for st. lucie

IN THE CIRCUIT COURT OF THE 19 JUDICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY, FLORIDA

CASE NO.: 12CA002123

ADOLFO ROURA,

Plaintiff,

vs.

KRISTINA MICHELLE BRANA andROSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

NON-PARTY. JORDAN GRABEL. M.D.'S WRITTEN OBJKCTIONS TO PLAINTIFF'SNOTICES OF PRODUCTION FROM NON-PARTY DATED OCTOBER 2. 2013

COMES NOW, Non-Party, JORDAN GRABEL, M,D., (hereinafter "GRABEL"),by and

through the undersigned counsel and pursuant to Fla.R,Civ.P. 1.410(e)(1),and hereby files its

Written Objections to Plaintiff's Notice of Production from Non-Party dated October 2, 2013

(hereinafter "NPNP")(attached hereto as Exhibit "A") served on or about October 2, 2013, as

follows:

1. GRABEL is not a party in the above-captioned matter and has no Imowledge of or

interest in the current dispute between plaintiff ADOLFO ROURA (hereinafter "Plaintiff" ) and

defendants KRISTINA MICHELLE BRANA and ROSCOX CORPORATION, (hereinafter

"Defendant" ).

2. GRABEL is a non-party expert witness retained on behalf of the defendants to

perform a Compulsory Medical Evaluation (CME).

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3. On or about October 2, 2013, counsel for the plaintiff in the instant matter issued two

Notices of Non-Party Production enclosing the proposed subpoenas to the following insurance

carriers (attached hereto as Composite Exhibit "A"):

~ Safeco Insurance Company of America

~ Safeco Insurance Company of Illinois

~ Federal Insurance Company

~ Auto-Owners Insurance Company

~ Zurich American Insurance Company of Illinois

~ Zurich American Insurance Company

~ Hartford Fire Insurance Company

~ Hartford Insurance Company of the Midwest

Hartford Insurance Company of the Southeast

Hartford Life and Accident Insurance Company

~ Farmers Specialty Insurance Company

Florida Farm Bureau Casualty Insurance Company

Liberty Mutual Fire Insurance Company, Westwood, WI

Liberty Mutual Insurance Company, Boston, MA

Chartis Property Casualty Company

~ Travelers Casualty and Surety Company

Travelers Casualty Insurance Company of America

The Travelers Indemnity Company of Connecticut

Case No: 12CA002123Roura v. Brana, et alNon-Party, Motion to Quash; Motion for Protective OrderPg3

4. The proposed subpoenas to the above referenced insurance carriers requests that they

each produce the following financial information pertaining to the non-party expert witness:

1)Please provide Tax Identification Payment Number (TIN) payment records for the

years 2009, 2010, 2011, 2012, and 2013 to-date, for each payment made by the

company, or any affiliated entity of any kind or nature, to the Tax IdentificationNumber(s) for Jordan C, Grabel, M,D., including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel M.D., please provide any and all documents of any kindor nature (retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.),which state/show/list the total amount of fees for services paid to JORDAN C.GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A. and/or any relatedsubsidiaries, corporations, professional associations, interests, businesses, or otheraffiliated entities acting on behalf of Jordan C, Grabel, M.D., by (Insurance CarrierName), for any, medical/legal services or litigation, including but not limited to:Compulsory or Independent Medical Examinations, testimony at trial (whether in-

person or by videotape) and/or depositions, records reviews and/or any other servicesprovided in the medical/legal fields, regardless of whether a report was issued,including but not limited to cases, claims or actions for the years 2009, 2010, 2011,2012, 2013 to-date.

The response should include documentation of each payment made by (InsuranceCarrier Name) to the expert JORDAN C. GRABEL, M,D., and/or JORDAN C.GRABEL, M.D., P.A., and/or any related subsidiaries, corporations, professionalassociations, interests, businesses, or other affiliated entities acting on behalf ofJordan C, Grabel, M.D, or JORDAN C. GRABEL, M.D., P.A., through any and allentities, including but not limited to defense law firms retained by (Insurance CarrierName), or serving as in-house counsel for (Insurance Carrier Name), and/or anyother affiliated Defendant, first party UM insurer or third party liability insurer(s) forthe years 2009, 2010, 2011, 2012, 2013 to-date.

5, The issuance of such a subpoena is an improper attempt to negate the rules and case

law that provide for the protection of non-party expert physicians'usiness and financial records

from production. See Fla.R.Civ.P. 1.280(b)(4)(a); Elkins v. Svken, 672 So. 2d 517, (Fla. 1996);

Allstate Insurance Companv v. Boecher, 733. So.2d 993, 996-97 (Fla, 1999).

6. While the Boecher Court allowed for the production of financial records regarding

a non-party expert witnesses'inancial relationship with the party and their insurer, it did not provide

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with the cart blanche access to issue subpoenas to a plethora of insurance carriers throughout North

America.

7. Plaintiff is attempting to gain access to the financial records of the non-party witness

that bear no relevance to his bias or relationship with the defendant in the instant matter, or their

insurance carrier. Instead, Plaintiff is engaged into a fishing expedition for financial records of the

non-party witness from any source possible.

8. GRABEL hereby objects to all items of the proposed subpoena as being irrelevant,

overly broad, oppressive, not reasonably limited as to time or as to scope, and not reasonably

calculated to lead to the discovery of admissible evidence.

The responding physician also objects to Defendant's Notices as he is not obligated

to provide the requested discovery pursuant to Florida Rules of Civil Procedure 1.280(b)(4)(A)(iii)

and under the Florida Supreme Court's decision in Elkins v. Svken, 672 So. 2d 517, (Fla. 1996)and

in Allstate Insurance Companv v. Boecher, 733 So. 2d 993,996-97, (Fla, 1999).Defendant has made

no showing of unusual or compelling circumstances to warrant an intrusion into non-party

GRABEL's confidential business records, even if such an inquiry is directed at other entities that in

possession ofhis financial information, Instead, Plaintiff attempts to bypass the protection afforded

to GRABEL as a non-party expert by trying to go to the sources of GRABEL'S income as a non-

party expert. Such a maneuver is not in keeping with the relevant rules and case law.

10. In sum, Plaintiff's Subpoena, served upon non-party GRABEL, constitutes an abuse

of the discovery rules and subpoena power under the Florida Rules of Civil Procedure. GRABEL

has no knowledge of or interest in the underlying litigation and has now been caught up in a "fishing

expedition" by counsel for the plaintiff.

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11. Based on the foregoing, and for the reasons set forth below, Non-Party GRABEL

respectfully requests this court enter an Order sustaining GRABEL's Written Objections.

LEGAL DISCUSSION

Pursuant to Fla. R. Civ. P. 1.280(c),upon motion by a party or by the person from whom

discovery is sought, and for good cause shown, the court in which the action is pending may make

any order to protect a party or person from annoyance, embarrassment, oppression, or undue burden

or expense that justice requires, including one or more of the following:

(1) that the discovery not be had; (2) that the discovery may be had only onspecified terms and conditions, including a designation of the time or place;(3) that the discovery may be had only by a method of discovery other thanthat selected by the party seeking discovery; (4) that certain matters not beinquired into, or that the scope of the discovery be limited to certain matters;

(5) that discovery be conducted with no one present except personsdesignated by the court; (6) that a deposition after being sealed be openedonly by order of the court; (7) that a trade secret or other confidentialresearch, development or commercial information not be disclosed or bedisclosed only in a designated way; and (8) that the parties simultaneouslyfile specified documents or information enclosed in sealed envelopes to beopened as directed by the court.

In deciding whether good cause has been shown, it is necessary to balance the opposing interests that

would be served by the granting or denying of discovery. South Florida Blood Service. Inc. v.

Rasmussen, 467 So.2d 798, 801 (Fla. 3d DCA 1985), aff d, 500 So.2d 533 (Fla.1987).

I. PLAINTIFF'S PROPOSED SUBPOENA DUCKS TECUM IS OUTSIDE THE SCOPEOF ACCEPTABLE DISCOVERY FROM A NON-PARTY EXPERT WITNESS

A. Plaintiff's requests are beyond the scope of acceptable discovery.

In addition to the claims of privilege raised above, the items sought Plaintiff's Subpoena

Duces Tecum are irrelevant, overly broad, unduly burdensome, harassing, vague, ambiguous, not

reasonably limited as to time or as to scope, and are not reasonably calculated to lead to the

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discovery of admissible evidence, As a result, those items are outside the scope of acceptable

discovery from non-party GRABEL or his employer.

In the seminal case of Surf Drugs. Inc. v. Vermette, 236 So.2d 108, 111-12(Fla.1970), the

Florida Supreme Court recognized four exceptions to the general rule requiring complete discovery:

(1)the subject matter of the discovery must be relevant to the cause; (2) discovery procedures may

not be used or conducted to harass or embarrass litigants or witnesses or for malicious purposes; (3)

the inquiry must not invade the ancient and necessary right of privileged communications between

lawyers and clients; (4) the work product of the litigant, his attorney or agent, cannot be examined,

absent rare and exceptional circumstances.

In exercising discretion to prevent injury through abuse ofthe action or the discovery process

within the action, trial courts are guided by the principles of relevancy and practicality." Friedman

v. Heart Institute of Port St. Lucie. Inc., 863 So.2d 189, 194 (Fla. 2003). The Florida Rules of Civil

Procedure contain provisions enabling the courts to control the abuse ofdiscovery procedures, such

as giving the courts discretionary powers with respect to protecting a party or person from

annoyance, embarrassment, oppression, or undue burden or expense. RoI as v. Rvder Truck Rental.

Inc., 641 So.2d 855, 857 (Fla. 1994); Citigroup Inc. v. Holtseberg, 915 So.2d 1265, 1270 (Fla. 4'"

DCA 2005)(citing Fla,R.Civ.P.1280(c)).

A subpoena duces tecum or deposition ofa records custodian ofa non-party cannot be used

for a mere "fishing expedition" [which might give rise to a potential cause of action] or general

inquisitorial examination of the papers with a view to ascertaining whether something ofvalue may

or may not show up. See Scottsdale Ins. Co. v. Camera DeComercio Latino-Americana De Los

Estados Unidos„ Inc., 813 So.2d 250, 252 (Fla. 3d DCA 2002); State Farm Mut, Auto Ins, Co. v,

Case No: 12CA002123Rourav. Brana, et alNon-Party, Motion to Quash; Motion for Protective Order

Pg 7

Parrish, 800 So.2d 706, 707 (Fla. 5'" DCA 2001);McCartv v. Estate of Schultz, 372 So.2d 210, 212

(Fla. 3d DCA 1979). In addition, neither of them should be employed to obtain material that

could be used to injure another person or party outside the context of the litigation. Alterra

Healthcare Corp. v. Estate of Shellv, 827 So.2d 936, 945 (Fla. 2002); Martin-Johnson. Inc. v.

Savage, 509 So.2d 1097, 1100 (Fla. 1987). (Empahsis supplied).

Further, the rule authorizing a subpoena duces tecum requires some degree of specificity, and

the documents or papers sought should be designated with sufficient particularity to suggest their

existence and materiality," and "describe them so they are identifiable by any reasonable person."

Walter v. Page, 638 So.2d 1030, 1031 (Fla, 2d DCA 1994);See also Palmer v. Servis, 393 So,2d

653, 654-55 (Fla. 5'" DCA 1981).A subpoena duces tecum cannot be used as a "fishing expedition"

or "search warrant" requiring a witness to produce broad categories of items through which the party

can search to find what may be wanted. Id.

B. The sought after information and documentation is not discoverable from anon-party medical expert, nor can it be discovered through uninterestedinsurance carriers that retained said expert in unrelated matters

A cursory review of Plaintiff's subpoena reveals that its requests exceed the scope of

permissible discovery from a non-party expert witness under the Florida Rules of Civil Procedure

Rule 1.280,as well as Elkins v. Svken, 672 So.2d 517 (Fla, 1996).Moreover, they are over broad,

not reasonably limited as to time or as to scope, not relevant to the underlying litigation, and is not

reasonably calculated to lead to the discovery of admissible evidence. The requirements of Fla. R.

Civ. P. 1.280(b)(4)(A)(iii) are as follows:

A party may obtain the following discovery regarding any person disclosed by interrogatories

or otherwise as a person expected to be called as an expert witness at trial:

Case No: 12CA002123Roura v. Brana, et alNon-Partv, Motion to Quash; Motion for Protective Order

Pg8

The scope of employment in the pending case and the compensation

for such service.The expert's general litigation experience, including the percentage

of work performed for plaintiffs and defendants.

The identity of other cases, within a reasonable time period, in which

the expert has testified by deposition or at trial.An approximation of the portion of the expert's involvement as an

expert witness, which may be based on the number of hours,

percentage of hour, or percentage of earned income derived &om

serving as an expert witness; however, the expert shall not be

required to disclose his or her earnings as an expert witness or income

derived from other services. (emphasis supplied).

The production ofthe expert's business records, files, and 1099's may be ordered onlv under

the most unusual or compelling circumstance and an expert may not be compelled to compile or

produce nonexistent documents. Svken v. Elkins, 644 So.2d 539 (Fla. 3d DCA 1994), aff'd Elkins

v. Svken, 672 So.2d 517 (Fla. 1996)(emphasis supplied). Upon motion, the court may order further

discovery by other means, subject to such restrictions as to scope and other provisions pursuant to

subdivision (b)(4)(c) of this rule concerning fees and expenses as the court may deem appropriate.

Fed R. Civ. P. 1.280(b)(4).

In Svken, supra, which involved two unrelated personal injury actions, the Third District

Court of Appeal defined the scope of discovery reasonably necessary to impeach the testimony of

an opponent's expert medical witness. In the first action, Svken v. Elkins, plaintiff's counsel

scheduled the deposition of the records custodian/bookkeeper of the defendant's orthopedic expert,

Dr. Richard Glatzer. Plaintiff's counsel sought the following information; (a) documentation of

income earned by the expert from IMEs since January 1, 1990; (b) the percentage of IME income

relative to private patient income since January 1, 1990;disclosure of the amount charged for IMEs,

and review of the expert's medical records for the past twelve months; the number of impairment

ratings given since January 1, 1990;and the number of court appearances and attorney conferences

Case No: 12CA002123Roura v. Brana, et alNon-Party, Motion to guashi Motion for Protective OrderPg9

and relative charges since January 1990, Defendant's counsel immediately filed an objection and

motion for a protective order.

In the companion case of Plaza v. Roth, plaintiff's counsel sent a Subpoena Duces Tecum

to the defendant's orthopedic expert requesting, among other things, copies of "all bills issued by

Dr. Gregory as a defense expert examiner to any insurance company or law firm during a certain

period and all journals, ledgers, and 1099 forms pertaining to payments received by Dr. Gregory

during a certain period, for examinations performed at the request of any insurance company or law

firm.

Ultimately, the Third District Court ofAppeal found the aforementioned discovery demands

"burdensome and intrusive" (as to the subpoenas served on Dr. Gregory in Plaza) and "cumulative

and duplicative of information easily available upon rudimentary written or oral deposition, but also

so burdensome as to create the possibility of a chilling effect on litigants'bility to find experts to

testify as witnesses" (as to the subpoenas forwarded to Dr. Glatzer in Svken). Svken, 644 So,2d at

547.

In Elkins. supra, at 522, the Florida Supreme Court upheld the ruling in Svken, quashing, as

overly burdensome, an order requiring expert witness physicians to produce tax records and

information regarding patients examined for litigation purposes, In doing so, the Supreme Court held

that the criteria set forth by the Third District Court of Appeal be followed when seeking financial

information from opposing medical experts and ordered that said criteria be included in the

commentary to Fla. R. Civ. P. 1.280.

In Allstate Insurance Companv v. Boecher, 733.So.2d 993, 996-97 (Fla. 1999),the Supreme

Court cited with approval its observation in Elkins that "decisions in this field have gone too far in

Case No: 12CA002123Roura v. Brana, et alNon-Party, Motion to Quash; Motion for Protective Order

Pg 10

permitting burdensome inquiry into the financial affairs ofphysicians, providing information which

'serves only to emphasize in unnecessary detail that which would be apparent to the jury on the

simplest cross-examination: that certain doctors are consistently chosen by a particular side in

personal injury cases to testify on its respective behalf,'" (quotations in original).

In the seminal case of Surf Drugs. Inc. v. Vermette, 236 So.2d 108, 111-12(Fla,1970), the

Supreme Court recognized four exceptions to the general rule requiring complete discovery: (1)the

subject matter of the discovery must be relevant to the cause; (2) discovery procedures may not be

used or conducted to harass or embarrass litigants or witnesses or for malicious purposes; (3) the

inquiry must not invade the ancient and necessary right of privileged communications between

lawyers and clients; (4) the work product of the litigant, his attorney or agent, cannot be examined,

absent rare and exceptional circumstances.

