Filing # 148984731 E-Filed 05/04/2022 07:51:58 PM
`
`CHARU RAHEJA and
`RAVI RAHEJA,
`
`Plaintiff,
`
`VS.
`
`JENNIFER KRISHNARAOand
`SAVANNAHCASEY,
`
`Defendants.
`ee
`
`IN THE CIRCUIT COURT OF THE
`FOURTH JUDICIAL CIRCUIT, IN AND
`FOR DUVAL COUNTY, FLORIDA
`
`CASENO.:
`
`2022-CA-59
`
`NOTICE OF PRODUCTION FROM NON-PARTY
`
`YOU ARE NOTIFIEDthat after ten (10) days from the date of service of this Notice, the
`undersigned will apply to the Clerk of this Court for issuance of the attached Subpoena directed
`to:
`
`Medical & Billing Records Custodian
`Shaw Chiropractic
`8705 Perimeter Park Blvd, Suite 6
`Jacksonville, FL 32216
`
`Medical & Billing Records Custodian
`Therapy Works of Jacksonville, Inc.
`San Marco Clinic
`1819 Hendricks Ave, Suite 2 & 3
`Jacksonville, FL 32207
`
`Medical & Billing Records Custodian
`Brooks Rehab Center-Billing
`P.O. Box 830674
`Birmingham, AL 35283-0674
`
`Medical & Billing Records Custodian
`Emas Spine and Brain
`4085 University Blvd South, Suite 3
`Jacksonville, FL 32216
`
`Medical & Billing Records Custodian
`Brooks Rehab Center-Medical
`Dr. Sarah Lahey
`8505 San Jose Blvd
`Jacksonville, FL 32217
`
`Medical & Billing Records Custodian
`Baymeadows MRI
`7999 Phillips Hwy, Suite 311
`Jacksonville, FL 32256
`
`Page 1 of 45
`
`ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 05/05/2022 06:28:18 PM
`
`

`

`Pharmaceutical Records Custodian
`Walgreens
`1901 E. Vorhees St
`Danville, IL 61834
`
`Pharmaceutical Records Custodian
`CVS Pharmacy
`1 CVS Drive
`Woonsocket, RI 02895
`
`Pharmaceutical Records Custodian
`Winn Dixie Pharmacy
`1201 Hays St
`Tallahassee, FL 32301
`
`Insurance Records Custodian
`Blue Cross Blue Shield
`c/o Chief Financial Officer
`200 E. Gaines St
`Tallahassee, FL 32399
`
`Pharmaceutical Records Custodian
`Walmart Pharmacy
`702 SW 8" St
`Bentonville, AR 72716
`
`Pharmaceutical Records Custodian
`Publix Pharmacy
`330 Publix Corporate Pkwy
`Lakeland, FL 33801
`
`Insurance Records Custodian
`State Farm Insurance
`200 E. Gaines St
`Tallahassee, FL 32399
`
`Insurance Records Custodian
`The Rawlings Company
`1 Eden Pkwy
`La Grange, KY 40031
`
`whoare notparties, to produce the itemslisted at the time and place specified in the Subpoena.
`
`Page 2 of 45
`
`

`

`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFYthat a true and correct copy of the foregoing was furnished by
`
`electronic mail via the Court’s E-Portal to all known designated addresses for Peter G. Shutters,
`
`Esquire, HARRIS GUIDI, ROSNER,P.A., Attorneys for Plaintiff at shutters@harrisguidi.com
`and millan@harisguidi.com this 4" day of May 2022.
`
`CAMERON, HODGES. COLEMAN,
`LaPOINTE & WRIGHT,P.A.
`
`/s/ Christopher C. Coleman
`VIRGIL W. WRIGHT,IU, ESQ.
`Florida Bar No. 993141
`CHRISTOPHER C. COLEMAN,ESQ.
`Florida Bar No.
`0716359
`
`1820 SE 18th Avenue
`Ocala, Florida 34471
`Phone: 352-351-1119 (al)
`Fax: 352-351-0151
`Designated Electronic Mail:
`Servicevww@cameronhodges3.com
`Attorney for Defendants
`
`Page 3 of 45
`
`

