
under the applicable and governing rules.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that, on this 18th day of August, 2021, I electronically filed the
foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in
compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service
by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record.
LAW OFFICES OF SANTEIRO & GARRISON
/s/ Jorge Santeiro, Jr.
Jorge Santeiro, Jr.
FBN 66230
6300 University Parkway
Suite 101
Sarasota, FL 34240
Tel: (800) 226-3224 Ext. 1021
Primary: _jsanteiro@fcci-group.com
Secondary: ssmithS@fcci-group.com
Secondary: legalservice@fcci-group.com
Attorney for Defendants
EXHIBIT A
(Items to Produce)
YOUR COMPLETE FILE RE: XIAO SHENG YUE, DOB: XX-XX-XXXX
SOCIAL SECURITY NUMBER: XXX-XX-XXXKX
1. PLEASE PROVIDE YOUR CURRENT PROFESSIONAL RESUME AND/OR
CURRICULUM VITAE (C.V.)
2. ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT, FORM OR
METHOD, INCLUDING, BUT NOT LIMITED TO, ALL OFFICE, EMERGENCY
ROOM, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN
FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB
REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL
THERAPY RECORDS, INCLUDING SIGN-IN SHEETS, ALL DESCRIPTIONS OF
EXERCISES PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE
AND TIME OF PATIENT'S APPOINTMENTS, AND INSURANCE DOCUMENTS;
3. ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES
PRIVATE OR Page 2 of 3 GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF
BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S
RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY,
RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS
INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY
BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED
BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION;
4. COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY
OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS,
CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED.
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
XIAO SHENG YUE,
Plaintiff,
CASE NO.: 2020-CA-1106AN
v.
CYNTHIA M. FOERSTER AND
CHAPP, INC.,
Defendants.
ee
DEFENDANT’S SUBPOENA FOR TAKING VIDEO DEPOSITION
DUCES TECUM OF MARC I. SHARFMAN, M.D.
TO: Marc I. Sharfman, M.D.
2137 West State Road 434
Longwood, FL 32779
(407) 644-3737
YOU ARE COMMANDED to appear before a person authorized by law on Thursday,
October 14, 2021, at 3:00 p.m., via ZOOM (details to be provided at least 24-hours prior to the
deposition), for the taking of your deposition in this Case, and to produce at your deposition the
documents described in Exhibit A attached hereto. You are subpoenaed to appear by Jorge
Santeiro, Esq., and unless otherwise excused from this Subpoena by said attorney or the Court,
you shall respond to this Subpoena as directed. If you fail to appear, you may be held in contempt
of court. The deposition will be recorded by US Legal Support.
Dated: August , 2021
/s/ Jorge Santeiro
Jorge Santeiro
For the Court
Jorge Santeiro
Florida Bar Number 66230
6300 University Parkway
Suite 101
Sarasota, FL 34240
Tel: (800) 226-3224 Ext. 1021
Primary: jsanteiro@fcci-group.com
Counsel for Defendants
EXHIBIT A
(Items to Produce)
YOUR COMPLETE FILE RE: XIAO SHENG YUE, DOB: XX-XX-XXXX
SOCIAL SECURITY NUMBER: XXX-XX-XXXKX
1. PLEASE PROVIDE YOUR CURRENT PROFESSIONAL RESUME AND/OR
CURRICULUM VITAE (C.V.)
2. ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT, FORM OR
METHOD, INCLUDING, BUT NOT LIMITED TO, ALL OFFICE, EMERGENCY
ROOM, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN
FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB
REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL
THERAPY RECORDS, INCLUDING SIGN-IN SHEETS, ALL DESCRIPTIONS OF
EXERCISES PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE
AND TIME OF PATIENT'S APPOINTMENTS, AND INSURANCE DOCUMENTS;
3. ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES
PRIVATE OR Page 2 of 3 GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF
BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S
RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY,
RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS
INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY
BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED
BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT
SOFTWARE THAT CONTAINS SAID INFORMATION;
4. COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY
OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A
COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS,
CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED.