In this matter, Plaintiff's Subpoena for Trial Duces Tecum requests the production of

information regarding GRABEL that is outside the scope of Florida Rule of Civil Procedure 1.280

and the criteria set forth by the Third District Court of Appeal in Svken. GRABEL objects to the

information sought in all items of Plaintiff's Subpoena as overly broad, irrelevant, not reasonably

limited as to time or scope, and not reasonably calculated to lead to the discovery of admissible

evidence in this matter,

Unlike Boecher. where the court allowed discovery into the financial relationship between

a CME expert and the insurance carrier defendant that retained him, Plaintiff does not simply seek

financial information from this defendant's insurance carrier that relates to GRABEL'S relationship

with said carrier. Instead plaintiff attempts to discover financial information and payment info

between GRABEL and any and all insurance carriers, despite the fact such information has no

Case No: 12CA002123Roura v. Brana, et alNon-Party, Motion to Quash; Motion for Protective Order

Pg 11

credible purpose in this case. Under Boecher, the only appropriate direction to travel for an experts

financial information, beyond the restrictions put in place under Rule 1.280, would be the

Defendant's insurance carrier or law firm. Even that direction does not provide for the discovery of

information from any and all insurance carriers or law firms for which the expert has provided

opinions, reviewed records, provided testimony, or any other type of service. See Boecher, 733.

So.2d 993.Plaintiff has made no showing of unusual or compelling circumstances to warrant such

an intrusion into GRABEL's confidential financial information and as such, the Written Objections

to the Notices of Non-Party Production should be upheld.

WHEREFORE, Non-Party, JORDAN GRABEL, M.D., respectfully requests this Court

enter an Order sustaining his Written Objections to Plaintiff's Notices ofNon-Party Production and

for all other relief necessary.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing has been furnished by Email this

day of October, 2013, to: Adam Guzi, Esquire, eservice(kwlclaw,corn„Andy Custer,

Esquire, acuster806(gaol,corn; [email protected].

ADAMSi

COOGLER1555 Palm Beach Lakes Blvd., Suite 1600West Palm Beach, FL 33401(561) 478-4500E-Mail:[email protected] and

[email protected] for Non-Party, JORDAN GRABEL, M.D.

By:IAN E. ROBINSON, ESQUIREFlorida Bar 0085329

~i~'F'SIi'F,'2"

IhII'

Oct. 2. Z!313 5:41!'IVI E'uster-IV!cGovern It!o 3/40 V, 'j

ADGLFO ROURA,

P(aintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST LUCIE COUNTY,FLORIDA

CASE No.: 12CA002123

KRISTINA MICHELLE BRANA andRQSCOX CORPORATION, a Florida Corporation„jointly and severally,

Defendants.

NOTICE GF PRODUCTION FROM NON-PARTY

YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service ofthis notice, if service is by hand-delivery andlor facsimile, or fifteen (15) days from the dateof service, if service is by mail, and if no objection is received from any party„ theundersigned will issue or apply to the C(erk of this Court for issuance of the attachedsubpoena directed to:

Safeco Insurance Company of America175 Berkeley StBoston, MA 02117

2. Safeco Insurance Company of Illinois

27201 Be(la Vista Parkway, Suite 130Warrenville, IL 60565

3 Federal Insurance Company15 Mountain View Roadlfarren„N J 07061

4. Auto-Owners Insurance Company6101 Anacapri BlvdLansing, IVll 48917

5. Zurich American Insurance Company of Illinois

1400 American LaneCorporate LawSchaumburg, IL 60196

Oct. 2. 2U13 b,'42I'IVI Buster-Mcgovern Xo. alerJ

6. Zurich American Insurance Company1400 American LaneSchaumburg, IL 60'I 96

7. Hartford Fire insurance CompanyOne Hartford PlazaHartford, CT 06155

8. Hartford Insurance Company of the Midvlrest

One Hartford PlazaHartford, CT 06155

9. Hartford Insurance Company of the SoutheastOne Hartford PlazaHartford, CT 06155

10. Hartford Life and Accident Insurance Company200 Hopmeadow RoadSimsbury, CT 06089

who Is/are not a party, to produce the items listed in the Subpoena at the time and placespecified therein.


I HEREBY CERTIFY on this 2nd day of October, 2013, that a true and correct copy of the

foregoing has been electronic mail (email) at designation; eservice{Swlclaw'.corrr, ADAM GUZI,

ESQ., Williams, Leininger 8 Cosby, P,A., 50 E. Ocean Blvd, Suite ¹203, Stuart, FL 34994, and I

have electronically filed the foregoing with the Clerk of St Lucie County by using the Florida Courts

e-Filing Portal.

CUSTER MCGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile.'561) 533-6853

/sl Andy M. CusterBY:

ANDY M. CLISTERFlorida Bar No.: 980341Email: Acuster806CSaol.corn

Second Email: sylvia(5custerlawfl.corn

Uct, 2, ZUl3 6:42I'Vl t'utter-Mcbovern lllo. 3 /4(} I', 4

ADOLFO ROURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY,FLORIDA

CASE NO„12CA002123

KRISTINA MICHELLE PRANA andROSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DUCES TECUNI(Mail-in Documents in Lieu of Appearance)

THE STATE OF FLORIDA'.

TO: Records CustodianSafeco Insurance Company of Americac/o Florida Chief Financial OfficerP.O. Box 8200 (32314-6200)200 E. Gatnes StreetTallahassee, Florida 32399

YOU ARE HEREBY CONINIANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'venue North, LakeVVorth, Florida 33460, on the 28'~. day of October, 20"I3, @1".30p.rn., for the taking of yourdeposition in the above-styled cause.

AND TO BRING WITH YOU, THE FOLLOWING:

1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M,D., please provide any and all documents of any kind or na'ture(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by SafecoInsurance Company ofAmerica, for any medical/legal services or litigation, including but not limitedto'. compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Safeco Insurance Companyof America to the expert, JORDAN C. GRABEL, M.D, and/or JORDAN C. GRABEL, M D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan CGrabel, M.D. or Jordan C. Grabel, M.D.,P,A., through any and all entities, including but not limited to defense law firms retained by Safeco

Oct. 2. 2013 b:43I'M {;uster-McGovern No. 3l40

Insurance Company of America, or serving as private andior in-house counsel for Safecoinsurance Company of America, and/or any other affiliated Defendant, fIrst party UM insurer or third

party liability insurer(s) for the years 2009, 20'I0, 2011, 2012 and 20'I 3 to-date.

THIS SUBPOENA REQUIRES PRODUCTION GF DOCUIIENTS

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO IIATTER HOW INSIGNIFICANT THAT ITEII MAY APPEAR TG THE PARTYTO WHOII THIS SUBPOENA IS DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU IIAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMS TO HE PRODUCED TO THE ATTORNEY WHOSE NAIIE APPEARSON THIS SUBPOENA BfLGW GN GR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.163F.S.A.,you are entitled to reimbursement of reasonablecosts incurred ln producing tha documents spaclffad herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to the

attorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:

1. appear as specified, or2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YGU IIAY BE IN CONTEMPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed

Dated: October 12. 2013

CUSTER - MCGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6850Facsimile: (661) 633-6863

ANDY M. CUSTERFlorida Bar No.: 980341Email. Acuster996{iaol.corn

Second Email; svlvia{scusterlawfl.corn

Oct. 2. 2013 6:43PM Custer-McGovern IIo, 3740 P. 6

ADQLFO ROURA„

Plaintiff,

vs,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LLJCIE COUNTY,FLORIDA

CASE NO.: 12CAQ02123

KRISTINA MICHELLE BRANA andRQSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DUCES TECUII{Mail-in Documents in Lieu of Appearance)

THE STATE OF FLORIDA;

TO. Records CustodianSafeco ins0r'ance Company of illinoisr./n Florid~ r.hicf @inane ial Affirm&

P.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M, Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 28'" day of October, 2013, @1:45p.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabal, M.I3.„pleaseprovide any and all documents of any kind or nature(retainer agreements, IRS Form '[ 099'a, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D,, and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by SafecoInsurance Company of lliinois, for any medical/legal services or litigation, including but not limitedto'. Compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields„regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Safaco Insurance Companyof Illinois to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRAHEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C,orabel, M.D. or Jordan C. Grabel, M D

„

P.A., through any and all entities„ including but not limited to defense law firms retained by Safeco

Uct. 2. 2013 b:43I'IVI GUster-II/IcGovern No, 3/40

Insurance Company of illinois, or serving as private and/or in-house counsel for Safeco InsuranceCompany of illinois, and/or any other affiliated Defendant, first party VM insurer or third partyliability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.

THI8 SUBPOENA REQUIRES PRODUCTION OF DOCUMENT8

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EYERY DOCUMENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITEII IVIAY APPEAR TO THE PARTYTO WHOII TKIS SUBPOENA IS DIRECTED, AND 18 MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items %ill be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU IIAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEIIS TO BE PRODUCED TQ THE ATTORNEY WHOSE NAME APPEARSON THI8 SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION,You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonab! ecosts incurred in producing the documents specified herein. Please include your request

fot'eimbursementof costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:

1 appear as specified, or2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - MCGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone; {561).533-6650Facsimile: {561)533-6853

ANDY M. CUSTERFlorida Bar No.: 980341Email. Acuster896taa~om

Second Email; sYlviatecusterlavtrfl.corn

Uct. 2. 2rJ13 b:44I'M I'utter-IVlcbovern IID. 3/4t) I'. b

ADQLFQ RQURA,

Plaintiff,



KRIGTINA MICHELLE BRANA andROSCOX CORPORATION, a Florida Corporation,jointly'nd severally,

Defendants.

SUBPOENA DtjCES TECUII(Mail-in Documents in Lieu of Appearance)

THE STATE OF FLORIDA:

Ta. Records CustodianFederal Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 62QQ (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YGU ARE HEREBY CGMINANDED TG APPEAR before a parson authorized by law to takedepositions at CtjSTER-MCGOVERN, Andy M. Custer, Esq., 1602 1Q~ Avenue North, LakeWorth, Florida 33460, on the 28'" day of October, 2013, I 2:00 p.m., for the taking of yourdeposition in tha above-styled cause.


1} Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-data, for each payment made by tha company, or any affiliatedentity of any kind or nature, to the Tax identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN —66-0340640.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any'ind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc,), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. BRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C, Grabel, M.D., by FederalInsurance Company, for any medical/legal services or litigation, including but not limited to.compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report w'as issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Federal insuranceCompany to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabal, M.D. or Jordan C. Grabel, M.D.,P.A., through any and all entities, including but not limited to defense law firms retaNed by Federal

Uet. 2, 2013 6:44I'Vl V,uster-IVlcUovern No. 3 /40 I'. 9

insurance Company, or serving as private and/or in-house counsel for Federal insuranceCompany, and/or any other affiliated Defendant, first party UM insurer or third party liability

insurer(s) for the years 2009„2010,2011, 2012 and 2013 to-date.

THIS SUBPOENA REQUIRES PRODUCTION QF DOCUMENTS

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HQW INSIGNIFICANT THAT ITEM MAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA I8 DIRECTED, AND IS MEANT TG INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items YGU MAY COMPLY WITH THI8 SUBPOENA BY PROVlDING LEGIBLECOPIES OF THE ITEMS TO BE PRODUCED TG THE ATTORNEY WHOSE NAME APPEARSQN THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE QF PRQDUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver ihe copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above,

IF YOU FAIL TG:

1.appear as specified, or2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YQU MAY BE IN CONTEMPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - MCGOVERN1602 10'" Avenue NorthLake V/orth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile; (561) 533-6853

BYANDY M. CUSTERFlorida Bar No..'80341Email: Acuster806(KaoLcom

Second Email: [email protected]

Uct, 2. 'jtji3 5:45I'M I'lister-Itllcbovern Iso. 3/4rJ I', 1II

ADOLFO ROURA,

Plaintiff,

IN THE GIRCLJIT COURT OF THENINETEENTH JUI3ICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY,FLORIDA

CASE NO.: '12CA002123

KRISTINA MICHELLE BRANA andROSCOX CORPORATION, a Florida Gorporatron,jointly and severally,

Defendants.

SUBPOENA l3UCES TECUM(Mail-in Documents in Lieu of Appearance)


TO.'Records CustodianAuto-Owners Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)2QQ E. Balnes StreetTallahassee, Florida 32399

YOU ARE HEREBY COIIIIANDED TO APPEAR before a person authorized by Iaw to takedepositions at CUSTER-MCGOVERN„Andy M. Guster, Esq., 1602 10'venue North, LakeWorth, Fiorida 33460, on the 28'" day of October, 2013, @2:15 p.m., for the taKing of yourdeposition in the above-styled cause.

AND TO BRING WlTH YOU„THEFOLLOWING')

Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan G. Brabei, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN G. GRAI3EL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M,D., by Auto-OwnersInsurance Company, for any medical/legal services or litigation, including but not limited to:compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2Q10, 2011, 2012 and 20"13 to-date.

The response should include documentation of each payment made by'uto-Owner's InsuranceCompany to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.arabel, M.D. or Jordan C. Grabel, M.D.,P.A.„through any and all entities, including but not limited to defense law firms retained by Auto-

Uct, 2. 2tjlg 6:4bl'M l'uster-IVlcbovern hlo, 3/4rJ I'. 11

Owners insurance Company, or serving as private and/or in-house counsel for Auto-OwnersInsurance Company, and/or any other affiliated Defendant, first party UM insurer or third partyliability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date

THIS SUBPOENA REQU)RES PRODUCTION GF DOCUMENTS

IT IS THE INTENT OF THIS SUBPOENA THA'T EACH AND EVERY DOCUMENT BEPRODUCED, NO NIATTER HGlhf INSIGNIFICANT THAT ITEM NIAY APPEAR TO THE PARTYTO WHO'HIS SUBPOENA IB DIRECTED, AND IS MEANT TO [NCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time You will not be required to surrenderthe original items. YOU NIAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES QF THE ITEIMS TQ BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92,153 F.G,A,, you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:


YOU NIAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.

Dated; October 12. 2013

CUSTER - NICGGVERN1602 10'"Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone; (561) 533-6650Facsimile: (561) 533-6853

BYANDY M. CUSTERFlorida sar No.; 980341Email: Acuster8068) aol.corn

second Email: svlvia(8custerlawfl.corn

Oct. 2, 2tI13 ti:4bl'M Custer-II/lcbovern No 3/4U V, 12

ADOLFO ROURA,

Plaintiff,

vs.

IN THE CIRCUIT COURT OF Tl-IENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY,FLORIDA


KRISTINA II/IICHELLE BRANA andRQSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DUCES TECUM{Mall-in Documents in Lieu of Appearance)

TWE STATE QF FLORIDA'.

TO: Records CustodianZurich American Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gainas StreetTallahassee, Florida 32399

YOU ARE HERE BYCQIINIANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 28'" day of October', 2013, @2:30p.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliated

entity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D,, please provide any and all documents of any kind or nature{retainer agreements, IRS Form 1099's, cancelled checks, ledgers, atc )„which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabal, M.D., by Zurich

American Insurance Company, for any medical/legal services or litigation, including but not limited..I I . I . l. I '. I I L'.-- — —i a.-.'-t f..l sl 1t5: 66ri'ipuieu+Mt Iiiuepai jueiiL itiauiPat eX'M)Ii i@ti6l15, tl55tlll jol ky aL Ll~lal iwllell lei ii I pel OVIi Vl A7

videotape} and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 201'I, 2012 and 2013 to-date

The response should include documentation of each payment made by Zurich American InsuranceCompany to the expert, JORDAN C. GRABEL, M D,, and/or JORDAN C, GRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C. Grabel, M.D.,P.A., through any and all entities, including but not limited to defense law firms retained by Zurich

Uct. 2. 2013 6:46I'M Uuster-IVlcGovern No. 3/40 I'. 13

American Insurance Company of Illinois, or serving as private and/or in-house counsel for Zurich

American Insurance Company, andior any other affiliated Defendant, first party UM insurer or third

party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.

THIS SUBPOENA REQUIRES PRODUCTION OF DQCUIIENTS

IT 18 THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUIIENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITEM IIAY APPEAR TO THE PARTYTG WHOM THIS SUBPOENA IS DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMS TO BE PRODUCED TO THE ATT'ORNEY WHOSE NAME APPEARSON THIS SUBPOENA BELOW QN QR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

in accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents, You may mail or deliver the copies to theallorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YQU FAIL TO:


YOU IIAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,

you shall respond to this Subpoena as directed.


