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Filing # 158910332 E-Filed 10/10/2022 03:02:24 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
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:
Medical Records Custodian for
HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC
700 WEST OAK STREET
KISSIMMEE, FL 34741
Billing Records Custodian for
HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC
700 WEST OAK STREET
KISSIMMEE, FL 34741
Radiology Records Custodian for
HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC
700 WEST OAK STREET
KISSIMMEE, FL 34741
Medical Records Custodian for
SHERIDAN RADIOLOGY SERVICES OF CENTRAL FLORIDA, INC. C/O
CORPORATION SERVICE COMPANY
1201 HAYS STREET
TALLAHASSEE, FL 32301
Page 1 of 4
Medical Records Custodian for
AKUMIN
4714 N ARMENIA AVE SUITE 103
TAMPA, FL 33603
Medical Records Custodian for
ORLANDO HEALTH NEUROPSYCHOLOGY DEPARTMENT
32 W. GORE STREET, 5TH FLOOR
ORLANDO, FL 32806
Medical Records Custodian for
HEADACHE AND NEUROLOGICAL TREATMENT INSTITUTE
2137 WEST STATE ROAD 434
LONGWOOD, FL 32779
Medical Records Custodian for
KISSIMMEE MEDICAL & WELLNESS CENTER
705 EAST OAK STREET, SUITE A
KISSIMMEE, FL 34744
Medical Records Custodian for
ORANGE COUNTY NEUROLOGY CLINIC, LLC
4359 HUNTERS PARK LANE
ORLANDO, FL 32837
Medical Records Custodian for
CENTRAL FLORIDA PRIMARY CARE - PCP
PO BOX 884
WINDERMERE, FL 34786
Medical Records Custodian for
POINCIANA MEDICAL CENTER
325 CYPRESS PARKWAY
KISSIMMEE, FL 34759
Radiology Records Custodian for
POINCIANA MEDICAL CENTER, FILMS
325 CYPRESS PARKWAY
KISSIMMEE, FL 34758
Billing Records Custodian for
POINCIANA MEDICAL CENTER, BILLING
325 CYPRESS PARKWAY
KISSIMMEE, FL 34759
Page 2 of 4
Medical Records Custodian for
ORTHOPAEDIC & SPINE ASSOCIATES
PO BOX 420759
KISSIMMEE, FL 34741
Medical Records Custodian for
EYE CARE SPECIALISTS OF FLORIDA, LLC
1124 CYPRESS GLEN CIRCLE
KISSIMMEE, FL 34741
Medical Records Custodian for
TARGET OPTICAL
4795 WEST IRLO BRUNSON MEMORIAL HIGHWAY
KISSIMMEE, FL 34746
Medical Records Custodian for
ADVANCED DIAGNOSTIC GROUP
4714 NORTH ARMENIA AVENUE, SUITE 103
TAMPA, FL 33603
Medical Records Custodian for
FAMILY PHYSICIANS GROUP
327 WEST OAK STREET
KISSIMMEE, FL 34741
Medical Records Custodian for
INTEGRATED REGIONAL LABORATORY PATHOLOGY SERVICES
P.O. BOX 741087
ATLANTA, GA 30374
Billing Records Custodian for
OSCEOLA REGIONAL MEDICAL CENTER>>>>5188504
335 CROSSING BOULEVARD
ORANGE PARK, FL 32073
Radiology Records and Reports Custodian for
SIMON MED IMAGING >>>>4083897
745 ORIENTA AVENUE SUITE 1161
ALTAMONTE SPRINGS, FL 32701
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.
Page 3 of 4
PLEASE BE GOVERNED ACCORDINGLY.
I HEREBY CERTIFY that on the WK day of 2FWREHU, 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 S SEMORAN BLVD
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 4 of 4
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
Plaintiff(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
HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC
700 WEST OAK STREET
KISSIMMEE, FL 34741
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
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:
***PROVIDE UPDATED RECORDS FROM 08/13/2021-PRESENT***
ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT 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, SIGN-IN SHEETS, ALL
DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH
,1',&$7('$7($1'7,0(2)3$7,(17¶6$332,170(176,1685$1&(
DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER
DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND
EXAMINATION OF THE PATIENT. XIAO SHENG YUE ALT DOB: ; 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
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
Plaintiff(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
HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC
700 WEST OAK STREET
KISSIMMEE, FL 34741
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
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:
***PROVIDE UPDATED RECORDS FROM 04/12/2021-PRESENT***
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
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. XIAO SHENG YUE ALT DOB:
; 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
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
Plaintiff(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
HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC
700 WEST OAK STREET
KISSIMMEE, FL 34741
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
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:
***PROVIDE UPDATED RECORDS FROM 11/29/2021-PRESENT***
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. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB:
; DOB: SSN:
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.
Page 1 of 3
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
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
Plaintiff(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
SHERIDAN RADIOLOGY SERVICES OF CENTRAL FLORIDA, INC. C/O
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 Services, 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:
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; AND
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
Page 1 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; AND
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. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE.
