Preview
Filing # 81455128 E-Filed 11/30/2018 12:39:49 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2017-CA-000174 MP
ASHLEY CALZADA and JUAN L. CALZADA,
individually and on behalf of JARIEL LUIS
CALZADA OYUELA, a minor,
Plaintiffs,
vs.
OSCEOLA REGIONAL HOSPITAL d/b/a
OSCEOLA REGIONAL MEDICAL CENTER,
ERIC FRENDAK, CRNA, OSCEOLA
OB/GYN, MICHAEL R. DENARDIS, D.O., OB
HOSPITALIST GROUP, LLC, EZER A
OJEDA, M.D., OSCEOLA ANESTHESIA
ASSOCIATES, PL, RODNEY DEL VALLE,
MD, JMJ FAMILY PRACTICE, INC., JOSE
RAMON FERNANDEZ, M.D., MID-FLORIDA
WOMAN'S CENTER, INC.,
BHUPENDRAKUMAR M. PATEL, M.D.,
PEDIATRIX MEDICAL GROUP, INC.,
PEDIATRIX MEDICAL GROUP OF
FLORIDA, INC., MEDNAX INC., JOSE 1.
GIERBOLINI, M.D., JUAN LONGHI, M.D.,
HCA, INC., HCA HEALTH SERVICES OF
FLORIDA, INC., AND HCA HEALTHCARE
SERVICES - FLORIDA, INC.,
Defendants.
/
PROOF OF SERVICE
BEFORE ME personally appeared Cynthia Sander, who deposes and says that
affiant is over the age of 18 years and is not a party to the above-captioned litigation,
that affiant personally served the attached Subpoenas Duces Tecum Without
Deposition by serving a copy thereof by mail to:
Florida Hospital Apopka
Release of Information — HIM
701 E. Altamonte Dr., Suite 2000
Altamonte Springs, FL 32701
Nite Light Pediatrics
5900 South John Young Parkway
Orlando, FL 32839
The Franz Center
3160 Southgate Commerce Blvd., Suite 64
Orlando, FL 32806
Windermere Medical Center
11600 Lakeside Village Lane
Windermere, FL 34786
On the 30th day of November, 2018.
Cunt Srler
Cynthia Gander
STATE OF FLORIDA
COUNTY OF ORANGE
Subscribed and sworn to (or affirmed) before me on November 30, 2018 by Cynthia
Sander who is personally known to me.
(SEAL)
@
cmc pe memo Notary Public
MY COMMIS#SIO FF 247505
N,
EXPIRES: July 17, 2019
Sees =
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2017-CA-000174 MP
ASHLEY CALZADA and JUAN L. CALZADA,
individually and on behalf of JARIEL LUIS
CALZADA OYUELA, a minor,
Plaintiffs,
vs.
OSCEOLA REGIONAL HOSPITAL d/b/a
OSCEOLA REGIONAL MEDICAL CENTER,
ERIC FRENDAK, CRNA, OSCEOLA
OB/GYN, MICHAEL R. DENARDIS, D.O., OB
HOSPITALIST GROUP, LLC, EZER A
OJEDA, M.D., OSCEOLA ANESTHESIA
ASSOCIATES, PL, RODNEY DEL VALLE,
MD, JMJ FAMILY PRACTICE, INC., JOSE
RAMON FERNANDEZ, M.D., MID-FLORIDA
WOMAN'S CENTER, INC.,
BHUPENDRAKUMAR M. PATEL, M.D.,
PEDIATRIX MEDICAL GROUP, INC.,
PEDIATRIX MEDICAL GROUP OF
FLORIDA, INC., MEDNAX INC., JOSE 1.