CUSTER - IICGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile: (561) 533-6853

BYANDY M. CUSTERFlorida Bar No..'80341Email: Acuster806fRaol.corn

'econd Emaii: svlviaOcusterlawfl.corn

Oct. 2. 2013 6:46PM Custer-McGovern No 3 I40 P, 14

AWOL/ 0 IlQUllA,

Plaintiff,

vs.

iN Ti-il: cincun eOVm ar vw~NINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY,FLORIDA



Defendants.

SUBPOENA DUCES TECUM(Mail-in Documents in Lieu of Appearance)


TO. Records CustodianZurich American Insur'ance Company of illinois

c/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTaliahassee, Florida 32399

YOU ARE HEREBY CQMIIANDEQ TOAPPEAR before a person authorizedby law to takedepositions at CUSTER MCBO'I/ERN, Andy M Custer, Esq, 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 28'" day of October, 2013, @2:45 p.m.„for the taking of yourdeposition in the above-styled cause

AND TG BRING WITH YOU, THE FGLLG'I/I/ING:

1} Please provide Tax identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliated

entity of any kind or nature, to the Tax Identification Number(s} for Jordan C. Grabel, M.D.,including but not limited to TIN —65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees forservices paid to JORDAN C. GRAHEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabei, M.D,, by ZurichAmerican Insurance Company of illinois, for any medical/legal services or litigation, including butnot limited to; compulsory or independent medical examinations, testimony at trial (whether in-

person or by videotape) and/or depositions, record reviews and/or any other services provided in

the medical/legal fields, regardless of whether a report was issued, including but not limited tocases, claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Zurich American insuranceCompany of Illinois to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D.,P.A. and/or any related subsidiaries, corporations, professional associations, interests, businessesandlor other affiliated entities acting on behalf of Jordan C. Grabal, M.D. or Jordan C. Grabel, M.D.,P.A., through any and all entities, including but not limited to defense law firms retained by Zurich

Oct. 2, 2013 6:47PM Custer-McGovern No. 3740 P. 15

American insurance Company of Illinois, or serving as private and/or in-house counsel for ZurichAmerican Insurance Company of illinois, and/or any other affiliated Defendant, first party UMinsurer or third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.

THIS SUBPOENA REQUIRES PRODUCTION OF DOCUMIENT8

'IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO NIATTER HOW INSIGNIFICANT THAT ITEMI NIAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA I8 DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMIS TO BE PRODUCED TO THE ATTORNEY WHOSE NANIE APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or hefnre the scheduted elate of nrodt!rtion

ln accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specil'ied herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above,

IF YOU FAIL TO:

1. appear as specified, or2. furnish the records instead of appearing as provided above, or

Abf~~t ted% thlQ CV&p&&~m, --.

YOU NIAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.

Dated: October 12, 2033

CUSTER - MCGOVERN1602 'l0'" Avenue NorthLake Nforth, Florida 33460Attorney for PlaintiffTelephone. (561) 533-6650Facsimile: (56 I) 533-6853

BYANDY M. CUSTERFlorida Bar No.: 980341Email: Acuster806eaol.corn

Second Email: svlvla(Icustezlawfl.corn


ADOLFO ROURA,

Plaintiff,

vs.




Defendants.

SUBPOENA l3UCES TEGUII(Mail-in Documents in Lieu of Appearance)

THE STATE OFFLORIDA.'O:

Records CustodianHartford Insurance Company of the Midwestc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E, Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorized by Iaw to taKe

depositions at CUSTER-MCGOVERN, Andy M. Custer„Esq., 1602 10~ Avenue North, Lakeworth, I-Ionda 834bU, on tne 25'" day of Uctober, 2015, (c 4:15 p.m., ror tne taung or yourdeposition in the above-styled cause.

AND To BRING WITH YOU, THEFOLLOWING')

Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 20'I3 to-date, for each payment made by the company, or any affiliated


2) As to Jordan G, Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099"s,cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN G. GRABEL, M,D.„and/or JORDAN C. BRABEL,M.D., P,A, and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan G. Grabel, M.D.„byHartford

insurance Company of the Midwest, for any medical/legal services or litigation, including but notlimited to. compulsory or independent medical examinations, testimony at trial (whether in-personor by videotape} and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 20'l3 to-date.

The response should include documentation of each payment made by Hartford insuranceCompany of the Midwest to the expert, JORDAN C. BRAHEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses and/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C.Grabel, M.D., P.A,, through any and all entities, including but not limited to defense law firms

Oct. 2. 2013 6:48PM Custer-McGovern No, 3740 P. 17

retained by Hartford insurance Company of the Midwest, or serving as private and/or in-housecounsel for Hartford Insurance Company of the Midwest, and/or any other affiliated Defendant, first

party UM insurer or third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013to-date.

THIS SUBPOENA REQUIRES PRODUCTION OF DOCUMENTS

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUNIENT BEPRcPoUGED, NQ MATTER Hvw IN5[6NlFIGANT THAT ITEwl tviAY APPEAR To THE PARTTTO WHOM THI8 8UBPOENA I8 DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time, You will not be required to surrenderthe original items. YOU IIAY COMPLY WITH THIS SUBPOENA BY PROVIDINO LEOIBLECOPIES OF THE ITEII8 TO BE PRODUCED TO 'THE ATTORNEY WHOSE NAIIE APPEARSON THIS SUBPOENA BELOW ON QR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at. thetime and place specified above.

IF YOU FAIL TO:


YOU MAY BE IN CONTEMPT QF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attonsey or the Court,you shall respond to this Subpoena as directed.

l3ated; October 12. 2013

CUSTER - MCGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone. (561) 533-6650Facsimile: (561) 533-6853

BYANDY M. CUSTERFlorida Bar No.: 980341Email: [email protected]


Oct, 2, 2013 6:4E3PM Custer-McGovern No, 374II P. 18

ADOLFG RQURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FUR ST, LUGIE COUNTY,FLORIDA

CASE NO,'. 12CA002123

KRISTINA MICHELLE BRANA andRQSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DtjCES TECUM(Mail-in Documents in Lieu of Appearance)

Tl-IE STATE OF FLORIDA:

TO: Records CustodianHartford Fire insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10" Avenue North, LakeWorth, Florida 33460, on the 28™day of October, 2013, @3:00 p.m., for the taking of yourdeposition in the above-styled cause.

ANO TO BRING N/ITH YOU, THE FOLLOWN9:

1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity vf any kind or nature, lv Lhe Tax iueriiiHcailun iuusnber(~j ivr Jordan C, 6rabei, ivi.P,,including but not limited to TIN —65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRAHEL,M.D.„P.A.and/or any related subsidiaries, corporations„professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.O., by Hartford FireInsurance Company, for any medical/legal services or litigation, including but not limited to:compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Hartford Fire InsuranceCompany to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C GRABEL, M.D., P.A,and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C,Grabel, M.D. or Jordan C. Grabel, M.D.,P.A., through any and ail entities, including but not limited to defense law firms retained by Hartford

Oct. 2. 2013 6:4BPM Custer-McGovern No, 3740 P. 19

Fire Insurance Company, or serving as private and/or in-house counsel for Hartford Fire InsuranceCompany, and/or any other affiliated Defendant, first party UM insurer or third party liability

insurer(s) for the years 2009, 2010, 2011„2012and 2013 to-date.


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUIIENT BEPRODUCED, NQ IIATTER HOW INSIGNIFICANT THAT ITEM IIAY APPEAR TO THE PARTYTG WHOII THIS SUBPOENA IS DIRECTED, AND IS IIEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMS TO BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:



l3ated: October 12. 2013

CUSTER - IlCGOVERN1602 10'"Avenue North

I ake I/IIorth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile: (561) 533-6853

ANDY M. CUSTERFlorida Bar No.: 980341Email: Acuster806eaol.corn

Second Email. svlvia@cus+erlawfl corn

Oct. 2, 2013 6:49PM Custer-McGovern IIo, 3740 P. 20

ADGLFG RGURA,

Plaintiff,

Vs.

IN THE CIRCUIT COURT GF TMENINETEENTH JUDICIAL CIRCUITIN AND FGR ST. LUCIE COUNTY,FLORIDA

CASE NG.: 12CA002123

KRIBTINA IVIICHELLE BRANA andROSCGX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DUCEB TECUM(Mail-in Documents in Lieu of Appearance)


TO: Records CustodianHartford Insurance Company of the Southeastc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Qaines StreetT~nwhnaaan. plnrirln 9 )'Mo

YOU ARE HEREBY COSIIIIANOED f0APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 28 " day of October, 2013, @3:30p.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,20'I0, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentify of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN - 65 0340540

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature{retainer agreemants, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P,A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated antitias acting on behalf of Jordan C. Grabel, M.D., by'artfordInsurance Company of the Southeast, for any medical/legal services or litigation, including but notIrmited to. compulsory or independent medical examinations, testimony at trial {whether in-personor by videotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-data.

The response should include documentation of each payment made by Hartford insuranceCompany of the Southeast to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C.GRABEL, M.D., P.A. and/or any related subsidiaries, corporations, professional associations,interests, businesses and/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. orJordan C. Grabel, M.D., P.A., through any and all entities, including but not limited to defense law


firms retained by Hartford insurance Company of the Southeast, or serving as private and/or in-

house counsel for Hartford insurance Company of the Southeast, and/or any other affiliatedDefendant, first party UM insurer or third party liability insurer(s} for the years 2009, 2010, 2011,2012 and 2013 to-date.


IT IS THE INTENT GF THIS 8UBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NG IlllATTER HOW INSIGNIFICANT THAT ITEM IIAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA IS DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTEI3.

These items will be inspected and may be copied at that time You will not be required to surrenderthe original items. YOU hllAY COIIPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEIIS TO BE PRODUCED TO THE ATTORNEY WHOSE NAIIE APPEAR8GN THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:

1.appear as specified, or2. furnish the records instead of appearing as provided above, or3, object to this Subpoena,

YOU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameenneAre nn fhl~ Quhnnanz anrt I Inlands. avnne@rl fmn thia 4 ihr nanna hv th~ attnmay r r tho r .eud,you shall respond to this Subpoena as directed


CUSTER IICGOVERN1602 10~ Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6660Facsimile: (561}533-6853

ANDY M CUSTERFlorida Bar No.: 980341Email: [email protected]

Second Email'[email protected]

Oct. 2. 2rjI3 6,5IIPM Custer-McGovern No. 3740 P. 22

ADQLFO ROURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAl CIRCUIT[N AND FOR ST. LUCIE COUNTY,Fl QRIDA


KRISTINA MICHELLE BRANA andRCISCQX CQRPQRATIQN, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DUCES TECUII(IVlail-In Documents in Lieu of Appearance)


TQ: Records CustodianHartford Life and Accident Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TQ APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 28'" day of October, 2913, I 3:45 p,m., for the taking of yourdeposition in the above-styled cause.

AND TO BRING WITH YOU„THEFOLLOWING:

I) Please provide Tax Identification Payment Number (TiN) payment records for the years 2009,2010, 2011„2012,and 2013 to-date„ for each payment made by the company, or any affiliated

entity of any kind or nature, to the Tax Identification Number(s) for Jordan C, Grabel, M,D.„including but not limited to TIN —65-0340540.

2) As to Jordan C. Grabe[, M.I3., please provide any and all documents of any kind or nature(retainer agreements, IR8 Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount. of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C Grabel, M.D., by Hartford Life

and Accident Insurance Company, for any medical/legal services or litigation, including but notlimited to; compulsory or independent medical examinations, testimony at trial (whether in-personor by videotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Hartford Life and AccidentInsurance Company to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P,A. and/or any related subsidiaries, corporations, professional associations, interests,businesses and/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C.Grabel, M.D., P.A., through any and all entities, including but not limited to defense law firms

Uct. 2. 2U13 b:VUI'M I;uster-McGovern No. 3/4U l', 23

retained by Hartford Life and Accident Insurance Company, or serving as private and/or in-housecounsel for Hartford Life and Accident Insurance Company, and/or any other affiliated Defendant,first party UM insurer or third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and2013 to-date.

THI8 SUBPOENA REQUIRES PRODUCTION OF DOCUMENTS

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITENI INAY APPEAR TO THE PARTY'O

WHOIN THIS SUBPOENA IS DIRECTED, AND IS INEANT TO INCLUDE AI L RECORDSREQUESTED,

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAY COMPLY MflTH THIS 8UBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITENt8 TO BE PRODUCED 'TG THE ATTORNEY WHOSE NAME APPEARSGN THIS SUBPOENA BELG'W ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts Incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents, You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above,

IF YOU FAIL TO:

1. appear as specified, ol2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YOU NIAY RE IN CONTENIPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shaH respond to this Subpoena as directed.

l3ated. October 12. 2013

CUSTER - NICGOVERN1602 10'venue NorthLake Worth„Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile: (561) 533-6653

ANDY M. CUSTERFlorida Bar No: 980341Emaii: AcusterBOBQaol.corn


Oct, 2, 2U13 6:OUI'M Custer-Mcbovern III', 3/4U I'. 24

AI3QLFG RGURA,

PIBintiff,

IN THE CIRCUIT COURT GF THENINETEENTH JLII3ICIAL CIRCUITIN AND FOR 8T, LUCIE COUNTY,FLORIDA


KRISTINA IVIICHELLE BRANA andROSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

NOTICE GF PRODUCTION FRGIIII NON-PARTY

YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service ofthis notice, if service is by hand-delivery and/or facsimile„or fifteen (16) days from the dateof service, if service is by mail, and if no objection is received from any party, theundersigned will issue or apply to the Clerk of this Court for issuance of the attachedsubpoena directed to:

1. Progressive Express insurance Company6300 Wilson Mills RoadMayfield Village, OH 44143

2. Nationwide General Insurance CompanyOne Nationwide PlazaColumbus, OH 43216

3. Canal Insurance Company400 E Stone AbeGreenville, SC 29601

4. Infinity Insurance Company3700 Colonnade ParkwaySuite 600Birmingham, AL 35243

5. Integon General Insurance Company500 West Fifth StreetWinston Salem, NC 27101

Uct. 2. 2013 b:hli'M Coster-IVlc(iovern No. 3/40 I', 2b

6. Direct General insurance Company201 North lliinois Street16~ Floor South TowerIndianapolis, IN 46204

?. National General Insurance Company500 West Fifth StreetWinston-Salem, NC 27101

8, Enterprise Leasing Company of Florida600 Corporate Park DriveSt. Louis, MO 63105

9. Enterprise Leasing Company of Orlando, LLC5442 Hoffner AveOrlando, Fl 32812

10. Enterprise Leasing Company of South Central LLC200 Vestavia Parkway, Suite 3?00Birmingham. AL 35216

who islare not a party, to produce the items listed in the Subpoena at the time and placespecified therein.


I HEREBY CERTIFY on this 2nd day of October, 2033, that a true and correct copy of the

foregoing has been electronic mail (email) at designation: yservicefRwlclaw.corn, ADAM GUZI,

ESQ., Williams, Leininger 8 Cosby, P.A., 60 E. Ocean Blvd., Suite 1203, Stuart, FL 34994, and I

have electronically filed the foregoing with the Clerk of St Lucie County by using the Florida Courts

e-Filing Portal.

CUSTER - MCGOVERN1602 10'" Avenue North

Lake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile: (561) 533-6853

Is/ Andy M. CusterBY

ANDY M, CUSTERFlorida Bar No..'80341Email: [email protected]

Second Email: svlviatRcusterlawfl.corn

Oct, 2, 2{II] ti:Qji'M {;uster-IVlcGovern No 3/4{3 I'. 2b

ADOLFO ROURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FQR ST. LUCIE COUNTY,FLORIDA

CASE NQ.: 12CA002123


Defendants,

BUBPOENA DUCES TECUM(Mail-in Documents in Lieu of Appearance)


TO: Records CustodianProgressive Express insurance Companyc/o Florida Chief Financial OfficerP.O. Box 8200 (32314-8200)200 E. Baines StreetTallahassee, Florida 32399

YOU ARE HEREBY COIIIIANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 28™day of October, 2013„{$10:30a.m., for the taking of yourdeposition in the above-styled cause.

AND To BRING WITH YOU, THE FOLLOWlNG."

