UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
Shawn A. Russell SUBPOENA IN A CIVIL CASE
v. Case Number 04-855 KA]
Inland Paperboard and Packaging, Inc.
TO: A.O. Osunkoya, M.D.
Family Health of Delaware
640 South Queen Street
Dover, DE 19904
ij YOU ARE COMMANDED to appear in the United States District Court at the place, date and time
s ecified below to testi in the above case.
PLACE or TESTIMONY COURTROOM
A DATE AND THVIE
Ei YOU ARE COMMANDED to appear at the place, date and time specified below to testify at the taking
of a de osition in the above case.
PLACE or DEPOSITION DATE AND rmi;
E YOU ARE COMMANDED to produce and ermit ins ection and copying of the following documents
_ P P
or objects at the place, date and time specified below (list documents or obj ects):
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 Securi #: 221-62-0854.
PLACE A DATE AND TIME:
I Tighe, Cottrell & Logan, P.A. S b 14 2005
704 N. King Street, 1>.o. sex 1031 Cptcm Cf ’ y
First Federal Plaza, Suite 500 i
Wilmington, DE 19801
ij YOU ARE COMNLANDED to permit inspection of the following premises at the date and time
s • ecified below.
PLACE or DEPOSITION I DATE AND TIME
Any 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 behalf, and may set
forth, for each person designated, the matters on which the person will testify. Federal Rules Civil Procedure,
3 0(Z2)(6).
iuaquesrmc i=Aaw·s NAME, ADDRESS AND PHONE NUMBER
G. Kevin Fasic, Esquire, Attorney for De dant lnland Paperboard and Packaging, Inc.
Tighe Cottrell & Logan, P.A.
P.O. Box 1031, Wilmington, DE 19 ‘ / A ,
302-658-64OO A · D · D
A 4;
ISSUING PARTY‘S SIGNATURE AND rms (IN » ’ ATE rr ATT Y mn PLAINTIFF on DEFENDANT)
DATE: 8/31/2005 `
ee ue · , e era u eso 1v1 roce ure, arts I I onnextpage
.. Case 1 :04-cv-00855-KAJ Document 38 Filed 09/O2/2005 Pa e 2 of 3
li _ _ PROOF OF SERVICE (
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DECLARATION OF SERVER
I declare under penalty of perjury under the laws ofthe United States of America that the foregoing infonnation contained in the
Proof of Service is nue and correct.
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Executedon A
mrs stcmrnae or snava
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one be i¢i
(c) PROTECTION OF PERSONS SUBJECT TO SUBPOENAS. (iv) subjects a person to undue burden.
(l) A party or an attorney responsible for the issuance and (B) If a subpoena
service of a 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 court on behalf of which the subpoena was issued _ confidential research, development, or cornrnercial information, or
shall enforce this duty and impose upon the party or attorney in (ii) requires disclosure of an unretained expert’s
breach of this duty an appropriate sanction which may include, but opinion or information not describing specinc events or .
is not limited to, lost earnings and reasonable attomey’s fee occun·ences in dispute and resulting fiom the expert’s study made
not at the request of any party, or
(2) (A) Aperson commanded to produce and permit (iii) requires a person who is not a party or an ofiicer
inspection and copying of designated books, papers, documents or of a party to incur substantial expense to travel more than 100
tangible things, or inspection of premises need not appear in miles to attend trial, the court may, to protect a person subject to
person at the place of production ei inspection unless commanded or affected bythe subpoena, quash or modify the subpoena need
to appear for deposition, hearing or trial for the testimony or material that cannot by otherwise met without
undue hardship and assures that the person to whom the subpoena
(B) Subject to paragraph (d) (2) of this rule, a person is addressed will be reasonably compensated, the court may order
commanded to produce and permit inspection and copying may, appearance or production only upon speciiied conditions. A
within 14 days after service of subpoena or before the time
specified for compliance if such time is less that 14 days after (d) 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) Aperson responding to a subpoena to produce
of the designated materials or of the premises. Ifobjection is documents shall produce them as they are kept in the usual course
made, the party serving the subpoena shall not be entitled to of business or shall organize and label themto 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 issued. If
objection has been made, the party serving the subpoena may, (2) When information subject to a subpoena is withheld on a
upon notice to the person commanded to produce, move at any claim that it is privileged or subject to protection as trial
time for an order to compel the production. Such an preparation rnateiials, the claim shall be made expressly 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,
party or an officer of a party nom significant expense resulting communications, or things not produced that is suiicient to enable
from the inspections and the demanding party to contest the claim.
copying commanded.
(3) (A) On timely motion, the court by which a subpoena
was issued shall quash or modify the subpoena if it _
(i) fails to allow reasonable time for compliance, .
(ii) requires a person who is not a party or an officer — · ‘
of a party to travel to a place more than 100 miles from the place
where that person resides, is employed or regularly transacts I
business in person, except that, subject to the provisions of clause
(c) (3) (B) (iii) of this rule, such a person may in order to attend l
I trial be commanded to travel nom any such place within the state
. in which the trial is held, or ‘ . `
(iii) requires disclosure of privileged or other
protected matter and no exception or waiver applies, or
. · Case 1 :04-cv-00855-KAJ Document 38 Filed 09/O2/2005 Page 3 of 3
AUTHORIZATION FOR MEDLCAL INFORMAf]fION
T0 WHOM IT MAY CONCERN:
I, “· W" U $56 Lil , the undersigned, hereby authorize the use or
disclosure of health information about me as described below:
1- Representatives or attorneys from Tighe, Cottrell & Logan, P.A., are authorized to
make the requested use or disclosure.
2. The specific infomation that should be disclosed is: all medical records, hospital
records, and other medical statements that may be requested pertaining to findings, treatments, and
opinions as to my medical condition. t
3. Iunderstand that the information used or disclosed by be subject to re—discl0sure by
the person or class of persons or facility receiving it, and would then no longer be protected by
federal privacy regulations, including but not limited to privacy regulations under the Health
Insurance Portability and Accountability Act (HIPAA). _
4. Imay revoke this authorization by notifying Tighe, Cotne1l&Logan,P.A., inwriting l
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 to whom this authorization is furnished may not condition its treatment of me
on whether or not I sign the authorization.
5. This authorization expires upon the conclusion of the litigation that relates to the
purpose ofthe intended use or disclosure of information about me.
6. A photostatic copy of this authorization shall be considered as true and valid as the
original.
I ` C (‘ "g P ry'?} ff'.) 1 {ly"
DATE: 3 A · K oL»'\·¥9~’»*" U
seein Security No. Ll l ~p QL ’C’ Un
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