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Filing # 132948813 E-Filed 08/18/2021 03:28:03 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE, Plaintiff, CASE NO.: 2020-CA-1106AN v. CYNTHIA M. FOERSTER AND CHAPP, INC., Defendants. eee NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., by and through the undersigned counsel, will take the video deposition set forth below: DEPONENT DATE/TIME LOCATION Marc I. Sharfman, M.D. Thursday, October 14, 2021 Via Zoom By U.S. 3:00 p.m. Legal Support ZOOM (details to be provided at least 24-hours prior to the deposition) The deponent shall produce all documents set forth in the attached Exhibit “A” at the time of the deposition. This deposition will be conducted upon oral examination before U.S. Legal Support, Court Reporter, and a Notary Public in and for the State of Florida at Large, or some other officer duly authorized by law to take depositions. The deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules. CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on this 18th day of August, 2021, I electronically filed the foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record. LAW OFFICES OF SANTEIRO & GARRISON /s/ Jorge Santeiro, Jr. Jorge Santeiro, Jr. FBN 66230 6300 University Parkway Suite 101 Sarasota, FL 34240 Tel: (800) 226-3224 Ext. 1021 Primary: _jsanteiro@fcci-group.com Secondary: ssmithS@fcci-group.com Secondary: legalservice@fcci-group.com Attorney for Defendants EXHIBIT A (Items to Produce) YOUR COMPLETE FILE RE: XIAO SHENG YUE, DOB: XX-XX-XXXX SOCIAL SECURITY NUMBER: XXX-XX-XXXKX 1. PLEASE PROVIDE YOUR CURRENT PROFESSIONAL RESUME AND/OR CURRICULUM VITAE (C.V.) 2. ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT, FORM OR METHOD, INCLUDING, BUT NOT LIMITED TO, ALL OFFICE, EMERGENCY ROOM, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, INCLUDING SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS, AND INSURANCE DOCUMENTS; 3. ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR Page 2 of 3 GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; 4. COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED. IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE, Plaintiff, CASE NO.: 2020-CA-1106AN v. CYNTHIA M. FOERSTER AND CHAPP, INC., Defendants. ee DEFENDANT’S SUBPOENA FOR TAKING VIDEO DEPOSITION DUCES TECUM OF MARC I. SHARFMAN, M.D. TO: Marc I. Sharfman, M.D. 2137 West State Road 434 Longwood, FL 32779 (407) 644-3737 YOU ARE COMMANDED to appear before a person authorized by law on Thursday, October 14, 2021, at 3:00 p.m., via ZOOM (details to be provided at least 24-hours prior to the deposition), for the taking of your deposition in this Case, and to produce at your deposition the documents described in Exhibit A attached hereto. You are subpoenaed to appear by Jorge Santeiro, Esq., and unless otherwise excused from this Subpoena by said attorney or the Court, you shall respond to this Subpoena as directed. If you fail to appear, you may be held in contempt of court. The deposition will be recorded by US Legal Support. Dated: August , 2021 /s/ Jorge Santeiro Jorge Santeiro For the Court Jorge Santeiro Florida Bar Number 66230 6300 University Parkway Suite 101 Sarasota, FL 34240 Tel: (800) 226-3224 Ext. 1021 Primary: jsanteiro@fcci-group.com Counsel for Defendants EXHIBIT A (Items to Produce) YOUR COMPLETE FILE RE: XIAO SHENG YUE, DOB: XX-XX-XXXX SOCIAL SECURITY NUMBER: XXX-XX-XXXKX 1. PLEASE PROVIDE YOUR CURRENT PROFESSIONAL RESUME AND/OR CURRICULUM VITAE (C.V.) 2. ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT, FORM OR METHOD, INCLUDING, BUT NOT LIMITED TO, ALL OFFICE, EMERGENCY ROOM, INPATIENT AND OUTPATIENT CHARTS AND RECORDS, LIEN FILES, SOAP NOTES, PATHOLOGY RECORDS AND REPORTS, LAB REPORTS, PHARMACY AND PRESCRIPTION RECORDS, PHYSICAL THERAPY RECORDS, INCLUDING SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED AND DOCUMENTATION WHICH INDICATE DATE AND TIME OF PATIENT'S APPOINTMENTS, AND INSURANCE DOCUMENTS; 3. ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR Page 2 of 3 GOVERNMENTAL; ANY AMOUNTS WRITTEN OFF BY THE PROVIDER, AND ANY AMOUNTS THAT ARE THE PATIENT'S RESPONSIBILITY AND EXPLANATION OF BENEFITS, PAYMENT HISTORY, RECORDS OF ANY LIENS, ANY INSURANCE BILLING OR PAYMENTS INFORMATION, EMERGENCY ROOM PHYSICIANS BILLS AND RADIOLOGY BILLING FROM ALL SOURCES, TO INCLUDE ANY COMPUTER GENERATED BILLING OR BILLING STORED IN ANY FORMAT AND PAYMENT SOFTWARE THAT CONTAINS SAID INFORMATION; 4. COPIES OF ALL ORIGINAL X-RAYS FILMS, CT SCANS, MRIS AND ANY OTHER SCANS OR IMAGES TAKEN AND/OR MAINTAINED, INCLUDING A COMPREHENSIVE LIST OF ALL DATES AND BODY PARTS OF ALL FILMS, CT SCANS, MRIS AND ALL OTHER IMAGES OR SCANS PROVIDED.