Free Subpoena - District Court of Delaware - Delaware

Case 1 :04-cv—00855-KAJ Document 41 Filed 09/19/2005 Page 1 of 3
_ Issued bythe p
if UNITED STATES DISTRICT COURT
DISTMCT OF DELAWARE
Shawn A. Russell SUBPOENA IN A CKVIL CASE U
v_ Case Number O4-855 KA}
Inland Paperboard and Paclcagiiig, Inc. D
TO: Dr. Martha lane Merrion
l lO5l Locldaart Lane
Marshall, VA 201 15
[Zi YOU ARE COMMANDED to appear in the United States District Court at the place, date and time `
s eci ed below to testii in the above case. ' ,
rtree or nssruvxoiqr i COURTROGM =
oars Ass rms
[Zi YOU ARE COlVHVIAN})ED to appear at the place, date and time specified below to testify at the taking
of a de osition inthe above case.
rarer or nsrosmow Q oars om mrs 1
YOU ARE COB/IEVIANDED to produce and permit inspection and copying ofthe followii documents
or objects at the place, date and time specified below (list documents or objects): 1
Deponent is to produce a copy of the entire medical file, including but not limited to all medical records,
reports, correspondence, progress and nurses notes, laboratory and diagnostic tests regarding the care and
treatment of Shawn A. Russell DOB: 10/20/1974· Social Securit #2 221—62—0854.
_ ]°L’*°E‘ D care me rms;
Tighe, Cottrell & Logan, PA. ‘ S t b ,4 2905 .
, 704 N. King saea, ro. sea 1021 l lp Bm Bl °
First Federal Plaza, Suite 500 y `
Wilmington, DE 19801 j
[Zi YOU ARE COMMANDED to permit inspection of the following premises at the date and time
s eciiied below.
einer or marosmos i DATE AND TIME
y organization not a party to this suit that is subpoenaed for the taking of a deposition shall designate one or
more officers, directors, or managing agents, or other persons who consent to testify on its behali and may set
forth, for each person designated, the matters on which the person will testify. Federal Rules Civil Procedure,
3 O{lgl(6Q. 1
aaoussnsc m G. Kevin Fasic, Esquire, Attorney for Defendant inland Paperboard and Packaging, Inc.
Tigbe Cottrell & Logan, PA. .
P.O. Box 1031, Wilmington, D * • : fr
302—658—6400 1
assume z»,o DATE; 8/31/2005
ee · .*> » , e era u eso wi rcce sre, arts " r » on nextpage