1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Brabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D,, please provide any and ail documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. BRABEL, M.D., and/or JORDAN C. BRABEL,M.D., PA. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M,D., by ProgressiveExpress Insurance Company, for any medical/legal services or litigation, including but not limitedto; compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape} and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made Progressive Expressinsurance Company, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses and/or other affiliated entities acting on behalf of Jordan C.Brabel, M.D. or Jordan C.Brabel, M.D., P.A., through any and ali entities, inciuding but not limited to defense law firms

Oct. 2. 2Ij13 6:52PM Custer-McGovern No. 3740 P. 27

retained by Progressive Express Insurance Company, or serving as private and/or in-housecounsel for Progressive Express Insurance Company, and/or any other affiliated Defendant, firstparty LlM insurer or third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013to-date.

TH)8 SUBPOENA REQUIRES PRODUCTION GF DOCUIIENTS

IT 18 THE INTENT OF TH)8 SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO I)ATTER HGW INSIGNIFICANT THAT ITEM MAY APPEAR TG THE PARTYTG WHOM THIS SUBPOENA IS DIRECTED, AND 18 IIEANT TO INCLUDE ALL RECORDSREQUESTED.

These items wil) be inspected and may be copied at that time. You will not be required to surrenderthe original items. YGU MAY CON)PLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMS 70 BE PRODUCED TO THE ATTORNEY MIHOSE NAIIE APPEARSQN TH)8 SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE GF PAQDUCTIQN.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production,

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documerits specified herein Please include your request forreimbursement of costs along with the documents. You may mail or delive! the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at theLinje ainu pfauu apuuiriuu eabuva.

IF YOU FA)L TG:


YOU IIAY BE IN CONTE)IPT OF COURT. Vou are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed


CUSTER - IICGOVERN1602 10~ Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile: (561) 533-6853

ANDY M CUSTERFlorida Bar No.: 980341Email: Acuster80Beao).corn

Second Email. svlviaÃcuster)awfl.corn

Oct. 2. 2013 6:52PM Custer-McGovern No, 3/40 P. 28

ADOLFO RQURA,

Plaintiff,

vs.


CASh I'4U.: I ZUAUUZ123


Defendants.

SUBPOENA DUCES TECUII(Mail-in Documents in Lieu of Appearance)

THE STATE QF FLORIDA:

TO: Records CustodianNationwide General Insurance Companyclo Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 28 " day of October, 2013„e10:45 a.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax identification Number(s) for Jordan C. Grabel, M.D.,Including but not limited to TIN - 65-0340540,

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by NationwideGeneral Insurance Company, for any medical/legal services or litigation, including but not limitedto: compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each pay'ment made Nationwide GeneralInsurance Company, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses and/or other affiliated entities acting on behalf of Jordan C.Grabef, M.D. or Jordan C.Grabel, M.D., P.A., through any and all entities, including but not lirniled to defense law firms

Oct. 2. 2013 6:52PM Custer-McGovern No. 3740 P. 29

retained by Nationwide General insurance Company, or serving as private and/or in-house counselfor Nationwide General Insurance Company, and/or any other affiliated Defendant, first party UMinsurer or third party liability insurer(s) for the years 2009, 2010, 2011„2012and 2013 to-date.

THIS SUBPOENA REQUIRES PRODUCTION OF DOCUIIENTS

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUIIENT BEPRoDUQcD Nc& IVIATTcR I Iow INGIQNIFIGANT TI)AT ITLM MAY APPLAR Tg Tl Ic PARTYTO WHOII THIS SUBPOENA 18 DIRECTED, AND I8 MEANT TO INCLUDE ALL RECORD8REQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe originai items YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMS TO BE PRODUCED TO THE ATTORNEY WHOSE MAINE APPEARSON THIS SUBPOENA BELOW OM OR BEFORE THE SCHEDULED DA'TE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursemerIt of costs along with the documents. You may mail or deliver the copies to lheattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:

1, appear as specified, or2. furnish the records instead of appearing as provided above, or3. object to this SLIbpoerIa,

YOU IIAY BE IN CONTFMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - IICGOVERN1602 10~ Avenue NorthLake Nforth, Florida 33460Attorney for PlaintiffTelephone (561) 533-6650Facsimile: (561) 533-6853

BYANDY M CUSTERFlorida Bar No.; 980341Email: Acuster806$ aol.corn

Second Email- svlvia(Scusterlawfl, corn


ADOLFO ROURA,

Plaintiff,

vs,


CASE NQ.: 12CAQ02123

KRISTINA MICHELLE BRANA andRQSCQX CQRPQRATIQN, a Florida Corporatior(,jointly and severally,

Defendants.

SUBPOENA DUCES TECUIN(Mail-in Documents in Lieu of Appearance)

THE STATE OF FLORIDA.

TO Records CustodianCanal Insurance Companyc/o Florida Chief Financial OfficerP O Box 6200 (32314-6200)200 E. Gaines Str'eetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER MCGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, Lake

Worth, Florida 33460, on the 28'" day of October, 2013, (I 11:00a.rn., for the taking of yourdeposition in the above-styled cause.


1) Please prov(de Tax identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliated

entity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.I3.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.I3., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRAHEL, M,D., and/or JORDAN C GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by CanalInsurance Company, for any medical/legal services or litigation, including but not limited to:~nipuleuiy v& i&iuupa)jdaii(. iitauivu( aaauti&iealiune, k-etiinvny m( (rial (w(iu((m) (n"pmeun ur by

videotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made Canal Insurance Company,to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A. and/or anyrelated subsidiaries, corporations, professional associations, interests, businesses and/or otheraffiliated entities acting on behalf of Jordan C.GrabeI, M.D. or Jordan C. Grabel, M.D., P.A,through any'nd all entities, including but not limited to defense law firms retained by Canal

Oct. 2. 2013 6:53PM Custer-McGovern No. 3740 P. 31

Insurance Company, or serving as private and/or in-house counsel for Canal insurance Company,and/or any other affiliated Defendant, first party UM insurer or third party liability insurer(s) for theyears 2009, 2010, 2011, 2012 and 2013 to-date.

THI8 8UBPOENA REQUIRES PRODUCTION OF DOCUMENTS

IT 18 THE INTENT OF THl8 SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITEM MAY APPEAR TO THE PARTYTO NfHOII THIS SUBPOENA 18 DIRECTED, AND I8 MEANT TO INCLUDE ALL RECORD8REQUESTED,

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original Items. YOU INAY COMPLY WITH THIS SUBPurNA BY PRuviulNG LeGIBLrCOPIES OF THE ITEII8 TO BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEAR8ON THIS 8UBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F,S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:

1. appear as specified„or2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YOU MAY BE IN CONTEIIPT OF GOURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.

Dated.'October 12, 2013

CUSTER - IICGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone; (561) 533-6650Facsimile: (561) 633-6863

BYANI3Y M. CUSTERFlorida Bar No.: 980341Email. [email protected]

Second Email: svlviarmcusterlawfl.corn

Oct. 2, 2II13 6:5%VIVI C;uster-Mcbovero III o. 3/4tI V. 32

ADOLFO RQURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN ANI3 FOR ST. LUCIE COUNTY,FLORIDA


KRISTINA It/IICHELLE BRANA andROSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.



TG; Records CustodianInfinity insurance Companyc/o Florida Chief Financial OfficerP.Q Box 6200 (32314-6200)200 E. Baines StreetTallahassee, Florida 32399

YQU ARE HEREBY GOIIIIANDED 'TO APPEAR before a person authorized by Iaw to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 28'" day of October„2013,@11:15a.m., for the taking of yourdeposition in the above-styled cause.

AND TO BRING WITH YOV, THE FOLLO'Ih/ING:

1) Please provide Tax identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN - 65-0340540

2) As to Jordan C. Brabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc,), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. BRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Brabel, M,D,, by InfinityInsurance Company, for any medical/legal services or litigation, including but not limited

to.'ompulsoryor independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made infinity insurance Company,to the expert, JORDAN C. BRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A. and/or anyrelated subsidiaries, corporations, professional associations, interests, businesses and/or otheraffiliated entities acting on behalf of Jordan C.Grabef, M.D. or Jordan C. Brabel, M.D., P.A.,through any and all entities, including but not limited to defense law firms retained by infinity

Oct. 2, 2013 6:54I'IVI I'uster-IVlctjovern IIIo, 3/40 I'. 33

Insurance Company, or serving as private and/or in-house counsel for Infinity Insurance Company,and/or any other affiliated Defendant, first. party UM insurer or third party liability insurer(s) for theyears 2009, 2010, 201 1, 2012 and 2013 to-date.

THIS SUBPOENA REQUIRES PRODUCTION OF DQCUIIENTS

IT I8 THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITEII IIAY APPEAR TO THE PARTYTO WHOII THIS SUBPOENA IS DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surr'ender

the original items. YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEIIS TO BE PRODUCED TO THE ATTORNEY WHOSE NAIIE APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F,S,A,, you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TQ:

1 appear as specified, or2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,



CUSTER - IICGOVERN1602 10~ Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone; (561) 533-6650Facsimile: (561) 533-6863

HY

ANDY M. CUSTERFlorida Bar No.: 980341Email: Acuster8068)aol.corn.

Second Email; svlviaIecusterlawfl.corn

oct, 2, 2013 6:55PM Custer-McGovern No. 374cj P. 34

ADOLFO ROURA,

Plaintiff,

vs.




Defendants.

SUBPOENA DUCES TECUMN/iaiI-in Documents in I ieu nf Anne~renre)


TO: Records CustodianIntegon General Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COININANI3ED TG APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy IVI. Custer, Esp., 1602 10'" Avenue North, Lake@/orth, Florida 33460, on the 28™day of October, 2013, @11:30a.m., for the taking of yourdeposition in the above-styled cause.

ANI3 TG BRlNG WITH YGU, THE FGLLGWING:

1} Piaasa provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s} for Jordan C. Grabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 'I099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D,, P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Brabel, M D., by IntegonGeneral Insurance Company, for any medical/legal services or litigation, including but not limited

to'compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,oiaime orOOtiOn fOr~hepzo Anna nen1O nn11 ne1n

The response should include documentation of each payment made Integon General InsuranceCompany, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C. Grabel, M.D.,P.A., through any and all entities, including but not limited to defense Iaw firms retained by [ntegon

oct. 2. 2013 b,baal'IVI t'uster-IVfcbovern III o. 3/40

General insurance Company, or serving as private and/or in-house counsel for Integon GeneralInsurance Company', andior any other affiliated Defendant, first party UM insurer or third partyliability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.

THI8 8UBPOENA REQUIRES PRODUCTION OF DOCUIIENT8

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUNIENT BEPRODUCED, NG IIATTER HGW INSIGNIFICAN'T THAT ITEM INAY APPEAR TG THE PARTYTG WHOM THIS SUBPOENA IS DIRECTED, AND IS INEANT TG INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YGU MAY COIIPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES GF THE ITEMS TG BE PRODUCED TG THE ATTORNEY WHOSE NAIIE APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92 153 F S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena„and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAllTO'.

appear as specified„or2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YOU INAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.

Dated ~otober 12. 2013

CUSTER - MCGOVERN1602 10'venue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561}533-6650Facsimile: (561) 533-6853

BYANDY M. CUSTERFlorida Bar No.: 980341Email. [email protected]

Second Email; svlviaiicusterlawfl.corn

Uct. 2. 2{}l3 5:bbVM I;uster-IVIc(govern No, ) /4rJ I'. 35

ADQLFQ RQURA,

Plaintiff,

IN THE CIRCUIT COURT GF THENINETEENTH JUDICIAL CIRCUITIN AND FGR BT. LUCIE COUNTY,FLORIDA


KRIST[NA MICHELLE BRANA andRGSCGX CGRPQRATIGN, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DUCES TECUM{Mail-in Documents in Lieu of Appearance)

THE STATE GF FLORIDA:

TO; Records CustodianDirect General Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TO AP PEAR before a parson authorized by law to takedeposilions at CUSTER™MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Fiorida 33460, on the 2&'H day of October, 2013, @11:46a,m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012„and2013 to-date, for each payment made by'he company, or any affiliated

entity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN —66-034N40,

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature{retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. BRABEL, M.D., and/or JORDAN C. BRABEL,M.D., P.A. ancf/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Brabel, M.D., by Direct Beneralinsurance Company, for any medical/legal services or litigation, including but not limited to:compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, induding but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response shouid include documentation of each payment made Direct General InsuranceCompany, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M,D., P,A.and/or any related subsKliaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabal, M.D. or Jordan C. Brabel, M.D.,P.A., through any and all entities, including but not limited to defense law firms retained by Direct

Oct. 2. 20l3 6:56PM Custer-McGovern No. 3740 P. 37

General Insurance Company, or serving as private and/or in-house counsel for Direct GeneralInsurance Company, and/or any other affiliated Defendant, first party UM insurer or third partyliability insurer'(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.

THI8 SUBPOENA REQUIRES PRODUCTION OF DOCUMENT8

IT I8 THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUIIENT BEPRODUCED, NO IIATTER HOW INSIGNIFICANT THAT ITEII MAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA I8 DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMS TO BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE 8CHEDULED DATE OF PRODUCTION.You may corn ply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S,A., you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:

1.appear's specified, ol

2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YOU MAY BE IN CONTEIIPT OF COUR'f. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - MCGOVERN1602 10'"Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone'. (561) 533-6650Facsimile: (561) 533-6853

BYANDY M. CUSTERFlorida Bar No.: 980341Email. Acuster8068) aol.corn

Second Email: svlviaRcusterlawfl.corn

Oct, 2, 2013 6:56PM Custer-McGovern No. 3740 P. 38

ADQLFQ RQURA,

Plaintiff,

IN THE CIRCUIT COURT QF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY,FLQRIDA


KRISTINA MICMELLE RRANA andROSCQX CQRPQRATIGN, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DUCES TEGUNI(Mail-in Documents in Lieu of Appearance)


TO: Records CustodianNational General Insurance Companyc/o Florida Chief Financial OfficerP.G, Box 6200 (32314-6200)200 E. Baines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorized by law to takedeposiTions at CUSTER IVICGGVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 28™day of October, 2013, e 12:30 p.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Brabei, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Brabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099"s,cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. BRABEL, M.D,, and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by NationalGeneral Insurance Company, for any medical/legal services or litigation, including but not limitedto; compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not iimited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made National General InsuranceCompany, to the expert, JORDAN C. BRABEL, M.D., and/or JORDAN C. BRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Brabel, /VI.D. or Jordan C. Grabei, M.D.,P A., through any and all entities, including but not limited to defense Iaw firms retained by National

Uct. 2, 2013 b:5/VM Duster-Mcbovern No 3/40 V, 39

General Insurance Company, or serving as private and/or in-house counsel for National Generalinsurance Company, and/or any other affiliated Defendant, first party UM insurer or third partyliability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.


IT IS 'THE INTENT OF 'THIS SUBPOENA THAT EACH AND EVERY DOCUNIENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITENI MAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA I8 DIRECTED, AND IS MEANT TO INCLUDE ALI RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items YOU NIAY CGNIPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMS TO BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.163F.S,A,, you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above

IF YOU FAIL TO;




CUSTER - NICGOVERN1602 10'"Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone; (551) 533-6650Facsimile: (561) 533-6653

ANDY M. CUSTERFlorida Bar No.: 980341Email: Acuster806(Raol~m

Second Email. svlvlaHcusterlawfl.corn

Oct. 2. L0I3 6:57PM Custer-McGovern No, 3740 P. 40

ADOLFQ ROURA,

Plaintiff,

vs.




Defendants.

8UBPOENA DUCE8 TECUIN(Mail-in Documents in Lieu of Appearance)


TO: Records CustodianEnterprise Leasing Company of Floridac/o CT Corporation System1200 South Pine Island RoadPlantation, Florida 33324

YOU ARE HEREBY CQIIIIANOED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M, Custer, Esq,, 1602 10 Avenue North, LakeWorth, Florida 33460, on the 28'" day of October, 2018, @12:45p.m., for the taking of yourdeposition in the above-styled cause.

AND TQ BRING WITH YOU, THE FOLLOWING:

5) Pb aes nrnvirio Tsv iris ntifin*tinn payee nt hl)&rr&her (TlhJ) paV'm& nt r& mr'rim tnr th& y& are )nno.2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M,D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/fist thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRAHEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by EnterpriseLeasing Company of Florida, for any medical/legal services or litigation, including but not limitedto: compulsory or independent medical examinations, testimony at trial (whether in-person or byviciantar&a) henri/nr rior&r&citi*r&c. rarnrri ravivwe anri/nr aw&mther conti&-& c nrni&irt~rt ir& th&

medical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made Enterprise Leasing Companyof Florida, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D „P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabel, M,D. or Jordan G. Grabel, M.D.,P.A., through any and alf entities, including but not. limited to defense law firms retained byEnterprise Leasing Company of Florida, or serving as private and/or in-house counsel for

Oct. 2, 2013 6:5/PM Custer-McGovern No. 31443 P. 41

Enterprise Leasing Company of Florida„andior any other affiiiated Defendant, first party LJMinsureror third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.