GIERBOLINI, M.D., JUAN LONGHI, M.D.,
HCA, INC., HCA HEALTH SERVICES OF
FLORIDA, INC., AND HCA HEALTHCARE
SERVICES - FLORIDA, INC.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
for records only
THE STATE OF FLORIDA:
TO: Records Custodian for
Florida Hospital Apopka
Release of Information — HIM
701 E. Altamonte Drive, Suite 2000
Altamonte Springs, FL 32701
YOU ARE COMMANDED to furnish to Craig S. Foels, Estes, Ingram, Foels &
Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32701, within ten (10)
days following receipt of this Subpoena, the following:
Any and all office notes, charts, doctors' reports, x-rays
or DICOM disc of digital radiology studies, records,
nurses' notes, admission and discharge summaries, any
and all other medical, psychological, psychiatric,
hospital or emergency room records of any kind or
nature whatsoever regarding examination, treatment
and _ evaluations, any and all materials reviewed
pertaining to JARIEL L. CALZADA OYUELA. (See
attached correspondence for patient's date of birth and
Social Security number.)
These items will be inspected and may be copied at that time. You will not be
required to surrender the original items.
You may comply with this subpoena by providing legible copies of the items to be
produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon
the payment in advance of the reasonable cost of preparation. You may mail or deliver
the copies to the attorney whose name appears on this subpoena. 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) furnish the records as provided above; or
(2) object to this subpoena,
you may be in contempt of court. You are subpoenaed by the following attorney to
produce the above-requested records, and unless excused from this subpoena by this
attorney or the court, you shall respond to this subpoena as directed.
DATED this 30th day of November, 2018.
Craig S. Foels
For the Court
s/Craig S. Foels
Attorney for MID-FLORIDA WOMAN'S CENTER, INC.,
and BHUPENDRAKUMAR M. PATEL, M.D.,
ESTES, INGRAM, FOELS & GIBBS, P.A.
2600 Lake Lucien Drive, Suite 330
Maitland, FL 32751
(407) 481-9449
Florida Bar No. 880868
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2017-CA-000174 MP
ASHLEY CALZADA and JUAN L. CALZADA,
individually and on behalf of JARIEL LUIS
CALZADA OYUELA, a minor,
Plaintiffs,
vs.
OSCEOLA REGIONAL HOSPITAL d/b/a
OSCEOLA REGIONAL MEDICAL CENTER,
ERIC FRENDAK, CRNA, OSCEOLA
OB/GYN, MICHAEL R. DENARDIS, D.O., OB
HOSPITALIST GROUP, LLC, EZER A
OJEDA, M.D., OSCEOLA ANESTHESIA
ASSOCIATES, PL, RODNEY DEL VALLE,
MD, JMJ FAMILY PRACTICE, INC., JOSE
RAMON FERNANDEZ, M.D., MID-FLORIDA
WOMAN'S CENTER, INC.,
BHUPENDRAKUMAR M. PATEL, M.D.,
PEDIATRIX MEDICAL GROUP, INC.,
PEDIATRIX MEDICAL GROUP OF
FLORIDA, INC., MEDNAX INC., JOSE I.
GIERBOLINI, M.D., JUAN LONGHI, M.D.,
HCA, INC., HCA HEALTH SERVICES OF
FLORIDA, INC., AND HCA HEALTHCARE
SERVICES - FLORIDA, INC.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
for records only
THE STATE OF FLORIDA:
TO: Records Custodian for
Nite Light Pediatrics
5900 S. John Young Parkway
Orlando, FL 32839
YOU ARE COMMANDED to furnish to Craig S. Foels, Estes, Ingram, Foels &
Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32701, within ten (10)
days following receipt of this Subpoena, the following:
Any and all office notes, charts, doctors' reports, x-rays
or DICOM disc of digital radiology studies, records,
nurses' notes, admission and discharge summaries, any
and all other medical, psychological, psychiatric,
hospital or emergency room records of any kind or
nature whatsoever regarding examination, treatment
and evaluations, any and all materials reviewed, and any
and all billing records including but not limited to, any
and all itemized billing statements pertaining to JARIEL
L. CALZADA OYUELA. (See attached correspondence
for patient's date of birth and Social Security number.)
These items will be inspected and may be copied at that time. You will not be
required to surrender the original items.