INCLUDING, BUT NOT LIMITED TO, ANY AND ALL RADIOLOGY REPORTS. XIAO
SHENG YUE ALT DOB: ; DOB: SSN:
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
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
Plaintiff(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
AKUMIN
4714 N ARMENIA AVE SUITE 103
TAMPA, FL 33603
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
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:
***PROVIDE UPDATED RECORDS FROM 04/23/2021-PRESENT***
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; AND
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
Page 1 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; AND
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. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB:
; DOB: SSN:
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
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
Plaintiff(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
ORLANDO HEALTH NEUROPSYCHOLOGY DEPARTMENT
32 W. GORE STREET, 5TH FLOOR
ORLANDO, FL 32806
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
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:
***PROVIDE UPDATED RECORDS FROM 03/16/2021-PRESENT***
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; AND
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
Page 1 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; AND
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. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB:
; DOB: SSN:
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
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
Plaintiff(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
HEADACHE AND NEUROLOGICAL TREATMENT INSTITUTE
2137 WEST STATE ROAD 434
LONGWOOD, FL 32779
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
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:
***PROVIDE UPDATED RECORDS FROM 04/05/2021-PRESENT***
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; AND
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
Page 1 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; AND
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. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB:
; DOB: SSN:
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
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
Plaintiff(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
KISSIMMEE MEDICAL & WELLNESS CENTER
705 EAST OAK STREET, SUITE A
KISSIMMEE, FL 34744
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
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:
***PROVIDE UPDATED RECORDS FROM 04/16/2021-PRESENT***
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; AND
ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR
CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND
PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL
HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR
Page 1 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; AND
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. ALL IMAGES AND
FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB:
; DOB: SSN:
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
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY,
FLORIDA
XIAO SHENG YUE
CASE NO. 2020-CA-001106
Plaintiff(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
ORANGE COUNTY NEUROLOGY CLINIC, LLC
4359 HUNTERS PARK LANE
ORLANDO, FL 32837
YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex
Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax:
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:
***PROVIDE UPDATED RECORDS FROM 04/06/2021-PRESENT***
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; AND
ALL ITEMIZED STATEMENTS
Preview
Filing # 158910332 E-Filed 10/10/2022 03:02:24 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 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: Medical Records Custodian for HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC 700 WEST OAK STREET KISSIMMEE, FL 34741 Billing Records Custodian for HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC 700 WEST OAK STREET KISSIMMEE, FL 34741 Radiology Records Custodian for HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC 700 WEST OAK STREET KISSIMMEE, FL 34741 Medical Records Custodian for SHERIDAN RADIOLOGY SERVICES OF CENTRAL FLORIDA, INC. C/O CORPORATION SERVICE COMPANY 1201 HAYS STREET TALLAHASSEE, FL 32301 Page 1 of 4 Medical Records Custodian for AKUMIN 4714 N ARMENIA AVE SUITE 103 TAMPA, FL 33603 Medical Records Custodian for ORLANDO HEALTH NEUROPSYCHOLOGY DEPARTMENT 32 W. GORE STREET, 5TH FLOOR ORLANDO, FL 32806 Medical Records Custodian for HEADACHE AND NEUROLOGICAL TREATMENT INSTITUTE 2137 WEST STATE ROAD 434 LONGWOOD, FL 32779 Medical Records Custodian for KISSIMMEE MEDICAL & WELLNESS CENTER 705 EAST OAK STREET, SUITE A KISSIMMEE, FL 34744 Medical Records Custodian for ORANGE COUNTY NEUROLOGY CLINIC, LLC 4359 HUNTERS PARK LANE ORLANDO, FL 32837 Medical Records Custodian for CENTRAL FLORIDA PRIMARY CARE - PCP PO BOX 884 WINDERMERE, FL 34786 Medical Records Custodian for POINCIANA MEDICAL CENTER 325 CYPRESS PARKWAY KISSIMMEE, FL 34759 Radiology Records Custodian for POINCIANA MEDICAL CENTER, FILMS 325 CYPRESS PARKWAY KISSIMMEE, FL 34758 Billing Records Custodian for POINCIANA MEDICAL CENTER, BILLING 325 CYPRESS PARKWAY KISSIMMEE, FL 34759 Page 2 of 4 Medical Records Custodian for ORTHOPAEDIC & SPINE ASSOCIATES PO BOX 420759 KISSIMMEE, FL 34741 Medical Records Custodian for EYE CARE SPECIALISTS OF FLORIDA, LLC 1124 CYPRESS GLEN CIRCLE KISSIMMEE, FL 34741 Medical Records Custodian for TARGET OPTICAL 4795 WEST IRLO BRUNSON MEMORIAL HIGHWAY KISSIMMEE, FL 34746 Medical Records Custodian for ADVANCED DIAGNOSTIC GROUP 4714 NORTH ARMENIA AVENUE, SUITE 103 TAMPA, FL 33603 Medical Records Custodian for FAMILY PHYSICIANS GROUP 327 WEST OAK STREET KISSIMMEE, FL 34741 Medical Records Custodian for INTEGRATED REGIONAL LABORATORY PATHOLOGY SERVICES P.O. BOX 741087 ATLANTA, GA 30374 Billing Records Custodian for OSCEOLA REGIONAL MEDICAL CENTER>>>>5188504 335 CROSSING BOULEVARD ORANGE PARK, FL 32073 Radiology Records and Reports Custodian for SIMON MED IMAGING >>>>4083897 745 ORIENTA AVENUE SUITE 1161 ALTAMONTE SPRINGS, FL 32701 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. Page 3 of 4 PLEASE BE GOVERNED ACCORDINGLY. I HEREBY CERTIFY that on the WK day of 2FWREHU, 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 