`

`IN THE CIRCUIT COURT OF THE
`FOURTH JUDICIAL CIRCUIT, IN AND
`FOR DUVAL COUNTY, FLORIDA
`
`CASE NO.:
`
` 2022-CA-59
`
`CHARU RAHEJA and
`RAVI RAHEJA,
`
`Plaintiff,
`
`VS.
`
`JENNIFER KRISHNARAOand
`SAVANNAH CASEY,
`
`Defendants.
`
`a S
`
`UBPOENA DUCES TECUM WITHOUT DEPOSITION
`
`TO: Medical & Billing Records Custodian
`Shaw Chiropractic
`8705 Perimeter Park Blvd, Suite 6
`Jacksonville, FL 32216
`
`YOU ARE HEREBY COMMANDEDto furnish to the Law Offices of CAMERON,
`HODGES, COLEMAN, LaPOINTE & WRIGHT,P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
`Florida 34471 within TEN DAYSofreceipt of this subpoena, the following:
`
`PLEASE NOTE WE ARE NOT SEEKING HIV/SUBSTANCE ABUSE RECORDS
`
`Therecords to be produced include as FOLLOWS:
`
`SNARWNE
`
`©
`10...
`
`Doctor's records/reports/notes
`Nurse's records/reports/notes
`Administrative reports/notes/memos
`All billing statements
`All letters
`Laboratory records/reports
`Radiology records/reports
`All radiology and diagnostic studies including but not limited to MRIs, CT scans
`and X-rays, preferably on disk
`Diagnostic reports EMG/MRI/EEG
`Therapy records/reports/notes
`Page 4 of 45
`
`

`

`Medical evaluation reports
`11.
`
`12._—_‘Referral forms
`13.
`Insurance documents/forms/ including copies of insurance cards
`14.
`Patient history forms/ including copies of photo identification
`15.|Pharmacyrecords/logs
`16.|Consultation reports
`17.—Hospital or outpatient records/billings
`18.
`Ambulance/EMSreports
`19.—Any other written information pertaining to:
`
`Patient
`Date of Birth
`Social Security No.
`
`RAVI KANWAL RAHEJA
`:
`: PF
`: Po
`
`All records requested should be all inclusive and should in no waybelimited to one
`incident.
`
`to 45 C.F.R. 164.512, "A covered entity may use or disclose
`Pursuant
`protected health information without the written consent or authorization of
`the individual..."to the extent that such use or disclosure is "required by law"
`and the use or disclosure complied with and is limited to the relevant
`requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
`law" includes, but is not limited to, court orders and court-ordered warrants;
`subpoenas or summons...a civil or an authorized investigative demand."
`(emphasis added)
`
`IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
`DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
`TO THE PARTY TO WHOM THIS SUBPOENAIS DIRECTED, BE PRODUCED; THIS
`SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
`OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
`PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
`
`IF YOU HAVEA QUESTION, PLEASE CALL APRIL @ (352) 351-1119.
`
`THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
`TESTIMONY SHALL BE TAKEN.
`
`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 havethe right to object to
`
`Page 5 of 45
`
`

`

`the production pursuant to this subpoena at any time before production by giving written notice
`to the attorney whose nameappearson this subpoena.
`
`If you fail to furnish the records or object to this subpoena, you may be in contempt of
`court. You are subpoenaed by the attorneys whose nameappears on this subpoena and unless
`excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
`as directed.
`DATEDthis 17" day of May 2022.
`
`CAMERON, HODGES. COLEMAN,
`LaPOINTE & WRIGHT,P.A.
`
`/s/ Christopher C. Coleman
`VIRGIL W. WRIGHT,IU, ESQ.
`Florida Bar No. 993141
`CHRISTOPHER C. COLEMAN,ESQ.
`Florida Bar No.
`0716359
`
`1820 SE 18th Avenue
`Ocala, Florida 34471
`Phone: 352-351-1119 (al)
`Fax: 352-351-0151
`Designated Electronic Mail:
`Servicevww@cameronhodges3.com
`Attorney for Defendants
`
`HIPAA Discovery Demand
`
`SATISFACTORYASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
`request for patient information contained in the above referenced legal process to the individual whose
`information is sought.
`I have made:
`
`a5)
`
`(2)
`
`(3)
`
`a good faith attempt to provide written notice to the individual at the individual's last
`known address and/or through the individual's legal counsel, and
`the notice included sufficient information about the above referenced legal proceeding
`so that the individual could raise an objection to the Court or administrative tribunal,
`and
`the time for the individualto raise objections with the Court or administrative tribunal
`has elapsed and either no objections werefiled, or all abjections were resolved by the
`Court in favorofdisclosure.
`
`Page 6 of 45
`
`