You may comply with this subpoena by providing legible copies of the items to be
produced to the attomey whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon
the payment in advance of the reasonable cost of preparation. You may mail or deliver
the copies to the attorney whose name appears on this subpoena. 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) furnish the records as provided above; or
(2) object to this subpoena,
you may be in contempt of court. You are subpoenaed by the following attorney to
produce the above-requested records, and unless excused from this subpoena by this
attorney or the court, you shall respond to this subpoena as directed.
DATED this 30th day of November, 2018.
Craig S. Foels
For the Court
s/Craig S. Foels
Attorney for MID-FLORIDA WOMAN'S CENTER, INC.,
and BHUPENDRAKUMAR M. PATEL, M.D.,
ESTES, INGRAM, FOELS & GIBBS, P.A.
2600 Lake Lucien Drive, Suite 330
Maitland, FL 32751
(407) 481-9449
Florida Bar No. 880868
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2017-CA-000174 MP
ASHLEY CALZADA and JUAN L. CALZADA,
individually and on behalf of JARIEL LUIS
CALZADA OYUELA, a minor,
Plaintiffs,
vs.
OSCEOLA REGIONAL HOSPITAL d/b/a
OSCEOLA REGIONAL MEDICAL CENTER,
ERIC FRENDAK, CRNA, OSCEOLA
OB/GYN, MICHAEL R. DENARDIS, D.O., OB
HOSPITALIST GROUP, LLC, EZER A
OJEDA, M.D., OSCEOLA ANESTHESIA
ASSOCIATES, PL, RODNEY DEL VALLE,
MD, JMJ FAMILY PRACTICE, INC., JOSE
RAMON FERNANDEZ, M.D., MID-FLORIDA
WOMAN'S CENTER, INC.,
BHUPENDRAKUMAR M. PATEL, M.D.,
PEDIATRIX MEDICAL GROUP, INC.,
PEDIATRIX MEDICAL GROUP OF
FLORIDA, INC., MEDNAX INC., JOSE I.
GIERBOLINI, M.D., JUAN LONGHI, M.D.,
HCA, INC., HCA HEALTH SERVICES OF
FLORIDA, INC., AND HCA HEALTHCARE
SERVICES - FLORIDA, INC.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
for records only
THE STATE OF FLORIDA:
TO: Records Custodian for
The Franz Center
3160 Southgate Commerce Blvd., Suite 64
Orlando, FL 32806
YOU ARE COMMANDED to furnish to Craig S. Foels, Estes, Ingram, Foels &
Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32701, within ten (10)
days following receipt of this Subpoena, the following:
Any and all office notes, charts, doctors' reports, x-rays
or DICOM disc of digital radiology studies, records,
nurses' notes, admission and discharge summaries, any
and all other medical, psychological, psychiatric,
hospital or emergency room records of any kind or
nature whatsoever regarding examination, treatment
and evaluations, any and all materials reviewed, and any
and all billing records including but not limited to, any
and all itemized billing statements pertaining to JARIEL
L. CALZADA OYUELA. (See attached correspondence
for patient's date of birth and Social Security number.)
These items will be inspected and may be copied at that time. You will not be
required to surrender the original items.
You may comply with this subpoena by providing legible copies of the items to be
produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon
the payment in advance of the reasonable cost of preparation. You may mail or deliver
the copies to the attorney whose name appears on this subpoena. 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) furnish the records as provided above; or
(2) object to this subpoena,
you may be in contempt of court. You are subpoenaed by the following attorney to
produce the above-requested records, and unless excused from this subpoena by this
attorney or the court, you shall respond to this subpoena as directed.
DATED this 30th day of November, 2018.
Craig S. Foels
For the Court
s/Craig S. Foels
Attorney for MID-FLORIDA WOMAN'S CENTER, INC.,
and BHUPENDRAKUMAR M. PATEL, M.D.,
ESTES, INGRAM, FOELS & GIBBS, P.A.