TH18 SUBPOENA REQUIRES PRODUCTION OF DOCUMENTS

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUhlIENT BEPRODUCED„NO I!ATTER HOW INSIGNIFICANT THAT ITEII MAY APPEAR TG THE PARTYTG WHOII THIS SUBPOENA IS DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at lhat time. You will not be required to surrenderthe original items. YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES GF THE ITEMS TO BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEAR8ON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.163F.S.A,,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAiL TG:


YOU IIAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - MCGOVERN1602 10~ Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone; (M1) 533-6650Facsimile: (661) 533-6853

BYANDY M. CUSTERRorida Bar No.; 980341Email: Acustere06&aol.corn

Second Email: svlvia(acusterlawfl.corn

Oct. 2. 2t313 6,58PM Custer-McGovern No. 3740 P. 42

ADOLFO ROURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LVCIE COUNTY,FLORIDA


KRISTINA MICHELLE BRANA andROSCOX CORPORATION, a Florida Corporation,jointly and severally„

Defendants.

SUBPOENA DUCES TECUM(Mail-in Documents in Ueu of Appearance)


TO: Records CustodianEnterprise Leasing Company of Orlando LLCc/o CT Corporation System1200 South Pine Island RoadPlantation, Florida 33324

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq,, 1602 10'" Avenue North, LakeVVarth, Florida ea4eO, on &ha '&p " d»&y of ~otei&o&& &pgQ& I, g:pp p.rn., for )he:-i-:na "& y"..."deposition in the above-styled cause.

AND TQ BRING WITH YQV, THE FOLLOWING:


2) As to Jordan C Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C, GRABEL, M.D., and/or JORDAN C. BRABEL,M D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by EnterpriseLeasing Company of Orlando, LLC, for any medical/legal services or litigation„ including but notlimited to. compulsory or independent medical examinations, testimony at trial (whether in-personor by videotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made Enterprise Leasing Companyof Orlando, LLC, to the expert, JORDAN C. GRA8EL, M.D., and/or'ORDAN C. GRABEL, M.D.,P.A. and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.erabel, M D, or Jordan C Brabel„M.D.,P.A.„through any and all entities, including but not limited to defense law'irms retained byEnterprise Leasing Company of Orlando, LLC, or serving as private and/or in-house counsel for

oct. 2. 2JJ13 b:bbf'M t'utter-McGovero No, 3 j'40 I', 43

Enterprise Leasing Company of Orlando, LLC, and/or any other affiliated Defendant, first party UMinsurer or third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date,

THIS 8UBPOENA REQUIRES PRODUCTION OF DOCUMENTS

IT l8 THE INTENT OF THIS 8UBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO NIATTER HOW INSIGNIFICANT THAT ITEM MAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA IS DIRECTED, ANI3 IS MEANT TO INCLUDE ALL RECORD8REQUE8TFD,

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES GF THE ITEMS TO BE PRODUCED TO THE ATTORNEY WHOSE NAINE APPEARSON THIS SUBPOENA BELOW ON GR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theatlorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:

1.appear aa specified, or2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YOU NIAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the atlorney or the Court,you shall respond to this Subpoena as directed.

Dated. October 12. 2013

CUSTER MCGOVERN1602 10 Avenue NorthLake VVorth, Florida 33460Attorney for PlaintiffTelephone. (561) 533-6650Facsimile: {56'I) 533-6853

BY:ANDY M. CUSTERFlorida 8ar No.; 980341Email: Acuster806tRaol.corn

Second Email svlvia{Scusterlawfl.corn

oct. 2, 2013 6:5ctPM Custer-McGovern No. 3740 P. 44

ADQLFO RQURA,

Plaintiff,



KRISTINA MICHELLE BRANA andRQSCQX CORPORATION, a Florida Corporation,jointly and severally,

Defendants,

SUBPOENA DUCES TECIJM(Mail-in Documents in Lieu of Appearance)

THE STATE QF FLORIDA'.

TQ. Records CustodianEnterprise Leasing Company of South Central LLCc/o CT Corporation System1200 South Pine Island RoadPlantation, Florida 33324

YOU ARE HEREBY CONINIANDED TO APPEAR before a person authorized by Iaw to takedepositions at CUSTER-MCGOVERN„Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 28™day of October, 2013, {81 I5 p.m., for the taking of yourdeposition in the above-styled cause.

AND TO BRING I/I/ITH YOU, THE FOLLOWING:

1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date„ for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Brabel, M D,including but not limited to TIN —65-0340540.

2) As to Jordan C. Grabef, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JQRDAN C. GRABEL, M.D,, and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by EnterpriseLeasing Company of South Central, LLC, for any medical/legal services or litigation, including butnot limited to.'ompulsory or independent medical examinations, testimony at trial (whether in-person or by videotape) and/or depositions, record reviews and/or any other services provided inthe medical/legal fields, regardless of whether a report waa issued, including but not limited tocases, claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

rho roeponeo shou)d inoludo dooumantation of a@oh paymanimad- C;.e-;prdi-- L-q-i;,a O-.—..pg;,"of South Central, LLC, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. andlor any related subsidiaries, corporations, professional associations, interests,businesses and/or other affiliated entities acting on behalf of Jordan C,Grabel, M.D. or Jordan C.Grabel, M.D., P.A., through any and aff entities, including but not limited to defense law firmaretained by Enterprise Leasing Company of South Central, LLC, or serving as private and/or in-

Oct, 2. 3II13 6: 59I'M E;ust e r-fVlc(iove rrt No 3/4U I', 4b

house counsel for Enterprise Leasing Company of South Central„LLC, andior any other affiliatedDefendant, first party UM insurer or third party liability insurer(s) for the years 2009, 2010, 2011,2012 and 2013 to-date.

THIS SUBPOENA REQUIRES PRODUCTION OF DIOCUMENTS

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUIIENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITEM 6l1AY APPEAR TG THE PARTYTO WKONI THIS SUBPOENA IS DIRECTED, AND IS IIEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspeCted andmay be COpied at that time. YOu Will nOt be required to surrenderthe original items, YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEhl!S TO BE PRODUCED TG THE ATTORNEY WHOSE NAIIE APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TG:


YOU IIAY BE IN CONTEIIPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - MCGOVERN1602 10'venue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 633-6650Facsimile (561) 533-6853

eYANDY M. CUSTERFlorida ear No.: 980341Email: Acuster806(maol.c~m

Second Email: svlviaticusterlawfl.corn

Oct. 2. 20L3 7:OIPM Custer-McGovern !I!o, 2141 P. 2/45

ADQLFO ROURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINCTCCNTl I

JUDICIAL

~tr~CVITIN AND FQR ST. LUCIE COUNTY,FLORIDA


KRIGTINA MICHELLE BRANA andRQSCQX CORPORATION, 8 Florida Corporation,jointly and severally,

Defendants.3 3G'!3

I j!

NOTICE GF PRODUCTION FROM NGN-PARTY

YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service ofthis notice, if service is by hand-delivery andlor facsimile, or fifteen (15) days from the dateof service, if service is by mail, and if no objection is received from any party, theundersigned will issue or apply to the Clerk of this Court for issuance of the attac edsubpoena directed to;

Farmers Specialty insurance Company5600 Beech Tree LaneCaledonia, Ml 49316

2. Florida Farm Bureau Casualty Insurance Company6700 SW 34~ StreetGainesviile, FL 32608

3. Florida Farm Bureau General insurance Company5700 SW 34'" StreetGainesville, FL 32608

4. Liberty Mutual Fire insurance Company2000 VVestwood DriveNfestwood, Wl 54401

5. Liberty Mutual Insurance Company175 Berkeley StreetMS 10BBoston, MA 02116

Uct, 2. 2013 /:cJli'll/i (;uster-lj/Icbovern No, 3/41 I'. 3/4b

6. Chartis Property Casualty Company175 Water StreetNew York, NY 10038

7. Travelers Casualty and Surety CompanyOne Tower SquareHartford, CT 06183

8. Travelers Casualty insurance Company of AmericaQne Tower SquareHartford, CT 06183

9. The Travelers Indemnity Company of ConnecticutOne Tower SquareHartford, CT 06183

10. The Travelers Indemnity Company of AmericaQne Tower SquareHartford, CT 06183

who is/are not a party, to produce the items listed in the Subpoena at the time and place specifiedtherein.


l HEREBY CERTIFY on this 2nd day of October, 2013, that a true and correct copy of

the foregoing has been electronic mail (email} at designation: eservice8)wlclaw.corn, AI3AM

GUZI, ESQ., Williams, Leininger 8 Cosby, P.A., 50 E. Ocean Blvd., Suite 4203, Stuart„FL

34994, and I have electronically filed the foregoing with the Clerk of St Lucie County by using

the Florida Courts e-Filing Portal.

CUSTER NIGGOVERN602 10'" Avenue North

Lake Worth, Florida 33460Attorney for PlaintiffTelephone. (561) 533-6650Facsimile; (561) 533-6853

is/ Andy M. Custer

ANDY M. CUSTERFlorida Bar No.: 980341Email Acuster806Imaol,rom

Second Email: svlvia(Rcusterlawfl. corn

Uct. 'l. 2013 /:JJ1I'IVI I'Ljster-IVIcboveln No, 3/41 I', 4/45

ADOLFO RQURA,

Plaintiff,

IN THE CIRCUIT CQURT QF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY,FLORIDA


KRISTINA MICHELLE BRANA andRQSCQX CORPORATION„a Florida Corporation,jointly and severaIIy,

Defendants,



To. Records CustodianFarmer's Specialty Insurance Companyc/o Florida Chief Financial OfficerP.Q. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COIINIANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 29'" day of October, 20"l3, @10".00a.rn., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and alf documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.},which state/show/list thetotal amount of fees for services paid to JORDAN C. GRA8EL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D, by Farmer'Specialty Insurance Company, for any medical/legal services or litigation, induding but not limitedto. compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date

The response should include documentation of each payment made by Farmer's SpeciaityInsurance Company to the expert, JORDAN C. GRABEL, IVI.D, and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses and/or other affiliated entities acting on behalf of Jordan C.Grabei, M.D. or Jordan C.Grabel, M D, P.A., through any and all entities, including but not limited to defense law firms

Oct. 2. 2013 7:02PM Custer-McGovern No. 3741 P. 5/45

retained by Farmer's Specialty Insurance Company, or serving as private and/or in-house counselfor Farmer's Specialty insurance Company„andior any other affiliated Defendant, first party UM

insurer or third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.


IT 18 THE INTENT GF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITEN'IAY APPEAR TO THE PARTY

TO WHOM THIS SUBPOENA IS DIRECTED, AND IS IIEANT TO INCLUDE ALL RECORDSREQUESTED.

The*a~ its m~ will hc w~pc rh rf ~nrl rnsay hc mr ir 8 ~k ths6 firn'ar r rwill oui hc e rit &irorl tn e &rranrler

the original items. YOU IIAY COIIPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEINS TO BE PRODUCED TO THE ATTORNEY WHOSE NAIIE APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.'I53 F,S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to the


If YOU FAIL TO:


YOU MAY BE IN CGNTEIIPT GF 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,



CUSTER - IICGOVERN1602 10'venue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile; (561) 533-6853

ANDY M. CUSTERFlorida Bar No.: 980341Email. Acuster806(gaol mg

Second Email; sviviatRcusterlawfl.corn

rJct, 2, 2II13 I:IjZI'M Custer-Mcbovern &o, S/4~

ADGLFO RQURA,

Plaintiff,



KRISTINA MICHELLE BRANA andROSCOX CORPORATION, a Florida Corporation,jointly and severaily,

Defendants.



TO: Records CustodianFlorida Farm Bureau General Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Baines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMIIANI3ED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M, Custer, Esq., 1602 10'venue North, LakeNforth, Florida 33460, on the 29'" day of October, 2018, @10:16a.m., for the taking of yourdeposition in the above-styled cause.

AND TO BRING NfITH YOU, THE FOLLOWING:

1} Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliated

entity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Brabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Brabel, M.D, please provide any and ail documents of any kind or nature(retainer agreements, IRS For'rn 1099's, canceIIed checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M,D., and/or JORDAN C. GRABEL,M.D, P.A and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by Florida FarmBureau General Insurance Company, for any medical/legal services or litigation, including but notlimited to: compulsory or independent medical examinations, testimony at tria( (whether in-personor by videotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Florida Farm BureauGeneral Insurance Company to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C.GRABEL, M.D., P.A. and/or any related subsidiaries, corporations, professional associations,interests, businesses and/or other affiliated entities acting on behalf of Jordan C.Brabel, M.D. orJordan C. Brabel, M.D, P.A.„through any and all entiiies, including but not limited to defense Iaw

Oct. 2, 2cJ13 /:rJ]i'Vl Custer-IVlcUovern 4o. 3 i41 I'. il45

firms retained by Florida Farm Bureau General Insurance Company, or serving as private andlorin-house counsel for Florida Farm Bureau General insurance Company, andlor any other affiliatedDefendant, first party UM insurer or third party liability insurer(s) for the years 2009, 2010, 2011,2012 and 2013 to-date.


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EYERY DOCUMENT BEPRODUCED, NO IIATTER HOW INSIGNIFICANT THAT ITEII MAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA IS DIRECTED, AND IS IIEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAY COMPLY WITH TH)8 SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEIIS TO BE PRODUCED TO THE ATTORNEY WHOSE NAIIE APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies 'to 'the


IF YOU FAILTO'.

appear as specified, or2. furnish the records instead of appearing as provided above, or3. object to this Subpoena,



CUSTER - MCGOVERN1602 10'" Avenue NorthLake Nforth, Florida 33460Attorney for PlaintiffTelephone. {561)533-6650Facsimile; {561)533-6853

ANDY M. CUSTERFlorida Bar No.: 980341Email: Acuster806(Saoi.corn

Second Email: svlviaN)custerlawfl.corn

Oct. 2. 2013 7,tj3PM Custer-McGovern No, 3741 P. 8/45

ADOLFO RQURA,

Plaintiff,

vs.


CASE NO,: 12CA002123

KRISTINA MICHELLE BRANA andRGSCGX CGRPGRATiGN, a Florida Corporation,jointly and severally,

Defendants.



TO: Records CustodianFlorida Farm Bureau Casualty Insurance Companyc/o Florida Chief Financial OfficerP.G. Box 6200 {32314-620Q)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COINMIANDED TO APPEAR before a person authorized by Iaw to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 29'" day of October, 2013, @10:30a.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (T)N) payment records for the years 2009,201Q, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliated


2) As to Jordan C. Grabel, M,D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1Q99's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. BRABEL,M.D., P,A, and/or ariy related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by Florida FarmBureau Casualty insurance Company, for any medical/legal services or litigation, including but not

limited to: compulsory or independent medical examinations, testimony at trial {whether in-personor by videotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009„2010,2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Florida Farm BureauCasualty Insurance Company to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C.(3ptADEL, M.D., r .A. csrnlfvt ariy )alalau aubakliariea, vvrpvraiivna, prvfeoaivnai avva~ietiune,interests, businesses and/or other affiliated entities acting on behalf of Jordan C.Brabel, M.D. orJordan C. Grabei, M.D., P.A., through any and ail entities, including but not limited to defense law

Oct, 2. 2013 7:03PM Custer-McGovern IIo. 3741 P. 9/45

firms retained by Florida Farm Bureau Casualty insurance Company, or serving as private and/orin-house counsel for Florida Farm Bureau Casualty Insurance Company, and/or any other affiliatedDefendant, first party UM insurer or third party liability insurer(s} for the years 2009, 2010, 2011,2012 and 2013 to-date.