`

`IN THE CIRCUIT COURT OF THE
`FOURTH JUDICIAL CIRCUIT, IN AND
`FOR DUVAL COUNTY, FLORIDA
`
`CASE NO.:
`
` 2022-CA-59
`
`CHARU RAHEJA and
`RAVI RAHEJA,
`
`Plaintiff,
`
`VS.
`
`JENNIFER KRISHNARAOand
`SAVANNAH CASEY,
`
`Defendants.
`
`a S
`
`UBPOENA DUCES TECUM WITHOUT DEPOSITION
`
`TO: Medical & Billing Records Custodian
`EmasSpine and Brain
`4085 University Blvd South, Suite 3
`Jacksonville, FL 32216
`
`YOU ARE HEREBY COMMANDEDto furnish to the Law Offices of CAMERON,
`HODGES, COLEMAN, LaPOINTE & WRIGHT,P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
`Florida 34471 within TEN DAYSofreceipt of this subpoena, the following:
`
`PLEASE NOTE WE ARE NOT SEEKING HIV/SUBSTANCE ABUSE RECORDS
`
`Therecords to be produced include as FOLLOWS:
`
`SNARWNE
`
`©
`10...
`
`Doctor's records/reports/notes
`Nurse's records/reports/notes
`Administrative reports/notes/memos
`All billing statements
`All letters
`Laboratory records/reports
`Radiology records/reports
`All radiology and diagnostic studies including but not limited to MRIs, CT scans
`and X-rays, preferably on disk
`Diagnostic reports EMG/MRI/EEG
`Therapy records/reports/notes
`Page 7 of 45
`
`

`

`Medical evaluation reports
`11.
`
`12._—_‘Referral forms
`13.
`Insurance documents/forms/ including copies of insurance cards
`14.
`Patient history forms/ including copies of photo identification
`15.|Pharmacyrecords/logs
`16.|Consultation reports
`17.—Hospital or outpatient records/billings
`18.
`Ambulance/EMSreports
`19.—Any other written information pertaining to:
`
`Patient
`Date of Birth
`Social Security No.
`
`RAVI KANWAL RAHEJA
`:
`: PF
`: Po
`
`All records requested should be all inclusive and should in no waybelimited to one
`incident.
`
`to 45 C.F.R. 164.512, "A covered entity may use or disclose
`Pursuant
`protected health information without the written consent or authorization of
`the individual..."to the extent that such use or disclosure is "required by law"
`and the use or disclosure complied with and is limited to the relevant
`requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
`law" includes, but is not limited to, court orders and court-ordered warrants;
`subpoenas or summons...a civil or an authorized investigative demand."
`(emphasis added)
`
`IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
`DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
`TO THE PARTY TO WHOM THIS SUBPOENAIS DIRECTED, BE PRODUCED; THIS
`SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
`OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
`PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
`
`IF YOU HAVEA QUESTION, PLEASE CALL APRIL @ (352) 351-1119.
`
`THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
`TESTIMONY SHALL BE TAKEN.
`
`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 havethe right to object to
`
`Page 8 of 45
`
`

`

`the production pursuant to this subpoena at any time before production by giving written notice
`to the attorney whose name appearson this subpoena.
`
`If you fail to furnish the records or object to this subpoena, you may be in contempt of
`court. You are subpoenaed by the attorneys whose nameappears on this subpoena and unless
`excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
`as directed.
`DATEDthis 17" day of May 2022.
`
`CAMERON, HODGES. COLEMAN,
`LaPOINTE & WRIGHT,P.A.
`
`/s/ Christopher C. Coleman
`VIRGIL W. WRIGHT,IU, ESQ.
`Florida Bar No. 993141
`CHRISTOPHER C. COLEMAN,ESQ.
`Florida Bar No.
`0716359
`
`1820 SE 18th Avenue
`Ocala, Florida 34471
`Phone: 352-351-1119 (al)
`Fax: 352-351-0151
`Designated Electronic Mail:
`Servicevww@cameronhodges3.com
`Attorney for Defendants
`
`HIPAA Discovery Demand
`
`SATISFACTORYASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
`request for patient information contained in the above referenced legal process to the individual whose
`information is sought.
`I have made:
`
`a5)
`
`(2)
`
`(3)
`
`a good faith attempt to provide written notice to the individual at the individual's last
`known address and/or through the individual's legal counsel, and
`the notice included sufficient information about the above referenced legal proceeding
`so that the individual could raise an objection to the Court or administrative tribunal,
`and
`the time for the individualto raise objections with the Court or administrative tribunal
`has elapsed and either no objections were filed, or all abjections were resolved by the
`Court in favorofdisclosure.
`
`Page 9 of 45
`
`