2600 Lake Lucien Drive, Suite 330
Maitland, FL 32751
(407) 481-9449
Florida Bar No. 880868
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2017-CA-000174 MP
ASHLEY CALZADA and JUAN L. CALZADA,
individually and on behalf of JARIEL LUIS
CALZADA OYUELA, a minor,
Plaintiffs,
vs.
OSCEOLA REGIONAL HOSPITAL d/b/a
OSCEOLA REGIONAL MEDICAL CENTER,
ERIC FRENDAK, CRNA, OSCEOLA
OB/GYN, MICHAEL R. DENARDIS, D.O., OB
HOSPITALIST GROUP, LLC, EZER A
OJEDA, M.D., OSCEOLA ANESTHESIA
ASSOCIATES, PL, RODNEY DEL VALLE,
MD, JMJ FAMILY PRACTICE, INC., JOSE
RAMON FERNANDEZ, M.D., MID-FLORIDA
WOMAN'S CENTER, INC.,
BHUPENDRAKUMAR M. PATEL, M.D.,
PEDIATRIX MEDICAL GROUP, INC.,
PEDIATRIX MEDICAL GROUP OF
FLORIDA, INC., MEDNAX INC., JOSE I.
GIERBOLINI, M.D., JUAN LONGHI, M.D.,
HCA, INC., HCA HEALTH SERVICES OF
FLORIDA, INC., AND HCA HEALTHCARE
SERVICES - FLORIDA, INC.,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
for records only
THE STATE OF FLORIDA:
TO: Records Custodian for
Windermere Medical Center
11600 Lakeside Village Lane
Windermere, FL 34786
YOU ARE COMMANDED to furnish to Craig S. Foels, Estes, Ingram, Foels &
Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32701, within ten (10)
days following receipt of this Subpoena, the following:
Any and all office notes, charts, doctors' reports, x-rays
or DICOM disc of digital radiology studies, records,
nurses' notes, admission and discharge summaries, any
and all other medical, psychological, psychiatric,
hospital or emergency room records of any kind or
nature whatsoever regarding examination, treatment
and evaluations, any and all materials reviewed, and any
and all billing records including but not limited to, any
and all itemized billing statements pertaining to JARIEL
L. CALZADA OYUELA. (See attached correspondence
for patient's date of birth and Social Security number.)
These items will be inspected and may be copied at that time. You will not be
required to surrender the original items.
You may comply with this subpoena by providing legible copies of the items to be
produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon
the payment in advance of the reasonable cost of preparation. You may mail or deliver
the copies to the attorney whose name appears on this subpoena. 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) furnish the records as provided above; or
(2) object to this subpoena,
you may be in contempt of court. You are subpoenaed by the following attorney to
produce the above-requested records, and unless excused from this subpoena by this
attorney or the court, you shall respond to this subpoena as directed.
DATED this 30th day of November, 2018.
Craig S. Foels
For the Court
s/Craig S. Foels
Attorney for MID-FLORIDA WOMAN'S CENTER, INC.,
and BHUPENDRAKUMAR M. PATEL, M.D.,
ESTES, INGRAM, FOELS & GIBBS, P.A.