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITEM IIAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA IS DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQLIESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU lVIAY COIIPLY WITH THIS SUBPOENA HY PROVIDING LEGIBLECOPIES GF THE ITEIIS TO BE PRODUCED TO THE ATTORNEY WHOSE NAIIE APPEARSGN THIS SUBPOENA BELOW GN OR BEFORE THE SCHEDULED DATE OF PRODUCTIONYou may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mall or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YGU FAIL TO;


YOU IlhAY BE IN CONTEMPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,



CUSTER - MCGOVERN1602 10~ Avenue NorthLake N/orth. Florida 33460Attorney for PlaintiffTelephone'561} 533-6650Facsimile; (561}533-6853

ANDY IVI. CUSTERFlorida Bar No.; 980341Email: Acuster806teaol.corn

Second Email: svlvia8)custerlawfl.corn

Oct, 2. 2013 /:04VIVI t;uster-IVIcbovern IIIo. 3/41 I', 10/4b

ADQLFO ROURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST, LUCIE COUNTY,FLORIDA

CASE NO.; 12GA002123


Defendants.

SUBPOENA DUCES TECUM(Mail-ln Documents in Lieu of Appearance)

THE STATE QFFLORIDA'O:

Records CustodianLiberty Mutual Fire Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY CQIIhllANDED To APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 29™day of October, 2013, @10:45a.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Brabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C, Grabel, M.D,, please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledger's, etc.), which state/show/liat thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,MD., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by Liberty MutualFire Insurance Company, for any medical/legal services or litigation, including but not limited to:compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Liberty Mutual FireInsurance Company to the expert, JORDAN C BRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses and/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan G.Grabel, M.D,, P.A., through any and all entities, including but not limited to defense law firms

Uct. 2. 2013 /:UPI'IVI Custer-IVlc(icvern Iio. 3/91 I'. 11/4h

retained by Liberty Mutual Fire Insurance Company, or serving as private and/or in-house counselfor Liberty Mutual Fire Insurance Company, and/or any other affiliated Defendant, first party UM

insurer or third party liability insurer(s} for the years 2009, 2010, 2011, 2012 and 2013 to-date.

THIS SUBPOENA REQUIRES PRGDIJC'TION OF DOCUMENTS

IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NQ MATTER HOW INSIGNIFICANT THAT ITEM MAY APPEAR TO THE PARTY

TO NIHOmi THIS SUBPOENA Is DIRECTED, AND I8 MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be r'equired to surrender

the original items, YOU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMS TO BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.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.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may'ail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at the

time and place specified above.

IF YOU FAILTO'.


YGU MAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,



CUSTER - MCGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561}533-6650Facsimile: (561}533-6853

BYANDY M. CUSTERFlorida Bar No.: 980341Email: [email protected]

Second Email. Sylvia(mcusterlawfl.corn

Oct. 2. 2013 7:05PM Custer-McGovern No, 3741 P. 12/45

Plaintiff,

IN THE CIRCUIT COURT GF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY,FLORIDA



Defendants./



TG; Records CustodianLiberty Mutual insurance Companyc/o Florida Chief Financial OfficerP.Q. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE I-IEREBV COII/III/IANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy IVI, Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 29™day of October, 2013, @11:00a.rn., for the taking of yourdeposition in the above-styled cause.

AND TO BRING WITH YOU, THE FOLLON/ING:

1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabai, M D,including but not limited to TIN —65-0340540.

2} As to Jordan C. Gr'abel, M.D., please provide any and all documents of any kind or nature(ratainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D,, and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corpor'ations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by Liberty MutuaiInsurance Company, for any medical/legal services or litigation, including but, not limited to.compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made by Liberty Mutual InsuranceCompany to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A.and/or anv related subsidiaries, corooratlons, professional associations. interests. businessesand/or other affiliated en'tities acting on behalf of Jordan C.Grabel, M D. or Jordan C. Qrabel, IVI,D.,

P.A., through any and all entities, including but not limited to defense law firms retained by Liberty

Oct. 2. 20]3 7:05PM Custer-McGovern No. 374l P, I3/45

Mutual Insurance Company, or serving as private arid/or in-house counsel for Liberty MutuaiInsurance Company, and/or any other affiliated Defendant, first party UM insurer or third partyliability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUINENT BEPRODUCED, NG INATTER HOW INSIGNIFICANT THAT ITEM IIAY APPEAR TO THE PARTYTO WHGII THIS SUBPOENA I8 DlRECTED, AND 18 INEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU INAY COMPLY WITH THI8 SUBPOENA BY PROVIDING LEGIBLECOPIES GF THE ITEII8 TO BE PRODUCED TO THE ATTORNEY WHOSE MAINE APPEARSON THIS SUBPOENA BELOW GN OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legibie copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theGHOt ABQ Wh999 nQll1C- ClpPCQI C'n il li8 ~U~pGOI IGI Bl i%A il IVI V J Oill I lil IHLCf J'QUL BppVQi CRI ~ QO CXl tl IO

time and place specified above.

IF YOU FA)L TO:

1.appear as specified, or2. furnish the records instead of appearing as provided above, or3, object to this Subpoena,

YOU IIAY BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappems on thie GubpOena, and unleSS eXCuSed fram thiS 5ubpcena by tne attOrney Or the C Ourt,


Dated: October l2, 2013

CUSTER - MCGOVERN1602 10~ Avenue NorthLake Nforth, Florida 33460Attorney for PlaintiffTelephone'(561) 633-6650Facsimile; (661) 533-6853

BYANDY M, CUSTERFlorida Bar No: 980341Email: Acuster806(Raol.corn


Oct. 2, 2II13 /: OIVM I;us t e I-Mcbove rn No. 3/41 V. 14/4b

ADOLFO ROURA,

Plaintiff,


CASE NO.: 12CAQQ2123

KRIST[NA MICHELLE BRANA andROSCOX CORPORATION, a Florida Corporation,|ointly and severally,

Defendants.

SUSPOENA DUCES TECVIN(Mail-in Documents in Lieu of Appearance)

THE STATE OFFLORIDA'O:

Records CustodianChartis Property Casualty Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COIII[IIANDED TG APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33480, on the 29™day of October, 2013, @11 !6a.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabef, M.D.,including but not limited to TIN - 65-0340540

2) As to Jordan C. Grabel, IVI,D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel„M D., by ChartisProperty Casualty Company, for any medical/legal services or litigation, including but not limitedto: compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response shou[d include documentation of each payment made Chartis Property CasualtyCompany to the expert„JORDAN C. GRABEL, M.D., and/'or JORDAN C. GRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affi[iated entities acting on behalf of Jordan C.Grabe[, M.D. or Jordan C. Grabel, M.D.,P.A., through any and all entibes, including but not limited to defense law firms retained by Chartis

Oct, 2. 2Q13 7:06PM Custer-McGovern tIo. 3741 P. 15/45

Property Casualty Company, or serving as private and/or in-house counsel for Chartis PropertyCasualty Company, andfor any other affiliated Defendant, first party UM insurer or third partyliability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date,


IT I8 THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUIIENT BEPAAOUf EO. MD NIATTER HAIKU IhlQIAMIPICAMT THAT ITDIUI lNAY APPIAN TO TW4 PARTYTO WHOM THIS SUBPOENA I8 DIRECTED, AND 18 IIEANT TO INCLUDE ALL RECORDSREQUESTED,

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAV COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEM8 TO BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEARSON THIS 8UBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTIONYou may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts Incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:


YOU IIAV BE IN CONTEMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed,

Dated October 12, 2013

CUSTER - MCGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile: {561)533-6853

eYANDYM CUSTERFlorida Bar No.; 980341Email: [email protected]

Second Email: svivia@custerlawfl,corn

Oct. 2. 2013 /:UbI'Iii Custer-Mcbovern No. 3/41 I'. 16/4b

ADQLFQ RQVRA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LVCIE CQUNTY,FLORIDA

CASE NQ '. 12CA002123

KRISTINA MICHELLE BRANA andRQSCQX CQRPQRATIQN, a Florida Corporation,jointly and severally,

Defendants.



TO: Records CustodianTravelers Casualty and Surety Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-8200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMIIANI3ED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M, Custer, Esq, 1602 10" Avenue North, LakeWorth, Fiorida 33460, on the 29~" day of October, 2013, @11;39a.m., for the taking of yourdeposition in the above-styled cause.

AND TO BRING WITH YOU, THE FOLLOI/ING:

1) Please provide Tax identification Pay'ment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M,D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C, Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099"s,cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M D., and/or JORDAN G. GRABEL,lVI.D., P,A, and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C, Grabel, M.D.„byTravelersCasualty and Surety Company, for any medical/legal services or litigation, including but not limitedto. compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 20'I0, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made Travelers Casualty and SuretyCompany to the expert, JORDAN C. GRABEL, M.l3., and/or JORDAN C. GRABEL, M D., P A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting onbehalfof Jordan G.Grabel, M.D. or Jordan C. Grabel, M.D.,P,A., through any and all entities„ including but not limited to defense law firms retained by

Oct. 2, 2013 7:07PM Custer-McGovern No. 3741 P, 17/45

Travelers Casualty and Surety'ompany, or serving as private and/or in-house counsel forTravelers Casualty and Surety Company, and/or any other affiliated Defendant, first party UM

insurer or third party liability insurer(s) for the years 2009, 2010, 2011, 201 2 and 2013 to-date.

THIS SUBPOENA REQUIRES PRODUCTION GF DOCUMENTS

ll'S THE INTENT GF THIS SUBPOENA THAT EACH AND EVERY DQCUIIENT BEPRODLI{ ED NO toiATTEP HQRf }MQIQ fdlFICANT THAT ITEliil MAy APPLAP Tn Tui= PARTyTG WHGII THIS SUBPOENA IS DIRECTED, AND IS INEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time, You will not be required to surrenderthe original items. YOU IIAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEM8 TO BE PRODUCED TO THE ATTORNEY WHOSE NAIIE APPEARSON THIS 8UBPOENA BELO'W ON OR BEFORE THE SCHEDULED DATE OF PRODUCTIONYou may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F.G.A.,you are entitled to reimbursement of reasonablecoctc incurred in ~roducina the docurnente er&ecified herein. Pleoee include your regueet. forreimbursement of costs along with the documents. You may mail or deliver the copies to the


IF YOU FAIL TO".


YOU IIAY BE IN CONl'EMPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall i.espond to this Subpoena as directed.

Dated ~Otober 12, 2013

CUSTER - IICGGVERN1602 10~ Avenue North

Lake Worth, Florida 33460Attorney for PlaintiffTelephone; (561) 533-6650Facsimile: (561) 533-6853

BYANDY M. CUSTERFlorida Bar No.: 980341Email. Acuster806{gaol,corn

Second Email; svlvia{mcusterlawfl.corn

Oct, 2. 2013 7:07PM Custer-McGovern No. 3741 I'. 18/45

ADQLFQ RQtJRA,

Plaintiff,



KRISTINA MICHELLE BRANA andROSCQX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

8UHPGENA DUCES TECUII(Mail-in Documents in Lieu of Appearance)


TQ; Records CustodianTravelers Casualty Insurance Company of Americac/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahacemm r:lnrirln %9%0o

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorizedby law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 28'" day of October, 2013„@11:45a.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 201'I, 2012, and 2013 to-date, for each payment made by the company, or any affiliated

entity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.I3.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRH Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRASEL, M.D., and/or JORDAN C. GRASEL,M D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C, Grabef, M,D, by TravelersCasualty Insurance Company of America, for any medical/legal services or litigation, including butnot limited to: compulsory or Independent medical examinations, testimony at trial (whether in-

person or by videotape) and/or depositions, record reviews and/or any other services provided in

the medical/legal fields, regardless of whether a report was issued, inciuding but not limited tocases, claims or actions for the years 2009, 2010, 2011, 2012 and 20'I3 to-date,

The response should include documentation of each payment made Travelers Casualty insuranceCompany of America to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D.. P.A. and/or any related subsidiaries, corporations, professional associations~r~stsbusinesses and/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C.Grabel, M,D., P.A., through any and all entitles, including but not limited to defense law firms

Oct. 2. 2I)13 7: OBPM Custer-McGovern No. 374 l P. l 9/45

retained by Travelers Casualty insurance Company of America, or serving as private and/or in-

house counsel for Travelers Casualty Insurance Company of America, and/or any other affiliatedDefendant, first party UM insurer or third party liability insurer(s) for the years 2009, 2010, 2011,20'l2 and 2013 to-date.


IT IS THE INl'ENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUIIENT BEPRODUGED, NO NIATTER HOW INSIGNIFICANT THAT ITEII IIAY APPEAR TO THE PARl YTO WHOM THIS 8UBPOENA IS DIRECTED, AND IS NIEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrender0're Urigirral iterrrs. YOU IIAY CONIPLY WITH THIS SUBPOENA SY PROVIDING LEGIBLECOPIES OF THE ITEIIS TO BE PRODUCED TO THE ATTORNEY WHOSE NANIE APPEARSON THIS SUBPOENA BELOW'N OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theettomoy whooa name appoaro on thio Gubpeena en er before the eehedu(od data of praduation.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby'liminate your appearance at thetime and place specified above.

IF YOU FAIL TO:


YOU NIAY BE IN CONTENIPT OF COURl'. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - INCGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile: (561}533-6853

ANDYM CUSTERFlorida Bar No.: 980341Email: Acuster806CSaol.corn

Second Email. svlvialicusterlawfl,corn

Oct. 2, 2013 /:0III'M Custer-Mcgovern Na. 3/41 I'. 20/4b

ADQLFQ RQURA,

Plaintiff,



KRISTINA MICHELLE BRANA andROSCQX CORPORATION, a Florida Corporation,jointly and severally,

Defendants,


THE STATE OF FLORIDA

TO: Records CustodianThe Travelers indemnity Company of Connecticutclo Florida Chief Financial OfficerP.O. Box 6200 {32314-6200)200 E. Baines StreetTal) ahassee, Florida 32399

YOU ARE HEREBY COIIMANDED TOAPPEAR before a person authorizedby law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North„LakeWorth, Florida 33460, on the 29'" day of October, 2013, @12:80p,m., for the taking of yourdeposition in the above-styled cause.

AND TQ BRING WITH YOU, THE FOLLOWING:

"I) Please provide Tax identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s} for Jordan C. Brabel, M.D.,Including but not limited to TIN - 65-0340540.

2) As to Jordan C. Brabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. BRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entitles acting on behalf of Jordan C. Grabel, M.D., by The TravelersIndemnity Company of Connecticut, for any medical/legal services or litigation, including but notlimited to. compulsory or independent medical examinations, testimony at trial (whether in-personor by videotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment The Travelers Indemnity Companyof Connecticut to the expert, JORDAN C. BRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Brabel, M.D or Jordan C. Brabel, M.D.,P.A., through any'nd all entities, including but not limited to defense law firms retained by The

uct, Z. 2U13 /:UUl'iI/i Coster-IVlcGovern No. 3/41 I', 21/4b

Travelers indemnity Company of Connecticut, or serving as private and/or in-house counsel foi TheTravelers Indemnity Company of Connecticut, and/or any other affiliated Defendant, first party UMinsurer or third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date,


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HQW INSIGNIFICANT THAT ITEM MAY APPEAR TQ THE PARTYTO WHOM THIS SUBPOENA I8 DIRECTED, AND IS MEANT TQ INCLUDE ALL'ECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAY CQIIPLY WITH THIS SUBPOENA BY PRQVIDING LEGIBLECOPIES OF THE ITEMS TO BE PRODUCED TQ THE ATTORNEY WHOSE NAME APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.'i 53 F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YQU FAIL TO:




CUSTER - MCGOVERN1602 10'"Aver ue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone (56'I) 533-BB50Facsimile; (561) 533-6853

BYANDY M. CUSTERFlorida Bar No.; 980341Email: Acuster8066)aol.corn

Second Email. svlviaAcusterlawfl.corn

Oct, 2. 2013 7:09PM Custer-McGovern No. 3741 P, 22/45

ADQLFO RQURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN ANI3 FQR ST. LUCIE COUNTY,FLORIDA

CASE NO.; IzCAooz-Iz~

KRISTINA MICHELLE BRANA andRQSCQX GQRPQRATIQN, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DUCES TECUNl(Mail-in Documents in Lieu of Appearance)


TQ; Records CustodianThe Travelers Indemnity Company of Americac/o Florida Chief Financial OfficerP.Q. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COIIIlANDED TG APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 29 "day of October, 2013,I 12:45 p.m., for the taking of yourdeposition in the above-styled cause.