`

`IN THE CIRCUIT COURT OF THE
`FOURTH JUDICIAL CIRCUIT, IN AND
`FOR DUVAL COUNTY, FLORIDA
`
`CASE NO.:
`
` 2022-CA-59
`
`CHARU RAHEJA and
`RAVI RAHEJA,
`
`Plaintiff,
`
`VS.
`
`JENNIFER KRISHNARAOand
`SAVANNAH CASEY,
`
`Defendants.
`
`a S
`
`UBPOENA DUCES TECUM WITHOUT DEPOSITION
`
`TO: Medical & Billing Records Custodian
`Therapy Works of Jacksonville, Inc.
`San Marco Clinic
`1819 Hendricks Ave, Suite 2 & 3
`Jacksonville, FL 32207
`
`YOU ARE HEREBY COMMANDEDto furnish to the Law Offices of CAMERON,
`HODGES, COLEMAN, LaPOINTE & WRIGHT,P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
`Florida 34471 within TEN DAYSofreceipt of this subpoena, the following:
`
`PLEASE NOTE WE ARE NOT SEEKING HIV/SUBSTANCE ABUSE RECORDS
`
`Therecords to be produced include as FOLLOWS:
`
`SANNAWN
`
`9.
`
`Doctor's records/reports/notes
`Nurse's records/reports/notes
`Administrative reports/notes/memos
`All billing statements
`All letters
`Laboratory records/reports
`Radiology records/reports
`All radiology and diagnostic studies including but not limited to MRIs, CT scans
`and X-rays, preferably on disk
`Diagnostic reports EMG/MRI/EEG
`Page 10 of 45
`
`

`

`Therapy records/reports/notes
`10...
`Medical evaluation reports
`11.
`
`12._—_‘Referral forms
`13.
`Insurance documents/forms/ including copies of insurance cards
`14.
`Patient history forms/ including copies of photo identification
`15.|Pharmacyrecords/logs
`16.|Consultation reports
`17.—Hospital or outpatient records/billings
`18.
`Ambulance/EMSreports
`19.—Any other written information pertaining to:
`
`Patient
`Date of Birth
`Social Security No.
`
`RAVI KANWAL RAHEJA
`:
`: PF
`: Po
`
`All records requested should beall inclusive and should in no way belimited to one
`incident.
`
`to 45 C.F.R. 164.512, "A covered entity may use or disclose
`Pursuant
`protected health information without the written consent or authorization of
`the individual..."to the extent that such use or disclosure is "required by law"
`and the use or disclosure complied with and is limited to the relevant
`requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
`law" includes, but is not limited to, court orders and court-ordered warrants;
`subpoenas or summons...a civil or an authorized investigative demand."
`(emphasis added)
`
`IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
`DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
`TO THE PARTY TO WHOM THIS SUBPOENAIS DIRECTED, BE PRODUCED; THIS
`SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
`OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
`PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
`
`IF YOU HAVEA QUESTION, PLEASE CALL APRIL @ (352) 351-1119.
`
`THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
`TESTIMONY SHALL BE TAKEN.
`
`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
`
`Page 11 of 45
`
`