2600 Lake Lucien Drive, Suite 330
Maitland, FL 32751
(407) 481-9449
Florida Bar No. 880868
10
Preview
Filing # 81455128 E-Filed 11/30/2018 12:39:49 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2017-CA-000174 MP ASHLEY CALZADA and JUAN L. CALZADA, individually and on behalf of JARIEL LUIS CALZADA OYUELA, a minor, Plaintiffs, vs. OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL CENTER, ERIC FRENDAK, CRNA, OSCEOLA OB/GYN, MICHAEL R. DENARDIS, D.O., OB HOSPITALIST GROUP, LLC, EZER A OJEDA, M.D., OSCEOLA ANESTHESIA ASSOCIATES, PL, RODNEY DEL VALLE, MD, JMJ FAMILY PRACTICE, INC., JOSE RAMON FERNANDEZ, M.D., MID-FLORIDA WOMAN'S CENTER, INC., BHUPENDRAKUMAR M. PATEL, M.D., PEDIATRIX MEDICAL GROUP, INC., PEDIATRIX MEDICAL GROUP OF FLORIDA, INC., MEDNAX INC., JOSE 1. GIERBOLINI, M.D., JUAN LONGHI, M.D., HCA, INC., HCA HEALTH SERVICES OF FLORIDA, INC., AND HCA HEALTHCARE SERVICES - FLORIDA, INC., Defendants. / PROOF OF SERVICE BEFORE ME personally appeared Cynthia Sander, who deposes and says that affiant is over the age of 18 years and is not a party to the above-captioned litigation, that affiant personally served the attached Subpoenas Duces Tecum Without Deposition by serving a copy thereof by mail to: Florida Hospital Apopka Release of Information — HIM 701 E. Altamonte Dr., Suite 2000 Altamonte Springs, FL 32701 Nite Light Pediatrics 5900 South John Young Parkway Orlando, FL 32839 The Franz Center 3160 Southgate Commerce Blvd., Suite 64 Orlando, FL 32806 Windermere Medical Center 11600 Lakeside Village Lane Windermere, FL 34786 On the 30th day of November, 2018. Cunt Srler Cynthia Gander STATE OF FLORIDA COUNTY OF ORANGE Subscribed and sworn to (or affirmed) before me on November 30, 2018 by Cynthia Sander who is personally known to me. (SEAL) @ cmc pe memo Notary Public MY COMMIS#SIO FF 247505 N, EXPIRES: July 17, 2019 Sees = IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2017-CA-000174 MP ASHLEY CALZADA and JUAN L. CALZADA, individually and on behalf of JARIEL LUIS CALZADA OYUELA, a minor, Plaintiffs, vs. OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL CENTER, ERIC FRENDAK, CRNA, OSCEOLA OB/GYN, MICHAEL R. DENARDIS, D.O., OB HOSPITALIST GROUP, LLC, EZER A OJEDA, M.D., OSCEOLA ANESTHESIA ASSOCIATES, PL, RODNEY DEL VALLE, MD, JMJ FAMILY PRACTICE, INC., JOSE RAMON FERNANDEZ, M.D., MID-FLORIDA WOMAN'S CENTER, INC., BHUPENDRAKUMAR M. PATEL, M.D., PEDIATRIX MEDICAL GROUP, INC., PEDIATRIX MEDICAL GROUP OF FLORIDA, INC., MEDNAX INC., JOSE 1. GIERBOLINI, M.D., JUAN LONGHI, M.D., HCA, INC., HCA HEALTH SERVICES OF FLORIDA, INC., AND HCA HEALTHCARE SERVICES - FLORIDA, INC., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION for records only THE STATE OF FLORIDA: TO: Records Custodian for Florida Hospital Apopka Release of Information — HIM 701 E. Altamonte Drive, Suite 2000 Altamonte Springs, FL 32701 YOU ARE COMMANDED to furnish to Craig S. Foels, Estes, Ingram, Foels & Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32701, within ten (10) days following receipt of this Subpoena, the following: Any and all office notes, charts, doctors' reports, x-rays or DICOM disc of digital radiology studies, records, nurses' notes, admission and discharge summaries, any and all other medical, psychological, psychiatric, hospital or emergency room records of any kind or nature whatsoever regarding examination, treatment and _ evaluations, any and all materials reviewed pertaining to JARIEL L. CALZADA OYUELA. (See attached correspondence for patient's date of birth and Social Security number.) These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena. 