S SEMORAN BLVD 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 4 of 4 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 Plaintiff(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 HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC 700 WEST OAK STREET KISSIMMEE, FL 34741 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 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: ***PROVIDE UPDATED RECORDS FROM 08/13/2021-PRESENT*** ALL DOCUMENTS AND RECORDS STORED IN ANY FORMAT 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, SIGN-IN SHEETS, ALL DESCRIPTIONS OF EXERCISES PRESCRIBED, DOCUMENTATION WHICH ,1',&$7('$7($1'7,0(2)3$7,(17¶6$332,170(176,1685$1&( DOCUMENTS, ALL RADIOLOGY REPORTS AND READINGS, AND ANY OTHER DOCUMENTS MAINTAINED PERTAINING TO THE CARE, TREATMENT AND EXAMINATION OF THE PATIENT. XIAO SHENG YUE ALT DOB: ; 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 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 Plaintiff(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 HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC 700 WEST OAK STREET KISSIMMEE, FL 34741 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 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: ***PROVIDE UPDATED RECORDS FROM 04/12/2021-PRESENT*** ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR 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. XIAO SHENG YUE ALT DOB: ; 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 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 Plaintiff(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 HCA FLORIDA OSCEOLA HOSPITAL - ORANGE PARK SSC 700 WEST OAK STREET KISSIMMEE, FL 34741 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 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: ***PROVIDE UPDATED RECORDS FROM 11/29/2021-PRESENT*** 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. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB: ; DOB: SSN: 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. Page 1 of 3 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 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 Plaintiff(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 SHERIDAN RADIOLOGY SERVICES OF CENTRAL FLORIDA, INC. C/O 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 Services, 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: 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; AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR Page 1 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; AND 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. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. INCLUDING, BUT NOT LIMITED TO, ANY AND ALL RADIOLOGY REPORTS. XIAO SHENG YUE ALT DOB: ; DOB: SSN: 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 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 Plaintiff(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 AKUMIN 4714 N ARMENIA AVE SUITE 103 TAMPA, FL 33603 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 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: ***PROVIDE UPDATED RECORDS FROM 04/23/2021-PRESENT*** 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; AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR Page 1 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; AND 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. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB: ; DOB: SSN: 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 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 Plaintiff(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 ORLANDO HEALTH NEUROPSYCHOLOGY DEPARTMENT 32 W. GORE STREET, 5TH FLOOR ORLANDO, FL 32806 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 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: ***PROVIDE UPDATED RECORDS FROM 03/16/2021-PRESENT*** 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; AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR Page 1 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; AND 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. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB: ; DOB: SSN: 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 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 Plaintiff(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 HEADACHE AND NEUROLOGICAL TREATMENT INSTITUTE 2137 WEST STATE ROAD 434 LONGWOOD, FL 32779 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 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: ***PROVIDE UPDATED RECORDS FROM 04/05/2021-PRESENT*** 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; AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR Page 1 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; AND 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. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB: ; DOB: SSN: 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 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 Plaintiff(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 KISSIMMEE MEDICAL & WELLNESS CENTER 705 EAST OAK STREET, SUITE A KISSIMMEE, FL 34744 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 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: ***PROVIDE UPDATED RECORDS FROM 04/16/2021-PRESENT*** 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; AND ALL ITEMIZED STATEMENTS OF THE BILLING CHARGES AND/OR CONSOLIDATED STATEMENT OF BENEFITS, WITH DIAGNOSTIC AND PROCEDURE CODES INCLUDING ALL CPT AND ICD-9/ICD-10 CODING AND ALL HCFA, UB04 AND UB92 BILLS, TO INCLUDE THE TOTAL CHARGES PRIVATE OR Page 1 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; AND 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. ALL IMAGES AND FILMS MUST BE PROVIDED ON CD IF AVAILABLE. XIAO SHENG YUE ALT DOB: ; DOB: SSN: 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 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE CASE NO. 2020-CA-001106 Plaintiff(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 ORANGE COUNTY NEUROLOGY CLINIC, LLC 4359 HUNTERS PARK LANE ORLANDO, FL 32837 YOU ARE COMMANDED to produce without deposition and deliver by mail or fax c/o Compex Legal Services, Inc. located at, 5481 W. Waters Ave. Suite 108, Tampa, Florida, 33634, Fax: 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: ***PROVIDE UPDATED RECORDS FROM 04/06/2021-PRESENT*** 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; AND ALL ITEMIZED STATEMENTS