`

`copies to the attorney whose name appears on this subpoena. You havethe right to object to
`the production pursuant to this subpoena at any time before production by giving written notice
`to the attorney whose nameappearson this subpoena.
`
`If you fail to furnish the records or object to this subpoena, you may be in contempt of
`court. You are subpoenaed by the attorneys whose nameappears on this subpoena and unless
`excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
`as directed.
`DATEDthis 17" day of May 2022.
`
`CAMERON, HODGES. COLEMAN,
`LaPOINTE & WRIGHT,P.A.
`
`/s/ Christopher C. Coleman
`VIRGIL W. WRIGHT,IU, ESQ.
`Florida Bar No. 993141
`CHRISTOPHER C. COLEMAN,ESQ.
`Florida Bar No.
`0716359
`
`1820 SE 18th Avenue
`Ocala, Florida 34471
`Phone: 352-351-1119 (al)
`Fax: 352-351-0151
`Designated Electronic Mail:
`Servicevww@cameronhodges3.com
`Attorney for Defendants
`
`HIPAA Discovery Demand
`
`SATISFACTORYASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
`request for patient information contained in the above referenced legal process to the individual whose
`information is sought.
`I have made:
`
`a5)
`
`(2)
`
`(3)
`
`a good faith attempt to provide written notice to the individual at the individual's last
`known address and/or through the individual's legal counsel, and
`the notice included sufficient information about the above referenced legal proceeding
`so that the individual could raise an objection to the Court or administrative tribunal,
`and
`the time for the individualto raise objections with the Court or administrative tribunal
`has elapsed and either no objections were filed, or all abjections were resolved by the
`Court in favorofdisclosure.
`
`Page 12 of 45
`
`

`

`IN THE CIRCUIT COURT OF THE
`FOURTH JUDICIAL CIRCUIT, IN AND
`FOR DUVAL COUNTY, FLORIDA
`
`CASE NO.:
`
` 2022-CA-59
`
`CHARU RAHEJA and
`RAVI RAHEJA,
`
`Plaintiff,
`
`VS.
`
`JENNIFER KRISHNARAOand
`SAVANNAH CASEY,
`
`Defendants.
`
`a S
`
`UBPOENA DUCES TECUM WITHOUT DEPOSITION
`
`TO: Medical & Billing Records Custodian
`Brooks Rehab Center-Medical
`Dr. Sarah Lahey
`8505 San Jose Blvd
`Jacksonville, FL 32217
`
`YOU ARE HEREBY COMMANDEDto furnish to the Law Offices of CAMERON,
`HODGES, COLEMAN, LaPOINTE & WRIGHT,P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
`Florida 34471 within TEN DAYSofreceipt of this subpoena, the following:
`
`PLEASE NOTE WE ARE NOT SEEKING HIV/SUBSTANCE ABUSE RECORDS
`
`Therecords to be produced include as FOLLOWS:
`
`SANNAWN
`
`9.
`
`Doctor's records/reports/notes
`Nurse's records/reports/notes
`Administrative reports/notes/memos
`All billing statements
`All letters
`Laboratory records/reports
`Radiology records/reports
`All radiology and diagnostic studies including but not limited to MRIs, CT scans
`and X-rays, preferably on disk
`Diagnostic reports EMG/MRI/EEG
`Page 13 of 45
`
`

`

`Therapy records/reports/notes
`10...
`Medical evaluation reports
`11.
`
`12._—_‘Referral forms
`13.
`Insurance documents/forms/ including copies of insurance cards
`14.
`Patient history forms/ including copies of photo identification
`15.|Pharmacyrecords/logs
`16.|Consultation reports
`17.—Hospital or outpatient records/billings
`18.|Ambulance/EMSreports
`19.—Any other written information pertaining to:
`
`Patient
`Date of Birth
`Social Security No.
`
`RAVI KANWAL RAHEJA
`:
`: PF
`: Po
`
`All records requested should beall inclusive and should in no way belimited to one
`incident.
`
`to 45 C.F.R. 164.512, "A covered entity may use or disclose
`Pursuant
`protected health information without the written consent or authorization of
`the individual..."to the extent that such use or disclosure is "required by law"
`and the use or disclosure complied with and is limited to the relevant
`requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
`law" includes, but is not limited to, court orders and court-ordered warrants;
`subpoenas or summons...a civil or an authorized investigative demand."
`(emphasis added)
`
`IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
`DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
`TO THE PARTY TO WHOM THIS SUBPOENAIS DIRECTED, BE PRODUCED; THIS
`SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
`OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
`PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
`
`IF YOU HAVEA QUESTION, PLEASE CALL APRIL @ (352) 351-1119.
`
`THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
`TESTIMONY SHALL BE TAKEN.
`
`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
`
`Page 14 of 45
`
`

