Preview
Filing # 161895232 E-Filed 11/28/2022 12:03:06 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-1106AN
Plaintiff(s),
vs.
CYNTHIA M. FOERSTER AND CYNTHIA M.
FOERSTER AND CHAPP, INC.
Defendant(s),
DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS
FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
Notice, service is by email, and if no objection is received from any party, the undersigned will
issue or apply to the Clerk of this court for the issuance of the attached Subpoena(s) directed to
the following:
Insurance Records Custodian for
SEDGWICK CLAIMS MANAGEMENT SERVICES C/O REGISTERED AGENT,
CORPORATION SERVICE COMPANY
1201 HAYS STREET
TALLAHASSEE, FL 32301
The above listed are not a party to this lawsuit and are requested to produce the items listed at
the time and place specified in the attached Subpoena(s).
If you wish to receive copies of these documents, please advise the undersigned, in writing,
and same will be provided, at a cost for photocopies, upon receipt.
IF COPY CHARGES EXCEED $200.00 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES
INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES.
PLEASE BE GOVERNED ACCORDINGLY.
Page 1 of 2
I HEREBY CERTIFY that on the WK day RI1RYHPEHU a true and correct copy
of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been
furnished by email to:
MANUEL STEFAN, ESQ.
MORGAN & MORGAN, P.A.
4495 SOUTH SEMORAN BOULEVARD
ORLANDO, FL 32807
MSTEFAN@FORTHEPEOPLE.COM
LAW OFFICES OF SANTEIRO & GARRISON
6300 UNIVERSITY PARKWAY, SUITE 101
SARASOTA, FL 34240-8424
Telephone: 800-226-3224, Ext. 1021
Fax:
By: /S/ Jorge Santeiro, Esq.
JORGE SANTEIRO, ESQ.
FL BAR NO. 66230
PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS:
JSANTEIRO@FCCI-GROUP.COM
SSMITH5@FCCI-GROUP.COM
Attorney for Defendant(s)
CHAPP, INC.
Page 2 of 2
_I
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-l 106AN
Plamtiff(s),
vs.
CYNTHIA M. FOERSTER AND CYNTHIA M.
FOERSTER AND CHAPP, INC.
Defendant(s),
SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS
THE STATE OF FLORIDA:
TO: RECORDS CUSTODIAN FOR
SEDGWICK CLAIMS MANAGEMENT SERVICES C/O REGISTERED AGENT,
CORPORATION SERVICE COMPANY
1201 HAYS STREET
TALLAHASSEE, FL 32301
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Sendees, Inc, located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with
you at that time and place the following:
ANY AND ALL INSURANCE RECORDS STORED IN ANY FORMAT, INCLUDING BUT
NOT LIMITED TO CORRESPONDENCE, PAYMENTS, PAYMENT HISTORY, POLICY
INFORMATION, DECLARATIONS PAGE, COMPLETE CLAIM FILES, RECORDS OF
ANY LIENS, COLOR PHOTOS, AND DAMAGE REPAIR ESTIMATES, INJURY
RECORDS OR CLAIM AND ANY OTHER DOCUMENTS CONTAINED WITHIN ANY
INSURANCE FILE AND/OR CLAIM FILE.
ALL NON-PRIVILEGED CLAIM FILE RECORDS.
ADDRESS: 125 DOBSON RD.
#1087
CHANDLER, AZ 85224 XIAO SHENG YUE ; DOB: SSN:
Page 1 of 3
IF COPY CHARGES EXCEED $ 2 0 0 . 0 0 FOR THIS PATIENT, PLEASE CONTACT
COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE
CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING
COPIES.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible
copies of the items to be produced to COMPEX LEGAL SERVICES, INC., the agent of
the attorney whose name appears on this subpoena, on or before the scheduled date of
production. "The records requested will be used for this litigation only and will be
returned or destroyed after litigation is complete." Please contact Compex Legal Services,
Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for
compliance to:
COMPEX LEGAL SERVICES, INC.
5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634
Tel: 888-531-2919, Fax: 888-531-2922
You may condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. You have the right to object to the production pursuant to this subpoena at
any time before production by giving written notice to the attorney whose name appears on this
subpoena.
THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided
above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed by
the attorney whose name appears on this subpoena and unless excused from this subpoena by the
attorney or the Court, you shall respond to this subpoena as directed.
Page 2 of 3
CERTIFICATE OF NOTICE
Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45
CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and
requirements to obtain patient health information and that the representations below are true
and correct:
1. I have made a good faith attempt to provide written notice to the above-named patient,
through counsel, of intent to obtain the patient's health information pursuant to this
subpoena;
2. The written notice provided sufficient information about this litigation or proceeding in which
the protected health information is requested to permit the patient to raise an objection to
the court or administrative tribunal; and
3. The time of the patient to raise objections to the court or administrative tribunal has elapsed
and (check one)
No objections were filed; or
All objections filed by the patient were resolved by the court or administrative
tribunal and the disclosures being sought are consistent with such resolutions.