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN —65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JQRI3AN C. GRABEL, M.I3., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C Grabel, IVI,D,, by The TravelersIndemnity Company ofAmerica, for any medical/(egal services or litigation, including but not limited

to.'ompulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedicalflegal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment The Travelers indemnity Companyof America to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabel, IVI.D. or Jordan C. Brabel, M.D.,P.A., through any and all entities, including but not limited to defense law firms retained by The

Uct. 'l. 2U13 /:U9l'M UIjster-Mcgovern No. 5/41 I'. 'ldi45

Travelers indemnity Company of America, or serving as private and/or in-house counsel for TheTravelers indemnity Company of America, and/or any other affiliated Defendant, first party UMinsurer or third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO NIATTER HGW INSIGNIFICANT THAT ITEMI INAY APPEAR TO THE PARTYTO YNGM THIS SUBPOENA l8 DIRECTED, AND IS NIEANT TG INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may ba copied at that time, You will not be required to surrenderthe original items. YGU INAY CGNIPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEINB TG BE PRODUCED TO THE ATTORNEY WHOSE NANIE APPEARSON THIS Suer OENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION,You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this subpoena on or before the scheduled date of production.


IF YGU FAIL TO:


YOU INAY BE IN CGNTEINPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - NICGOVERN1602 10~ Avenue Morth

Lake Worth, Florida 33460Attorney for PlaintiffTelephone. (561) 533-6650Facsimile: (561) 633-6853

BYANDY M. CUSTERFlorida Bar No.: 980341Email. Acusterwsajaol.corn.

Second Email; svlvia(Scusterlawfl.corn

Uct. 2. 2U13 /:lUI'M Duster-Mcgovern &o, &&S1

ADOLFO ROURA,

Plaintiff,

VS.

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL ClRCUITIN AND FOR BT. LUCIE COUNTY, .

FLORIDA


KRISTINA MICHELLE BRANA andRGSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

NOTICE OF PRODUCTION FROM NON-PARTY

YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service ofthis notice, if service is by hand-delivery and/or facsimile, or fifteen (15)days from the dateof service, if service is by mail, and if no objection is received from any party, theundersigned will issue or apply to the Clerk of this Court for issuance of the attachedsubpoena directed to:

1. The Travelers Indemnity Co.One Tower SquareHartford, CT 06183

2. Travelers Commercial insurance CompanyOne Tower SquareHartford, CT 06183

3. Arnica Mutual Insurance CompanyOne Hundred Arnica WayLincoln, Rl 02865

4. Allstate insurance Company2775 Sanders RoadNorthbrook, IL 60062

5. Castle Key Insurance Company780 Carillon ParkwaySt. Petersburg, Fl 32716

Uct. 2 )Ulcc I:lUI'IVI Uoeter-IVic(iovern No, 3 i'll I'. 2b/4b

6. State Farm General Insurance CompanyOne State Farm PlazaBloomington, IL 61?10-0001

7. State Fare Fire and Casualty CompanyOne State Farm PlazaBloomington, IL 61710-0001

8. State Farm Mutual Automobile Insurance CompanyOne State Farm PlazaBloomington, IL 61710-0001

9. State Farm Florida Insurance Company7400 Cypress Gardens BlvdVVInter Haven, Fl 33888

10. Government Employees Insurance Company5260 Western AveChevy Chase, MD 20815

who islare not a party, to produce the items listed in the Subpoena at the time and placespecified therein.

CERTIF ICATE OF SERVICE

I HEREBY CERTIFY on this 2ncl day of October, 2013, that a true and correct copy of the

foregoing has been electronic mail (email) at designation eservice(Rwlclaw.corn, ADAM GUZ[,

ESQ., Williams, Leininger 8 Cosby, P.A., 60 E. Ocean Blvd,, Suite 0203, Stuart, FL 34994, and [

have electronically filed the foregoing with the Clerk of St Luc(e County by using the Florida Courts

e-FIIIng Portal.

CUSTER - MCGOVERN1602 10'"Avenue NorthLake Worth, Florida 33460Attorney for PlaintiFf

Telephone: {561)533-6650Facsimile. (561) 533-6853

Isl Andy M. CusterBY

ANDY M. CUSTERFlorida Bar No.: 980341Email: Acuster806@aoi,corn


Uct. 2. 2rJ13 /;lrJVM (;ueter-Mcgovern IIIo. 3/41 V, 2b/4b

ADQLFQ RQURA,

Plaintiff,




Defendants.

SUBPOENA DUCES TECUII(Mai)-in Documents in Lieu of Appearance)

THE STATE QFFLQRiDA.'Q:

Records CustodianThe Travelers Indemnity Co.c/o Florida Chief Financial OfficerP.O. Box 6200 (32314-8200)200 E. Galnas StreetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33480, on the 28'" day of October, 2013, I 8.30 a.rn., for the taking of yourdeposition in the above-styled cause.

ANl3 TG BRING WITH YOU, THE FOLLOW/ING:

1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Brabal, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Brabel, M.D., please provide any and all documents of any kind or natura(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JQRDAN C. 8RABEL, M.D, and/or JQRDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C, Grabel, M.D., by The Travelers

Indemnity Co., for any medical/iegal services or litigation, including but not limited to. compulsoryor Independent medical examinations, testimony at trial (whether in-person or by videotape) and/ordepositions, record reviews and/or any other services provided in the medical/legal fields,regardless of whether a report was issued, including but not limited to cases, claims or actions forthe years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should Include documentation of each payment made The Travelers Indemnity Co,to the expert, JQRDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A. and/or anyrelated subsidiaries, corporations, professional associations, interests, businesses and/or otheraffiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C. Grabel, M,D., P.A.,through any and all entities, including but not limited to defense law firms retained by The Travelers

Oct, 2, 2013 7:11PM Custer-McGovern IIo. 3741 P. 27/45

Indemnity Co, or serving as private and/or in-house counsel for The Travelers indemnity Co.,and/or any other affiliated Defendant, first party UM insurer or third party liability insurer(s} for theyears 2009, 20"l0, 20'l1, 2012 and 2013 to-date.


IT IS THE INTENT OF THI8 8UBPOENA THAT EACH AND EVERY DOCUIIENT BEPRODUCED, NO IIATTER HOW INSIGNIFICANT THAT ITEM MAY APPEAR TO THE PARTYTO WHOII THIS SUBPOENA IS DIRECTED, AND 18 IIEANT TO INCLUDE ALL RECORD8REQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU IIAY COIIPLV WITH THIS SUBPOENA BY PROVIDING LEGIBLE(QP]g$ Pgrgg /'7PM$ go Qg PPOQi IQcQ TPl TUL ATTODNLY glPQ$ c h]Phil( APPcAb$ON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAILTO'.


YOU IIAY BE IN CONTEIlllPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - MCGOVERN1602 10 Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone; (561) 533-6650Facsimile; (661) 633-6853

ANDY M. CUSTERFlorida Bar No.: 980341Email. Acuster806C aol. corn

second Email; svlvia(Scusterlawfl.corn

Oct, Z, Z013 /:11VII/I t'uster-Mcbovern fjio, 3/41 I'. 2H/4b

ADQLFO ROURA,

Plaintiff,

vs.

IN THE CIRCUIT COURT QF THENINETEENTH JUI3ICIAL CIRCUITIN AND FQR 5T. LUCIE COUNTY,FLQRIDA

CASE NQ.'. 12CA002123


Defendants.

80BPGENA DUCES TECUII(Mail-ln Documents in Lieu of Appearance)


TO: Records CustodianTravefers Commerciaf Insurance Companyc/o Florida Chief Financial OfficerP.G. Box 6200 (32314-6200)200 E, Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COIIMANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M Custer, Esq,, 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 2& " day of October, 2013, @8:45 a.m., for the taking of yourdeposition in the above-styled cause

AND TO BRING WITH YOU, THE POLLOI/ING:

1) Please provide Tax identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D,,including but not limited to TIN —65-0340540.

2) As to Jordan C. Grabel, M.D., pfease provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by TravelersCommercial insurance Company, for any medical/fegal services or litigation, including but notlimited to compulsory or independent medical examinations, testimony at trial (whether in-personor by videotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-data.

The response should include documentation of each payment made Travelers Commercialinsurance Company, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C BRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses and/or other affiliated entities ecting on behalf of Jordan C.Grabel, M.D. or Jordan C.Brabef, M.D., P.A., through any and all antitias, including but not limited to defense law firms

Oct, 2. 2013 /:12f'IVI UIjster-IVlcGovern No. 3/41 I', 29/45

retained by Travelers Commercial insurance Company, or serving as private and/or in-housecounsel for Travelers Commercial insurance Company, and/or any other affiliated Defendant, firstparty UM insurer or third party liability insurer{s) for the years 2009, 20 "l0, 2011, 2012 and 2013to-date.

THIS SUBPOENA REQUIRES PRODUCTION OF DOCUNlENT8

IT IS THE INTENT GF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO NIATTER HONI INSIGNIFICANT THAT ITENI NIAY APPEAR TO THE PARTYTG WHGNI THI8 8UBPOENA IS DIRECTED, AND IS INEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU MAY CONIPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITENIS TO BE PRODUCED TG THE ATTORNEY WHOSE NANIE APPEARSGN THIS 8UBPOENA BELOW ON GR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F.S.A.„youare entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena„and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:


YOU MAY BE IN CONTENIPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by'the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - IICGGVERN1602 10'"Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone. {561)533-6650Facsimile: (681) 533-6853

BYANDY M. CUSTERFlorida Bar No.; 980341Email'Acuster808Caol.corn

Second Eraii; [email protected]

Oct, 2, 2013 7:12PM Custer-McGovern No. 3741 P. 30/45

ADOLFO ROURA,

Plaintiff,

vs.

IN THE CIRCU)T COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY,FLORIDA.

CASE NO.: 12CAQ02123

KRSTINA MICHELLE BRANA andROSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

SUBPOeNA btjCES TECUM{Mail-in Documents in Lieu of Appearance)


TO: Records CustodianArnica Mutual Insurance Com panyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200}200 E Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COIIIINIANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy'. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 28T" day of October, 2013, I 9:00 a.rn., for the taking of yourdeposition in the above-styled cause.

AND To BRING I/I/ITH YOU, THE FOLLOWING:

1} Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliated

entity of any kind or nature, to the Tax Identificat(on Number(s) for Jordan C. Grabel, h/I.D.,

including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature{retainer agreements, IRB Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M D., P A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M,D,, by Arnica MutualInsurance Company, for any medical/legal services or litigation, including but not limited to:compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in the

medical/legal fields, regardless of whether a report was Issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 20'i 3 to-date.

The response should include documentation of each payment made Arnica Mutual InsuranceCompany, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C. Grabel, M.D,P.A., through any and all entities, including but not limited to defense law firms retained by Arnica

Oct. 2. 2rJ13 /:12VII/I Custer-Mcgovern No. 3/41 I', 31/41

Mutual Insurance Company, or serving as private and/or in-house counsel for Arnica MutualInsurance Company, and/or any other affiliated Defendant, first party LIM insurer or third partyliability insurer(s) for the years 2009, 2010, 2011, 2012 and 20'i3 to-date.


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUNIENT BEPRODUCED„NG IIATTER HOW INSIGNIFICANT THAT ITEM IIAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA I8 l3IRECTED, AND IS IIEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected andmay be copied at that time. You will not be required to surrenderthe original items. YGU MAY COMPLY WITH THI8 SUBPOENA BY PROVIDING LEGIBLECOPIES QF THE ITEMS TO BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEARSQN THIS SUBPOENA BELOW GN QR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production

in accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:

1. appear as specified, or2. furnish the records instead of appearing as provided above, or3, object to this Subpoena,

YOU MAY BE IN CONTEIIPT OF COURT. You are subpoenaed by the attorney whose nameappaaro on this Oubpoena, and unless excused from this Subpoena by the attorney or the Cou&4,



CUSTER - MCGOVERN1602 10'"Avenue NorthLake Worth, Florida 33460Attorney for PiaintiffTelephone: (661) 633-6650Facsimile: (561) 533-6853

ANDY M. CUSTERFlorida Bar No. 980341Email; Acuster806Raol.corn


Uct, 2. 2rJ13 i;13I'M t'uster-McGovern No. 3/41 I'. 32/4b

ADOLFO ROURA,

Plaintiff,



%HIS I INA MICHPLLE URANA andROSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.



TQ. Records CustodianAllstate Insurance Companyc/o Florida Chief Financial OfficerP.Q. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YGU ARE HEREBY CGIIIIANDED TG APPEAR before a person authorized by law to takedepositions al CUSTER-MCGOVERN, Andy M. Custer„Esq, 1602 10" Avenue North„LakeWorth, Florida 33460, on the 28'" day of October, 2013, I 9 l5 a,m., for the taking of yourdeposition in the above-styled cause.

AND TG BRING WITH YGU, THE FOLLOWING;

1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN —65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D.„and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, cor'porations, professional associations, interests,businesses or other affiliated entities acting on behaif of Jordan C. Grabel, M.D., by AllstateInsurance Company, for any medical/legal services or litigation, including but not limited to.compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made Allstate Insurance Company,to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A. and/or anyrelated subsidiaries, corporations, professional associations, interests, businesses and/or otheraffiliated entities acting on behalf of Jordan C.GrabeI, M.D. or Jordan C. Grabel, M D., P.A.,through any and all entities, Including but not limited to defense law firms retained by Allstate

Oct. 2. 2013 /:13I'Ittl C;uster-IVlc(iovern hlo, 3/41 I'. 33/4b

insurance Company, or serving as private and/or in-house counsel for Allstate insurance Company,and/or any other affiliated Defendant, first party UM insurer or third party liability insurer(s) for theyears 2009, 2010, 2011, 2012 and 20 "I3 to-date.

TWI8 8UBPOENA REQUIRES PRODUCTION OF DOCUMENTS

1T IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO INATTER HOW INSIGNIFICANT THAT ITEllll IIAY APPEAR TQ THE PARTYTO WHOII TH1S SUBPOENA IS DIRECTED) AND IS MEANT TG INCLUDE ALL RECORDSREQUESTED,

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YOU IIAY COIIPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEMS TG BE PRODUCED TG THE ATTORNEY WHOSE NAME APPEARSON THIS SUBPOENA BELOW GN GR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

ln accordance with Florida Statute 92.153F S.A.„youare entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YGU FAIL TG:

"l. appeal as specified, or2, furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YGU IIAY BE IN CONTEMPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER - IICGOVERN1602 10'venue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile: (661) 533-6853

BYANDY M. CUSTERFlorida Bar No.: 980341Email: Acuster806Raol.corn

Second Email: svlviat5custerlawfl.corn

Uot. 2. 2013 /:141'M Custer-Mcgovern No. 3 /41 I', N/4b

AI3OLFO ROURA,

Plaintiff,

vs.

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LLICIE COUNTY,FLORIDA

CASE NO,.'2CA002123


Defendants.

SUBPOENA DUCES TECUNI(Mail-in Documents in Lieu of Appearance)

THE STATE QF FLORIDA:

TO: Records CustodianCastle Key insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-B200)200 E. Bainea StreetTallahassee, Florida 32399

YOU ARE HEREBY GOIIIIII/IANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeN/orth, Florida 33460, on the 28™day of October, 2078, @9:80 a.rn., for the taking of yourdeposition in the above-styled cause.

AND TO BRING WITH YOU, THE FOLLO'I/I/INO:

7) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(a) for Jordan C Grabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099's, cancelled checKs, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. ORABEL,M.D, P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by Castle KeyInsurance Company, for any medical/legal services or litigation, including but not limited to.compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made Castle Key InsuranceCompany, to the expert, JORDAN C BRABEL, M.D., and/or JORDAN C. BRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C. Grabel, M.D.,P,A., through any and all entities, including but not limited to defense law firms retained by Castle

Uct. 2. 2013 /:14VM I'uster-McGoverii No. 3/41 I'. 3b/4b

Key insurance Company, or serving as private and/or in-house counsel for Castle Key )nsuranceCompany, and/or any other affiliated Defendant, first party UM insurer or third party liabilityInsurer(s'I d'or me years zuw, zu1u, zul1, zu12 ano zu't 4 lo-oate.

THIS SUBPOENA REQUIRES PRODUCTION GF DOCUIIENTS

IT IS THE INTENT GF THIS SUBPOENA THAT EACH AND EVERY DOCUIIENT BEPRODUCED, NG IIATTER HGW INSIGNIFICANT THAT ITEM MAY APPEAR TO THE PARTYTG WHGII THIS SUBPOENA IS DIRECTED, AND IS MEANT TQ 1NCLUDE ALL RECORDSREQUESTEI3.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items YGU MAY COMPLY WITH THIS SUBPOENA BY PROVIDlNG LEGIBLECOPIES OF THE ITEMS TO BE PRODUCED TQ THE ATTORNEY WHOSE NAME APPEARS.ON THIS SUBPOENA BELOW ON GR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by'providing legible copies of the items to ba produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.553F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreirpbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thatime and place specified above

IF YOU FAlL TO:

1. appear as specified, or2. furnish tha records instead of appearing as provided above, or3. object to this Subpoena,

YOU IIAY BE IN CONTEMPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by tha attorney or the Court,you shall respond to this Subpoena as directed.