`

`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 nameappears on this subpoena.
`
`If you fail to furnish the records or object to this subpoena, you may be in contempt of
`court. You are subpoenaed by the attorneys whose nameappears on this subpoena and unless
`excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
`as directed.
`DATEDthis 17" day of May 2022.
`
`CAMERON, HODGES. COLEMAN,
`LaPOINTE & WRIGHT,P.A.
`
`/s/ Christopher C. Coleman
`VIRGIL W. WRIGHT,IU, ESQ.
`Florida Bar No. 993141
`CHRISTOPHER C. COLEMAN,ESQ.
`Florida Bar No.
`0716359
`
`1820 SE 18th Avenue
`Ocala, Florida 34471
`Phone: 352-351-1119 (al)
`Fax: 352-351-0151
`Designated Electronic Mail:
`Servicevww@cameronhodges3.com
`Attorney for Defendants
`
`HIPAA Discovery Demand
`
`SATISFACTORYASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
`request for patient information contained in the above referenced legal process to the individual whose
`information is sought.
`I have made:
`
`a5)
`
`(2)
`
`(3)
`
`a good faith attempt to provide written notice to the individual at the individual's last
`known address and/or through the individual's legal counsel, and
`the notice included sufficient information about the above referenced legal proceeding
`so that the individual could raise an objection to the Court or administrative tribunal,
`and
`the time for the individualto raise objections with the Court or administrative tribunal
`has elapsed and either no objections were filed, or all abjections were resolved by the
`Court in favorofdisclosure.
`
`Page 15 of 45
`
`

`

`IN THE CIRCUIT COURT OF THE
`FOURTH JUDICIAL CIRCUIT, IN AND
`FOR DUVAL COUNTY, FLORIDA
`
`CASE NO.:
`
` 2022-CA-59
`
`CHARU RAHEJA and
`RAVI RAHEJA,
`
`Plaintiff,
`
`VS.
`
`JENNIFER KRISHNARAOand
`SAVANNAH CASEY,
`
`Defendants.
`
`a S
`
`UBPOENA DUCES TECUM WITHOUT DEPOSITION
`
`TO: Medical & Billing Records Custodian
`Brooks Rehab Center-Billing
`P.O. Box 830674
`Birmingham, AL 35283-0674
`
`YOU ARE HEREBY COMMANDEDto furnish to the Law Offices of CAMERON,
`HODGES, COLEMAN, LaPOINTE & WRIGHT,P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
`Florida 34471 within TEN DAYSofreceipt of this subpoena, the following:
`
`PLEASE NOTE WE ARE NOT SEEKING HIV/SUBSTANCE ABUSE RECORDS
`
`Therecords to be produced include as FOLLOWS:
`
`SNARWNE
`
`©
`10...
`
`Doctor's records/reports/notes
`Nurse's records/reports/notes
`Administrative reports/notes/memos
`All billing statements
`All letters
`Laboratory records/reports
`Radiology records/reports
`All radiology and diagnostic studies including but not limited to MRIs, CT scans
`and X-rays, preferably on disk
`Diagnostic reports EMG/MRI/EEG
`Therapy records/reports/notes
`Page 16 of 45
`
`

`

`Medical evaluation reports
`11.
`
`12._—_‘Referral forms
`13.
`Insurance documents/forms/ including copies of insurance cards
`14.
`Patient history forms/ including copies of photo identification
`15.|Pharmacyrecords/logs
`16.|Consultation reports
`17.—Hospital or outpatient records/billings
`18.
`Ambulance/EMSreports
`19.—Any other written information pertaining to:
`
`Patient
`Date of Birth
`Social Security No.
`
`RAVI KANWAL RAHEJA
`:
`: PF
`: Po
`
`All records requested should be all inclusive and should in no waybelimited to one
`incident.
`
`to 45 C.F.R. 164.512, "A covered entity may use or disclose
`Pursuant
`protected health information without the written consent or authorization of
`the individual..."to the extent that such use or disclosure is "required by law"
`and the use or disclosure complied with and is limited to the relevant
`requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
`law" includes, but is not limited to, court orders and court-ordered warrants;
`subpoenas or summons...a civil or an authorized investigative demand."
`(emphasis added)
`
`IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
`DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
`TO THE PARTY TO WHOM THIS SUBPOENAIS DIRECTED, BE PRODUCED; THIS
`SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
`OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
`PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
`
`IF YOU HAVEA QUESTION, PLEASE CALL APRIL @ (352) 351-1119.
`
`THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
`TESTIMONY SHALL BE TAKEN.
`
`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 havethe right to object to
`
`Page 17 of 45
`
`

