IN THE CIRCUIT COURT, SEVENTH

JUDICIAL CIRCUIT, IN AND FOR

ST. JOHNS COUNTY, FLORIDA
CASE NO.: 2013-CA-1047
DIVISION: 55
JEANETTE L. MALLE,
Plaintiffs,
vs.
FRED R. MCDONALD, an individual, and
JOHN L. SHADD TRUCKING, INC.,
a Florida corporation,
Defendants.
______________________________/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA
TO:

MyMatrixx
Attn: Records Custodian
5706 Benjamin Center Dr., Suite 103
Tampa, FL 33634
YOU ARE COMMANDED to appear at the offices of Fernandez Trial Lawyers, P.A., 8780-200

Perimeter Park Court, Jacksonville, FL, 32216, on, Thursday, August 4, 2016, at 10:00 a.m., and to have
with you at that time and place the following:
SEE EXHIBITS A and A1 ATTACHED
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 schedule 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 and thereby eliminate your appearance at the time and place specified above. You have the

right to object to the production pursuant to this subpoena at anytime before production by giving written
notice to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the
time and place specified above. You have the right to object to the production by giving written notice to
the attorney whose name appears on this subpoena.
HIPAA CERTIFICATE
This certifies that this subpoena has been issued in compliance with the Health Insurance
Portability and Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR
164.512(e)(1)(ii) as this subpoena has been issued pursuant to Rules 1.410 and 1.310 Fla.R.Civ.P. The
Party issuing this subpoena has made a good faith attempt to provide written notice to the
Plaintiff/Patient listed above by sending his/her attorney, an Notice of Production of Records from
Non-Party for which this subpoena has been issued and which included sufficient information about
this litigation to permit the Plaintiff/Patient to raise an objection to the court or administrative tribunal.
The Plaintiff/Patient has not raised any objection to the issuance of this subpoena and the production of
the requested documents.
If you fail to:
(a)

appear as specified; or

(b)

furnish the records instead of appearing as provided above; or

(c)

object to this subpoena;

you may be in contempt of court. You are subpoenaed to appear by the attorneys whose names appear on
this subpoena and unless excused from this subpoena as directed.
DATED on this ___ day of July 2016.
HUNTER S. CONRAD, ESQ.
Clerk of said Court
/s/ Shannon Padgett
As Officer of the Court
(Court Seal)
SHANNON PADGETT, ESQ.
Fernandez Trial Lawyers, P.A.
8780-200 Perimeter Park Court
Jacksonville, Florida 32216
(904) 398-8008
Attorney for Defendants

EXHIBIT A
Any and all documents, memorandums, notes or similar such materials related, in any way, to the
following individual:
NAME:
DOB:
SSN:

JEANETTE MALLE
12/13/1968
264-89-8904

Any and all pharmaceutical records, notes and materials, as well as all documents reflecting
expenses for health care services provided by you, your staff, or any entity with which you may be
associated. If your file contains addresses for any of the health care providers listed in his records,
please provide that information as well.
In short, this request is designed to obtain from you any and all information you have, which is
documented in any form, and related to the above-noted individual.