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) furnish the records as provided above; or (2) object to this subpoena, you may be in contempt of court. You are subpoenaed by the following attorney to produce the above-requested records, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this 30th day of November, 2018. Craig S. Foels For the Court s/Craig S. Foels Attorney for MID-FLORIDA WOMAN'S CENTER, INC., and BHUPENDRAKUMAR M. PATEL, M.D., ESTES, INGRAM, FOELS & GIBBS, P.A. 2600 Lake Lucien Drive, Suite 330 Maitland, FL 32751 (407) 481-9449 Florida Bar No. 880868 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2017-CA-000174 MP ASHLEY CALZADA and JUAN L. CALZADA, individually and on behalf of JARIEL LUIS CALZADA OYUELA, a minor, Plaintiffs, vs. OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL CENTER, ERIC FRENDAK, CRNA, OSCEOLA OB/GYN, MICHAEL R. DENARDIS, D.O., OB HOSPITALIST GROUP, LLC, EZER A OJEDA, M.D., OSCEOLA ANESTHESIA ASSOCIATES, PL, RODNEY DEL VALLE, MD, JMJ FAMILY PRACTICE, INC., JOSE RAMON FERNANDEZ, M.D., MID-FLORIDA WOMAN'S CENTER, INC., BHUPENDRAKUMAR M. PATEL, M.D., PEDIATRIX MEDICAL GROUP, INC., PEDIATRIX MEDICAL GROUP OF FLORIDA, INC., MEDNAX INC., JOSE I. GIERBOLINI, M.D., JUAN LONGHI, M.D., HCA, INC., HCA HEALTH SERVICES OF FLORIDA, INC., AND HCA HEALTHCARE SERVICES - FLORIDA, INC., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION for records only THE STATE OF FLORIDA: TO: Records Custodian for Nite Light Pediatrics 5900 S. John Young Parkway Orlando, FL 32839 YOU ARE COMMANDED to furnish to Craig S. Foels, Estes, Ingram, Foels & Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32701, within ten (10) days following receipt of this Subpoena, the following: Any and all office notes, charts, doctors' reports, x-rays or DICOM disc of digital radiology studies, records, nurses' notes, admission and discharge summaries, any and all other medical, psychological, psychiatric, hospital or emergency room records of any kind or nature whatsoever regarding examination, treatment and evaluations, any and all materials reviewed, and any and all billing records including but not limited to, any and all itemized billing statements pertaining to JARIEL L. CALZADA OYUELA. (See attached correspondence for patient's date of birth and Social Security number.) These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attomey whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena. 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) furnish the records as provided above; or (2) object to this subpoena, you may be in contempt of court. You are subpoenaed by the following attorney to produce the above-requested records, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this 30th day of November, 2018. Craig S. Foels For the Court s/Craig S. Foels Attorney for MID-FLORIDA WOMAN'S CENTER, INC., and BHUPENDRAKUMAR M. PATEL, M.D., ESTES, INGRAM, FOELS & GIBBS, P.A. 2600 Lake Lucien Drive, Suite 330 Maitland, FL 32751 (407) 481-9449 Florida Bar No. 880868 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2017-CA-000174 MP ASHLEY CALZADA and JUAN L. CALZADA, individually and on behalf of JARIEL LUIS CALZADA OYUELA, a minor, Plaintiffs, vs. OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL CENTER, ERIC FRENDAK, CRNA, OSCEOLA OB/GYN, MICHAEL R. DENARDIS, D.O., OB HOSPITALIST GROUP, LLC, EZER A OJEDA, M.D., OSCEOLA ANESTHESIA ASSOCIATES, PL, RODNEY DEL VALLE, MD, JMJ FAMILY PRACTICE, INC., JOSE RAMON FERNANDEZ, M.D., MID-FLORIDA WOMAN'S CENTER, INC., BHUPENDRAKUMAR M. PATEL, M.D., PEDIATRIX MEDICAL GROUP, INC., PEDIATRIX MEDICAL GROUP OF FLORIDA, INC., MEDNAX INC., JOSE I. GIERBOLINI, M.D., JUAN LONGHI, M.D., HCA, INC., HCA HEALTH SERVICES OF FLORIDA, INC., AND HCA HEALTHCARE SERVICES - FLORIDA, INC., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION for records only THE STATE OF FLORIDA: TO: Records Custodian for The Franz Center 3160 Southgate Commerce Blvd., Suite 64 Orlando, FL 32806 YOU ARE COMMANDED to furnish