Dated October 12. 20'13

CUSTER - IICGOVERN1602 10'"Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (563) 533-6650Facsimile: (561) 533-6853

BYANDY M. CUSTERFlorida Bar No.'. 980341Email: Acuster806{Saol.corn

Second Email: svlviaN)custerlawfl.corn

Uct. 2. 2013 /:1bl'M I;uster-Mc(govern No, 3/41 I'. 3b/4b

ADOLFO ROURA,

Plaintiff,

vs.




Defendants.



TO: Records CustodianState Farm General Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-62QQ)200 E Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY CQMIIIIANDED TQ APPEAR before a person authorizedby law to takedepositions at CUSTER-h/ICGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 28™day of Qciober, 2013, @9:46 a.m., for the taking of yourdeposition in the above-styled cause.

AND TO BRING I/ITH YOU, THE FOLLOWING".

1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2Q13 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099'8, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., andior JORDAN C. GRABEL„M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by State FarmGeneral Insurance Company, for any medicalilegal services or litigation, including but not limitedto: compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/ol depositions, record reviews and/or any other services provided In themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2Q11, 2Q12 and 2013 to-date.

The response should include documentation of each payment made State Farm General InsuranceCompany, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL, M.D., P.A.and/or any related subsidiaries, corporations„professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C. Grabel, M.D.,P A., through any and all entities, Including but not limited to defense law firms retained by State

Oct. 2. 2iJ13 /:15I'M Custer-IVlcbovern No. 3/41 I'. 3//4b

Farm General Insurance Company, or serving as private and/or in-house counsel for State FarmGeneral Insurance Company, and/or any other affiliated Defendant, first party UM insurer or third

party liability insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.


IT IS THE INTENT GF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITENI NIAY APPEAR TO THE PARTYTO WHONI THIS SUBPOENA I8 DIRECTED, AND I8 MEANT TO INCLUDE ALL RECORDSREQUESTED.

Thesetems viiiII be inspected and m»ay be copied at tibet tii»e. You will not be i equii ed to surrenderthe original items. YOU MAY CONIPLY tNITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIE8 OF THE ITENIS TO BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEARSON THIS SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliv'er the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAILTO'.


YOU NIAY BE IN CGNTENIPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER MCGOVERN1602 10'" Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone (561) 533-6650Facsimile; (561) 533-6853

eYANDY M. CUSTERFlorida Bar No.; 980341Email: [email protected]

Second Email.'vlviaecusterlawfl.corn

Oct. 2. 2I)l3 7:l5PM Custer-McGovern No. 3741 P, 38/45

ADQLFQ RQURA,

Plaintiff,

IN THE CIRCUIT COURT OF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LUCIE COUNTY,FLQRIl3A


KRISTINA MICHELLE BRANA andL ~

jointly and severally,

Defendants.



TO: Records CustodianSta'te Farm Fire and Casualty Companyclo Florida Chief Financial OfficerP.O Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMIIANDED TOAPP EAR before a person authorized by Iaw'to takedepositions at CUSTER-MCGOVERN, Andy'. Custer, Esq., 1602 10'" Avenue North, LakeYVorth, Florida 33460, on the 28'" day of October, 2013, I 4:00 p.m., for the taking of yourdeposition in the above-styled cause.

AND TG BRING WITH YOU, THE FOLLOWING:

1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax identification Number(s) for Jordan C. Grabel, M.D.,including but not iimited to TIN —85-0340540.

2) As to Jordan C. Grabei, M.D., please provide any and all documents of any kind or nature{retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C Grabel, M.D., by State FarmFire and Casualty Company, for any medical/legal services or litigation, including but not limited

to: compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) andlor depositions, record reviews and/or any other services provided in thenwaciiaolllagal fialdai rogardloaa of whan&ar o rapoi% w'ao ioooodi iAoldelil a$ 4 vt rior Srili'tool 4o aaoaoiclaims or actions for the years 2009, 2010, 2011, 20'I 2 and 2013 to-date.

The response should include documentation of each payment made State Farm Fire and Casualty

Company, to the expert, JORDAN C. GRABEL, M.D., andlor JORDAN C. GRAHEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesandior other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C. Grabel, M.D.,P.A., through any and all entities, incfuding but not limited to defense law firms retained by State

Oct. 2. 2013 7:16PM Custer-McGovern No. 3741 P, 39/45

Farm Fire and Casually Company, or serving as private and/or in-house counsel for State FarmFire and Casualty Company, and/or any other affiliated Defendant, first party UM insurer or thirdparty liability Insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date.


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUINENT BEPRODUCED, NO IIATTER HOW INSIGNIFICANT THAT ITEIN INAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA IS DIRECTED, AND IS INEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that. time. You will not be required to surrendertha original items YOU INAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEIIS TO BE PRODUCED TO THE ATTORNEY WHOSE NAINE APPEARSGN THIS SUBPOENA BELOW GN OR BEFORE THE SCHEDUI ED DATE OF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before tha scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecoats incurred in producing the documents specified herein Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetima and place specified above.

IF YOU FAIL TO;

1. appear as specified, or2. furnish tha records instead of appearing as provided abave, or3. object to this Subpoena,

YOU MAY BE IN CGNTEINPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER INCGOVERN1602 10~ Avenue NorthLake Worth, Florida 33480Attorney for PlaintiffTelephone: (561}533-6650Facsimile: (581) 533-8853

ANDY M CUSTERFlorida Bar No.; 980341Email; [email protected]

Second Email. sylviaoc~tarlawfl.corn

Uct, 2. 2rJ13 /:1bl'II/I Duster-Mcgovern No, 3/41 I'. 40/4b

ADGLFG ROURA,

Plaintiff,



KRISTINA MICHELLE BRANA andRGSCGX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.



TO: Records CustodianState Farm Mutual Automobile Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 6200 (32314-6200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COMMANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10~ Avenue North, LakeWorth, Florida 33460, on the 28'" day of October, 2013,I 4:16 p.m., for the taking of yourdeposition in the above-styled cause.

ANI3 TO BRING WITH YOU, THE FOLLOIhtING:


2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature{retainer agreements, IRB Form 1099's, cancelled checks, ledgers, etc.), which state/show/fist thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. BRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, Interests,businesses or other affiliated entities acting on behalf of Jordan C. Qrabel, M.D., by State FarmMutual Automobile Insurance Company, for any medical/legal services or iitigation, including butnot limited to: compulsory or independent medical examinations, testimony at trial (whether in-person or by videotape) and/or depositions, record reviews and/or any other services provided inthe medical/legal fields, regardless of whether a report was issued, including but not limited tocases, claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made State Farm Mutual AutomobileInsurance Company, to the expert, JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations„ interests,businesses and/or other affiliated entities acting on behalf of Jordan C.arabel, M.D. or Jordan C.Grabel, M.D., P.A., through any and all entities, including but not limited to defense Iaw firma

Oct. 2. 2tj13 /:1/PM Custer-McGovern No. 3/41 P. 41/45

retained by State Farm Mutual Automobile insurance Company, or serving as private and/or in-house counsel for State Farm Mutual Automobile Insurance Company, and/or any other affiliatedDefendant, first party UM insurer or third party liability insurer(s) for the years 2009, 2010, 2011,2012 and 2013 to-date.


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HOW INSIGNIFICANT THAT ITEM MAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA 18 DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED,

These items will be inspected and may be copied at that time. You will not be required to surrenderme Onglnai Items. YOu IVI+Y VVIVII LY WIIH IHlb bUUI'VENA BY PRUVII3ING LE( ISLECOPIES OF THE ITEMS TQ BE PRODUCED TO THE ATTORNEY WHOSE NAME APPEARSON TH18 SUBPOENA BELOW ON OR BEFORE THE SCHEDULED DATE QF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.153F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specifted herein. Please include your request forreimbursement of coats along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above.

IF YOU FAIL TO:




CUSTER - MCGOVERN1602 10'"Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: {561)533-6650Facsimile; (561) 533-6853

BYANDY M. CUSTERFlorida Bar No.. 980341Email: Acuster806(Raol. corn

Second Email: svlviaScusterlawfl.corn

Or t 2 2013 7'1/PM Rnatter —MrHnvern kin 3741 P 42/4h

ADGLFG RGURA,

PIaintiff,

vs.

IN THE CIRCUIT COURT GF THENINETEENTH JUDICIAL CIRCUITIN AND FOR ST. LUC1E COUNTY,FLORIDA

CASE NO.: 12CA002 "123

KRISTINA MICHELLE BRANA andRGBCGX CGRPGRATIGN, a Florida Corporation,jointly and severally,

Defendants.

8UBPOENA DUCE8 TECUIN(Mail-in Documents in Lieu of Appearance)

THE STATE GF FLORIDA:

TO; Records CustodianState Farm Florida Insurance Companycio Florida Chief Financial OfficerP.O. Box 6200 (32334-u200)200 E. Gaines StreetTallahassee, Florida 32399

YOU ARE HEREBY COIIIIMANDED TO APPEAR before a person authorized by law to takedepositions at CUSTER-MCGOVERN, Andy M. Custer, Esq., 1602 10'" Avenue North, LakeWorth, Florida 33460, on the 2S'" day of October„2013, @4:30p.m., for the taking of yourdeposition in the above-styled cause.

ANI3 TO BRING Ill'H YOU, THE FOLLOWING:

1) Please provide Tax Identification Payment Number (TiN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-date, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax identification Number(s) for Jordan C Brabel, M.D.,including but not limited to TIN - 65-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature(retainer agreements, IRS Form 1099'a, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Brabel, M.D., by State Far'm

Florida insurance Company, for any medical/legal services or litigation, including but not limited to:compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape} and/or depositions, record reviews andi'or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases„claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date.

The response should include documentation of each payment made State Farm Florida insuranceCompany, to the expert, JORDAN C. GRABEL, M.D,, and/or JGRDAN C. GRABEL, M.D., P.A.and/or any related subsidiaries, corporations, professional associations, interests, businessesand/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C. Grabel, M.D.,P.A., through any and all entities, including but not limited to defense law firms retained by State

Oct, 2, 2013 7:1HPM Custer-McGovern No. 3741 P. 43/45

Farm Florida Insurance Company, or serving as private and/or in-house counsel for State FarmFlorida Insurance Company, and/or any other affiliated Defendant, first party UM insurer or thirdparty liabiiity insurer(s) for the years 2009, 2010, 2011, 2012 and 2013 to-date,

THIS SUBPOENA REQUIRES PRODUCTION OF DOCUNIENTS

IT IS THE INTENT GF THIS SUBPOENA THAT EACH AND EVERY DOCUNIENT BEPRODUCED, NG MATTER HOW INSIGNIFICANT THAT ITENI MAY APPEAR TQ THE PARTYTO WHQNI THI8 SUBPOENA l8 DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED.

Theta itamc will ba inapaatad and may ba eapiad at that tima Yap will not ba raquirad ta ai rvrandarthe original items. YQU MAY CON!PLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITEM8 TO BE PRODUCED TO THE ATTORNEY WHOSE NAIIE APPEARSON THIS 8UBPOENA BELOW GN GR BEFORE THE SCHEDULED DATE GF PRODUCTION.You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.

In accordance with Florida Statute 92.163F.S.A.,you are entitled to reimbursement of reasonablecosts incurred in producing the documents specified herein. Please include your request forreimbursement of costs along with the documents. You may mail or deliver the copies to theattorney whose name appears on this Subpoena, and thereby eliminate your appearance at thetime and place specified above

IF YOU FAIL TG:


YOU MAY BE IN CONTENIPT OF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or the Court,you shall respond to this Subpoena as directed.


CUSTER IlllCGOVERN1602 10~ Avenue NorthLake I/Vorth, Fiorida 33460Attorney for PlaintiffTelephone'561) 533-6650Facsimile: (561) 533-6853

BYANDY M. CUSTERFlorida Bar No.; 980341Email: [email protected]

Second Email: svlvia@custerlawfl,corn

Oct. 2, 2U13 /:1III'IVI I;uster-Me(govern N o. 3/41 I'. 44/4b

ADOLFO ROURA,

Plaintiff,

vs.


CASE NO.: 'l2CA002123

KRISTINA II/IICHELLE BRANA andROSCOX CORPORATION, a Florida Corporation,jointly and severally,

Defendants.

SUBPOENA DUCES TECUII{Mail-in Documents in Lieu of Appearance)


TO: Records CustodianGovernment Employees Insurance Companyc/o Florida Chief Financial OfficerP.O. Box 8200 (32314-6200)200 E. Baines StreetTallahassee, Florida 32399

YOU ARE HERE8Y COMINANDED TO APPEAR before a person authorized by Iaw to takedepositions at CUSTER-MCGOVERN„Andy M, Custer, Esq., 'i802 10'" Avenue North, LakeWorth, Florida 33460, on the 28'" day of October, 2013, @4:45 p.rn., for the taking of yourdeposition in the above-styled cause


1) Please provide Tax Identification Payment Number (TIN) payment records for the years 2009,2010, 2011, 2012, and 2013 to-data, for each payment made by the company, or any affiliatedentity of any kind or nature, to the Tax Identification Number(s) for Jordan C. Grabel, M.D.,including but not limited to TIN —85-0340540.

2) As to Jordan C. Grabel, M.D., please provide any and all documents of any kind or nature{retainer agreements, IRS Form 1099's, cancelled checks, ledgers, etc.), which state/show/list thetotal amount of fees for services paid to JORDAN C. GRABEL, M.D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses or other affiliated entities acting on behalf of Jordan C. Grabel, M.D., by Government

. Employees Insurance Company, for any medical/legal services or litigation, Including but not limitedto: compulsory or independent medical examinations, testimony at trial (whether in-person or byvideotape) and/or depositions, record reviews and/or any other services provided in themedical/legal fields, regardless of whether a report was issued, including but not limited to cases,claims or actions for the years 2009, 2010, 2011, 2012 and 2013 to-date,

The response should include documentation of each payment made Government EmployeesInsurance Company, to the expert, JORDAN C. GRABEL, M D., and/or JORDAN C. GRABEL,M.D., P.A. and/or any related subsidiaries, corporations, professional associations, interests,businesses and/or other affiliated entities acting on behalf of Jordan C.Grabel, M.D. or Jordan C.Grabel, M.D., P.A., through any and all entities, including but not limited to defense Iaw firms

oct. 2, )013 /:1bi'IVl Custer-IVlcGovern No. 3 /41 I'. 4b/4b

retained by Government Employees Insurance Company', or serving as private and/or in-housecounsel for Government Employees Insurance Company, and/or any other affiliated Defendant,first party UM insurer or third party liability insurer(s) for the years 2009, 2010, 2011, 2012 and2013 to-date.


IT IS THE INTENT OF THIS SUBPOENA THAT EACH AND EVERY DOCUMENT BEPRODUCED, NO MATTER HQW INSIGNIFICANT THAT ITEM MAY APPEAR TO THE PARTYTO WHOM THIS SUBPOENA IS DIRECTED, AND IS MEANT TO INCLUDE ALL RECORDSREQUESTED.

These items will be inspected and may be copied at that time. You will not be required to surrenderthe original items. YGU MAY COMPLY WITH THIS SUBPOENA BY PROVIDING LEGIBLECOPIES OF THE ITENIS TO BE PRODUCED TQ THE ATTORNEY WHOSE NAME APPEARSGN THIS SUBPOENA BELOW ON QR BEFORE THE SCHEDULED DATE OF PRODUCTION,You may comply with this Subpoena by providing legible copies of the items to be produced to theattorney whose name appears on this Subpoena on or before the scheduled date of production.


IF YQU FAILTO'.

appear as specified, or2, furnish the records instead of appearing as provided above, or3. object to this Subpoena,

YGU MAY BE IN CONTEMPT GF COURT. You are subpoenaed by the attorney whose nameappears on this Subpoena, and unless excused from this Subpoena by the attorney or'the Court,you shall respond to this Subpoena as directed.

Dated'. October 12, 2013

CUSTER —MCGOVERN1602 10~ Avenue NorthLake Worth, Florida 33460Attorney for PlaintiffTelephone: (561) 533-6650Facsimile. (661) 633-6853

BY.ANDY M. CUSTERFlorida Bar No.: 980341Email. [email protected]

Second Email; svlvia&custerlawfl.corn