`

`the production pursuant to this subpoena at any time before production by giving written notice
`to the attorney whose nameappears on this subpoena.
`
`If you fail to furnish the records or object to this subpoena, you may be in contempt of
`court. You are subpoenaed by the attorneys whose nameappears on this subpoena and unless
`excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
`as directed.
`DATEDthis 17" day of May 2022.
`
`CAMERON, HODGES. COLEMAN,
`LaPOINTE & WRIGHT,P.A.
`
`/s/ Christopher C. Coleman
`VIRGIL W. WRIGHT,IU, ESQ.
`Florida Bar No. 993141
`CHRISTOPHER C. COLEMAN,ESQ.
`Florida Bar No.
`0716359
`
`1820 SE 18th Avenue
`Ocala, Florida 34471
`Phone: 352-351-1119 (al)
`Fax: 352-351-0151
`Designated Electronic Mail:
`Servicevww@cameronhodges3.com
`Attorney for Defendants
`
`HIPAA Discovery Demand
`
`SATISFACTORYASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
`request for patient information contained in the above referenced legal process to the individual whose
`information is sought.
`I have made:
`
`a5)
`
`(2)
`
`(3)
`
`a good faith attempt to provide written notice to the individual at the individual's last
`known address and/or through the individual's legal counsel, and
`the notice included sufficient information about the above referenced legal proceeding
`so that the individual could raise an objection to the Court or administrative tribunal,
`and
`the time for the individualto raise objections with the Court or administrative tribunal
`has elapsed and either no objections were filed, or all abjections were resolved by the
`Court in favorofdisclosure.
`
`Page 18 of 45
`
`

`

`IN THE CIRCUIT COURT OF THE
`FOURTH JUDICIAL CIRCUIT, IN AND
`FOR DUVAL COUNTY, FLORIDA
`
`CASE NO.:
`
` 2022-CA-59
`
`CHARU RAHEJA and
`RAVI RAHEJA,
`
`Plaintiff,
`
`VS.
`
`JENNIFER KRISHNARAOand
`SAVANNAH CASEY,
`
`Defendants.
`
`a S
`
`UBPOENA DUCES TECUM WITHOUT DEPOSITION
`
`TO: Medical & Billing Records Custodian
`Baymeadows MRI
`7999 Phillips Hwy, Suite 311
`Jacksonville, FL 32256
`
`YOU ARE HEREBY COMMANDEDto furnish to the Law Offices of CAMERON,
`HODGES, COLEMAN, LaPOINTE & WRIGHT,P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
`Florida 34471 within TEN DAYSofreceipt of this subpoena, the following:
`
`PLEASE NOTE WE ARE NOT SEEKING HIV/SUBSTANCE ABUSE RECORDS
`
`Therecords to be produced include as FOLLOWS:
`
`SNARWNE
`
`©
`10...
`
`Doctor's records/reports/notes
`Nurse's records/reports/notes
`Administrative reports/notes/memos
`All billing statements
`All letters
`Laboratory records/reports
`Radiology records/reports
`All radiology and diagnostic studies including but not limited to MRIs, CT scans
`and X-rays, preferably on disk
`Diagnostic reports EMG/MRI/EEG
`Therapy records/reports/notes
`Page 19 of 45
`
`