to Craig S. Foels, Estes, Ingram, Foels & Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32701, within ten (10) days following receipt of this Subpoena, the following: Any and all office notes, charts, doctors' reports, x-rays or DICOM disc of digital radiology studies, records, nurses' notes, admission and discharge summaries, any and all other medical, psychological, psychiatric, hospital or emergency room records of any kind or nature whatsoever regarding examination, treatment and evaluations, any and all materials reviewed, and any and all billing records including but not limited to, any and all itemized billing statements pertaining to JARIEL L. CALZADA OYUELA. (See attached correspondence for patient's date of birth and Social Security number.) These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena. 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) furnish the records as provided above; or (2) object to this subpoena, you may be in contempt of court. You are subpoenaed by the following attorney to produce the above-requested records, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this 30th day of November, 2018. Craig S. Foels For the Court s/Craig S. Foels Attorney for MID-FLORIDA WOMAN'S CENTER, INC., and BHUPENDRAKUMAR M. PATEL, M.D., ESTES, INGRAM, FOELS & GIBBS, P.A. 2600 Lake Lucien Drive, Suite 330 Maitland, FL 32751 (407) 481-9449 Florida Bar No. 880868 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2017-CA-000174 MP ASHLEY CALZADA and JUAN L. CALZADA, individually and on behalf of JARIEL LUIS CALZADA OYUELA, a minor, Plaintiffs, vs. OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL CENTER, ERIC FRENDAK, CRNA, OSCEOLA OB/GYN, MICHAEL R. DENARDIS, D.O., OB HOSPITALIST GROUP, LLC, EZER A OJEDA, M.D., OSCEOLA ANESTHESIA ASSOCIATES, PL, RODNEY DEL VALLE, MD, JMJ FAMILY PRACTICE, INC., JOSE RAMON FERNANDEZ, M.D., MID-FLORIDA WOMAN'S CENTER, INC., BHUPENDRAKUMAR M. PATEL, M.D., PEDIATRIX MEDICAL GROUP, INC., PEDIATRIX MEDICAL GROUP OF FLORIDA, INC., MEDNAX INC., JOSE I. GIERBOLINI, M.D., JUAN LONGHI, M.D., HCA, INC., HCA HEALTH SERVICES OF FLORIDA, INC., AND HCA HEALTHCARE SERVICES - FLORIDA, INC., Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION for records only THE STATE OF FLORIDA: TO: Records Custodian for Windermere Medical Center 11600 Lakeside Village Lane Windermere, FL 34786 YOU ARE COMMANDED to furnish to Craig S. Foels, Estes, Ingram, Foels & Gibbs, P.A., 2600 Lake Lucien Drive, Suite 330, Maitland, FL 32701, within ten (10) days following receipt of this Subpoena, the following: Any and all office notes, charts, doctors' reports, x-rays or DICOM disc of digital radiology studies, records, nurses' notes, admission and discharge summaries, any and all other medical, psychological, psychiatric, hospital or emergency room records of any kind or nature whatsoever regarding examination, treatment and evaluations, any and all materials reviewed, and any and all billing records including but not limited to, any and all itemized billing statements pertaining to JARIEL L. CALZADA OYUELA. (See attached correspondence for patient's date of birth and Social Security number.) These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena. 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) furnish the records as provided above; or (2) object to this subpoena, you may be in contempt of court. You are subpoenaed by the following attorney to produce the above-requested records, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this 30th day of November, 2018. Craig S. Foels For the Court s/Craig S. Foels Attorney for MID-FLORIDA WOMAN'S CENTER, INC., and BHUPENDRAKUMAR M. PATEL, M.D., ESTES, INGRAM, FOELS & GIBBS, P.A. 2600 Lake Lucien Drive, Suite 330 Maitland, FL 32751 (407) 481-9449 Florida Bar No. 880868 10