JORGE SANTEIRO, ESQ. Dated:
Attorney for Defendant(s)
FL Bar No. 66230
LAW OFFICES OF SANTEIRO & GARRISON
6300 UNIVERSITY PARKWAY, SUITE 101 By: Jorge Santeiro, Esq.
SARASOTA, FL 34240-8424 For the Court
Telephone: 800-226-3224, Ext. 1021
Page 3 of 3
Preview
Filing # 161895232 E-Filed 11/28/2022 12:03:06 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-1106AN Plaintiff(s), vs. CYNTHIA M. FOERSTER AND CYNTHIA M. FOERSTER AND CHAPP, INC. Defendant(s), DEFENDANT(S) NOTICE OF PRODUCTION OF DOCUMENTS FROM NON-PARTY YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this Notice, service is by email, and if no objection is received from any party, the undersigned will issue or apply to the Clerk of this court for the issuance of the attached Subpoena(s) directed to the following: Insurance Records Custodian for SEDGWICK CLAIMS MANAGEMENT SERVICES C/O REGISTERED AGENT, CORPORATION SERVICE COMPANY 1201 HAYS STREET TALLAHASSEE, FL 32301 The above listed are not a party to this lawsuit and are requested to produce the items listed at the time and place specified in the attached Subpoena(s). If you wish to receive copies of these documents, please advise the undersigned, in writing, and same will be provided, at a cost for photocopies, upon receipt. IF COPY CHARGES EXCEED $200.00 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. PLEASE BE GOVERNED ACCORDINGLY. Page 1 of 2 I HEREBY CERTIFY that on the WK day RI1RYHPEHU a true and correct copy of the foregoing Defendant(s) Notice of Production of Documents from Non Party has been furnished by email to: MANUEL STEFAN, ESQ. MORGAN & MORGAN, P.A. 4495 SOUTH SEMORAN BOULEVARD ORLANDO, FL 32807 MSTEFAN@FORTHEPEOPLE.COM LAW OFFICES OF SANTEIRO & GARRISON 6300 UNIVERSITY PARKWAY, SUITE 101 SARASOTA, FL 34240-8424 Telephone: 800-226-3224, Ext. 1021 Fax: By: /S/ Jorge Santeiro, Esq. JORGE SANTEIRO, ESQ. FL BAR NO. 66230 PRINCIPAL EMAIL FOR SERVICE OF PLEADINGS: JSANTEIRO@FCCI-GROUP.COM SSMITH5@FCCI-GROUP.COM Attorney for Defendant(s) CHAPP, INC. Page 2 of 2 _I IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-l 106AN Plamtiff(s), vs. CYNTHIA M. FOERSTER AND CYNTHIA M. FOERSTER AND CHAPP, INC. Defendant(s), SUBPOENA DUCES TECUM FOR PRODUCTION OF DOCUMENTS THE STATE OF FLORIDA: TO: RECORDS CUSTODIAN FOR SEDGWICK CLAIMS MANAGEMENT SERVICES C/O REGISTERED AGENT, CORPORATION SERVICE COMPANY 1201 HAYS STREET TALLAHASSEE, FL 32301 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Sendees, Inc, located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 888-531-2922, after ten (10) days from the date of service of this subpoena, and to have with you at that time and place the following: ANY AND ALL INSURANCE RECORDS STORED IN ANY FORMAT, INCLUDING BUT NOT LIMITED TO CORRESPONDENCE, PAYMENTS, PAYMENT HISTORY, POLICY INFORMATION, DECLARATIONS PAGE, COMPLETE CLAIM FILES, RECORDS OF ANY LIENS, COLOR PHOTOS, AND DAMAGE REPAIR ESTIMATES, INJURY RECORDS OR CLAIM AND ANY OTHER DOCUMENTS CONTAINED WITHIN ANY INSURANCE FILE AND/OR CLAIM FILE. ALL NON-PRIVILEGED CLAIM FILE RECORDS. ADDRESS: 125 DOBSON RD. #1087 CHANDLER, AZ 85224 XIAO SHENG YUE ; DOB: SSN: Page 1 of 3 IF COPY CHARGES EXCEED $ 2 0 0 . 0 0 FOR THIS PATIENT, PLEASE CONTACT COMPEX LEGAL SERVICES, INC. AT 888-531-2919 WITH A LIST OF THE CHARGES INVOLVED IN OBTAINING THESE RECORDS BEFORE CREATING COPIES. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to COMPEX LEGAL SERVICES, INC., the agent of the attorney whose name appears on this subpoena, on or before the scheduled date of production. "The records requested will be used for this litigation only and will be returned or destroyed after litigation is complete." Please contact Compex Legal Services, Inc. directly and send all Medical Records, Bills, Films, and all other items necessary for compliance to: COMPEX LEGAL SERVICES, INC. 5481 W. WATERS AVE. SUITE 108, TAMPA, FLORIDA, 33634 Tel: 888-531-2919, Fax: 888-531-2922 You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. Page 2 of 3 CERTIFICATE OF NOTICE Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Parts 160 and 164, I hereby certify that I have complied with the regulations and requirements to obtain patient health information and that the representations below are true and correct: 1. I have made a good faith attempt to provide written notice to the above-named patient, through counsel, of intent to obtain the patient's health information pursuant to this subpoena; 2. The written notice provided sufficient information about this litigation or proceeding in which the protected health information is requested to permit the patient to raise an objection to the court or administrative tribunal; and 3. The time of the patient to raise objections to the court or administrative tribunal has elapsed and (check one) No objections were filed; or All objections filed by the patient were resolved by the court or administrative tribunal and the disclosures being sought are consistent with such resolutions. JORGE SANTEIRO, ESQ. Dated: Attorney for Defendant(s) FL Bar No. 66230 LAW OFFICES OF SANTEIRO & GARRISON 6300 UNIVERSITY PARKWAY, SUITE 101 By: Jorge Santeiro, Esq. SARASOTA, FL 34240-8424 For the Court Telephone: 800-226-3224, Ext. 1021 Page 3 of 3