`

`Medical evaluation reports
`11.
`
`12._—_‘Referral forms
`13.
`Insurance documents/forms/ including copies of insurance cards
`14.
`Patient history forms/ including copies of photo identification
`15.|Pharmacyrecords/logs
`16.|Consultation reports
`17.—Hospital or outpatient records/billings
`18.
`Ambulance/EMSreports
`19.—Any other written information pertaining to:
`
`Patient
`Date of Birth
`Social Security No.
`
`RAVI KANWAL RAHEJA
`:
`: PF
`: Po
`
`All records requested should be all inclusive and should in no waybelimited to one
`incident.
`
`to 45 C.F.R. 164.512, "A covered entity may use or disclose
`Pursuant
`protected health information without the written consent or authorization of
`the individual..."to the extent that such use or disclosure is "required by law"
`and the use or disclosure complied with and is limited to the relevant
`requirements of such law." Pursuant to 45 C.F.R. 164.501, "Required by
`law" includes, but is not limited to, court orders and court-ordered warrants;
`subpoenas or summons...a civil or an authorized investigative demand."
`(emphasis added)
`
`IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY
`DOCUMENT, NO MATTER HOW INSIGNIFICANT THAT ITEM MIGHT APPEAR
`TO THE PARTY TO WHOM THIS SUBPOENAIS DIRECTED, BE PRODUCED; THIS
`SUBPOENA IS MEANT TO INCLUDE ALL RECORDS AND BILLS, REGARDLESS
`OF DATE (PRIOR AND SUBSEQUENT TO THE DATE OF ACCIDENT),
`PERTAINING TO THE ABOVE-NAMED INDIVIDUAL.
`
`IF YOU HAVEA QUESTION, PLEASE CALL APRIL @ (352) 351-1119.
`
`THIS SUBPOENA IS FOR PRODUCTION OF RECORDS ONLY. NO ORAL
`TESTIMONY SHALL BE TAKEN.
`
`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 havethe right to object to
`
`Page 20 of 45
`
`

`

`the production pursuant to this subpoena at any time before production by giving written notice
`to the attorney whose nameappears on this subpoena.
`
`If you fail to furnish the records or object to this subpoena, you may be in contempt of
`court. You are subpoenaed by the attorneys whose nameappears on this subpoena and unless
`excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena
`as directed.
`DATEDthis 17" day of May 2022.
`
`CAMERON, HODGES. COLEMAN,
`LaPOINTE & WRIGHT,P.A.
`
`/s/ Christopher C. Coleman
`VIRGIL W. WRIGHT,IU, ESQ.
`Florida Bar No. 993141
`CHRISTOPHER C. COLEMAN,ESQ.
`Florida Bar No.
`0716359
`
`1820 SE 18th Avenue
`Ocala, Florida 34471
`Phone: 352-351-1119 (al)
`Fax: 352-351-0151
`Designated Electronic Mail:
`Servicevww@cameronhodges3.com
`Attorney for Defendants
`
`HIPAA Discovery Demand
`
`SATISFACTORYASSURANCE NOTICE: I represent that I have made reasonable efforts to give notice of the
`request for patient information contained in the above referenced legal process to the individual whose
`information is sought.
`I have made:
`
`a5)
`
`(2)
`
`(3)
`
`a good faith attempt to provide written notice to the individual at the individual's last
`known address and/or through the individual's legal counsel, and
`the notice included sufficient information about the above referenced legal proceeding
`so that the individual could raise an objection to the Court or administrative tribunal,
`and
`the time for the individualto raise objections with the Court or administrative tribunal
`has elapsed and either no objections were filed, or all abjections were resolved by the
`Court in favorofdisclosure.
`
`Page 21 of 45
`
`

`

`IN THE CIRCUIT COURT OF THE
`FOURTH JUDICIAL CIRCUIT, IN AND
`FOR DUVAL COUNTY, FLORIDA
`
`CASE NO.:
`
` 2022-CA-59
`
`CHARU RAHEJA and
`RAVI RAHEJA,
`
`Plaintiff,
`
`VS.
`
`JENNIFER KRISHNARAOand
`SAVANNAH CASEY,
`
`Defendants.
`
`a S
`
`UBPOENA DUCES TECUM WITHOUT DEPOSITION
`
`TO:
`
`Pharmaceutical Records Custodian
`Walgreens
`1901 E. Vorhees St
`Danville, IL 61834
`
`YOU ARE HEREBY COMMANDEDto furnish to the Law Offices of CAMERON,
`HODGES, COLEMAN, LaPOINTE & WRIGHT,P.A., 1820 SE 18th Avenue, Suite 1, Ocala,
`Florida 34471 within TEN DAYSofreceipt of this subpoena, the following:
`
`PLEASE NOTE WE ARE NOT SEEKING HIV/SUBSTANCE ABUSE RECORDS
`
`Therecords to be produced include as FOLLOWS:
`
`SNARWNE
`
`©
`10...
`
`Doctor's records/reports/notes
`Nurse's records/reports/notes
`Administrat