Case 1 :04-cv—OO855-KAJ Document 41 Fi led 09/19/2005 Page 2 of 3
i _ i QPROOF OF SERVICE 1
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SE _·-‘·_ Q=Z;$ii‘."f·_`f -;.. ji; .=‘-s?;¢i?tss»·rr¤-‘THrs;_s-éttzttieii=<>N.QittEt4trer-i>¥.:€i-: ‘=.-= r ‘‘‘. i ~/‘ - =..-
ll Complete items 1, 2, and 3. Also complete gi · · p
1 item 4 if Restricted Delivery is desired. . U AQEM
ll Print your name and address on the reverse _ KZ! Addresses jc.
SEWED W so that we can return The card to YOU- B, geese by (Prir1tedName) C. Date ot Delivery
s Attach this card to the back ofthe mailpicce,
or on the front if space permits. _ __
D. is delivery address from itegi 1.7 E3 Yes y
I 1. Article Addressed to: If YES_ Ente., QL`, w··gaQrgg;~.bBi¤v3iX 53 ND 1
` Ls? i
K ‘ _ GL. r..c‘>\\ Asif) ‘ ‘
I deciare 1; OG ` N@P`W@ Cjgngj IVIQPPI On $2 5 gf.; gg in tm
Proof of S i \@f_)i L®Qi<\(`\@{`\“i* Lt’;$>t‘W@ {if;-_ 4;;; 3 t
Executed ivi@i"¤Dir\@i i , \i H @[51 i 5 - 3. Scwlcc Type `7`*· __,M' .
Bicemrieu Meri mltersesss Mau Q
E] Registered E Return Receipt for Merchandise Z
{II Insured Mali EI C.O.ED. .
4. Restricted Detlvery? (Extra Fee) p Q Yes
1 2. Article Number ` - " ` " " -
(fransferfmmservicclabeij i-REEL} LLEU Ummm qlqq EEEEZ ""'”"'
RUM PS Form 381 1, Fgbi-gary 2004 Domestic Return Receipt 102,595»02~M—154G
(c) PROTECTION OF PERSONS SUBJECT TO SUBPOENAS. (iv} subjects ax person to endce burden.
(1) A pany or an attorney responsible for the issuance and (B) If a subpoena
service of 2. subpoena shall take reasonable steps to avoid
imposing undue burden or expense on a person subject to that (i} requires disclosure of a trade secret or other
subpoena. The com on behalf of which thc subpoena was issued confidential research, development, or commercial information, or
shall enforce this duty amd impose upon the party or attorney in (ii) requires disclosure of an unrctaizred expcrt's
breach of this duty an appropriate sanction which may include, but opinion or information not describing specific events or .
is not limited to, lost earnings and reascnabie attomey’s fee occurrences in dispute and resulting from the expert’s study made
not at the request of any party, or
_ (2) (A) A person commanded to produce mid permit {iii) requires a person who is not a party or an officer
inspection and copying of designated books, papers, documents or of e party to incur substantial expense to travei more than 100
tangible things, or inspection of premises need not appear iu miles to attend trial, the court may, to protect a person subject to
person at the place of production or inspection unless commanded or affected by the subpoena, quash or modify the subpoena need
to appear for deposition, hearing or trial for the testimony or material that cannot by otherwise met withoct
undue hardship and assures that the person to whom the subpoena
(B) Subject to paragraph (d) (2} of this rule, an person is addressed will be reasonably compensated, the court may order
commanded to produce and permit inspection and copying may, appearance or producticm only upon specified conditions.
within 14 days after service of subpoena or before the time
specified for compliance if such time is less that 14 days after {ci) DUTIES IN RESPONDING TO SUBPOENA
service, serve upon the party or attorney designated in the `
subpoena written objection to inspection or copying of any or all (1) A person responding to a subpoena to produce
ofthe designated materiais or ofthe premises. If objection is documents shall produce them as they are kept in the usual course
made, the party sewing the subpoena shall not be entitled to of business or shall organize and label them to correspond with the
inspect and copy materials or inspect the premises except pursuant categories in the demand.
to an order of the court by which the subpoena was isszred. If
Objection has been made, the party serving the suinpocna may, {2) When infomiatiou subject to a subpoena is withheld on a
upon notice to the person commanded to produce, move at any claim that it is priviicged or subject to protection as trial
time for au order to compel the production. Such an preparation matcriais, the claim shall be made expressiy and shall
order to comply production shall protect any person who is not a be supported by a description of the nature of the documents,
paaty or ar: officer of a party from significant expense rescitirrg communications, or things not produced that is sufiieient to enable
from the inspections and the demanding party to contest the ciaim.
copying commanded.
(3} {A) On timely motion, the court by which a subpoena
was issued shell quash or modify the subpoena if it
{i) fails to allow reasonable time for compliance, _
(ii) requires :2 person who is not :1 party cr an ofiiccr
of a party to zravci to a place more than 100 miles iiom the piece
where that person resides, is employed or regularly transacts
business in person, except that, subject to the provisions of ciause
(c) (3) (B} (iii) of this rule, such :1 person may in order to attend
trial be commanded to travel from any such place within the state
in which the trial is helé, or `
(iii} requires disclosure ofprivilegeé or other
protected matter and no exception or waiver applies, or

UW — ‘ WWC:¥é ¥:O4-cv—OO855-KAJ Documeni 41 Filed 09/19/2005 Page 3 of 3
I AUTHORIZA1`EON FOR MEDKDAL INFGRMATIQN
TO WHOM {T MAY CONCFERN:
. ` gx ‘
I, Q L. .#i\=~·*~·’¤”‘~ gg ·-· ·$> 2*/·{ ____, thc undersigned, hereby authoxize the use or ‘
disclosure bf health infomation az out me as described below;
L Representatives or attorneys from Tighc, Cottrell & Logan, PA., am authcmzaci to
make thc requested use 01* disclosure.
- 2. The speciiic information that should be disclosed is: all medical records, hospital ‘
rccmds, and other medical statements that may he requested pertaining to findings, trcammzts, and
opinions as tc: my medical condition.
F 3. {understand that the inf0rmati¤¤‘used 01: disclosed iz bc subj cnt to rc#disc1dsu by
_ the person or class of pctsnms _0r facility receiving it; and would 4::1 no icmgar bc protected- by
federal privacy regulations, including but not limited 10 privacy regulations under the Health
Insurance I?c¤rtability`e1x1d Accuuntabiiity Act (HIPAA). .
4. {may revoke this aumqrizaticu by notifying Tighc, C0 ttwil & Logan, P A., in writing
of my desire to revoke it. However, I understand that any action already taken in reliance on this
authorization can not be reversed, and my revocation will not affect those actions. I understand that ·
the medical provider tc whom this authorization is furnished may mt condition its treatment cfmc
on whether or not I sign the authorization.
5; This authorization expires upon thé ccxxclusion of the litigation that reiatcs to thc
purpose ofthe intended use 0: disciqsurc of infomation about 1316.
6. A piwtustatic copy of this authorization shall bc considered as tmc and valid as the
urigirmi.
LE) vé _.¤·‘ Eh" '_,P"d#'i?
DATE: af . il U5 ` " ;‘.»“§’?L,»»W¤ Fi} ~ E/-w?»·<"€'£J
Social Security No. 21 {il" 5 Ll
Date c:fBi1·t2z: JL;} W Mg M
ESS:
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