Free Subpoena - District Court of Delaware - Delaware

jb Case 1 :04-cv—OO855-KAJ Documésistnéiiilay thEi|ed O9/O2/2005 PWR TG I N A L
UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
Shawn A. Russell SUBPOENA H\l A CIVIL CASE
v. Case Number 04-855 KA.}
Inland Paperboard and Packaging, Inc.
TO: Marilyn Barnes, F.N.P.
Family Health of Delaware
640 South Queen Street
Dover, DE 19904 `
lj 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 3 COURTROOM
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. I
PLACE or DEPOSITION I DATE AND TIME
E YOU ARE COMIVIANDED to produce and permit inspection and copying of the following documents
or objects at the place, date and time specified below (list documents or objects):
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.
A "LACE’ ~ DATE AND TIME:
Tighe, Cottrell & Logan, P.A. S 14 2005
. 704 N. King stmt, 1>.o. Box 1031 A Cptcmber ’
First Federal Plaza, Suite 500 . »
Wilmington, DE 19801
El YOU ARE COMMANDED to permit inspection of the following premises at the date and time
s • ecified below.
PLACE or DEPOSITION 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,
30(lg)(6Q.
REQUESTING r·ARrv·s NAME, ADDRESS AND PHONE NUMBER
G. Kevin Fasic, Esquire, Attorney for Defendant Inland Paperboard and Packaging, Inc.
Tighe Cottrell & Logan, P.A.
P.O. Box 1031, Wilmington, DE 19 *
302-658-6400 I g , ,_
ISSUING 1=ARrv·s SIGNATURE AND TITLE »¥§T?F¥'l?"· *3*6 Y ron PLAINTIFF on DEFENDANT)
DATE: 8/31/2005
iS€€ RUIB Z5, Rules of ClVll PIOCCHUIG, PHITS C & D OI1 I`l€XlC pagfbl

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' j _ _ PROOF OF SERVICE
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DECLARATION OF SERVER
I declare under penalty of perjury under the laws of the United States of America that the foregoing infonnation contained in the
Proof of Service is true and correct. ·
Executed on Q l l Ab}
DATE srcmrurza or snrrvsa
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Annasss or serzvrcs
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Rule 45, Federal Rules Civil Procedure, Parts C & D:
(cz) PROTECTION OF PERSONS SUBJECT TO SUBPOENAS. (iv) subjects a person to undue burden.
(1) A party or an attorney responsible for the issuance and (B) lfa 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 commercial 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 specihc events or .
is not limited to, lost earnings and reasonable attomey’s fee occurrences in dispute and resulting from the expert’s study made
A not at the request of any party, or
_ (2) (A) A person commanded to produce and permit (iii) requires a person who is not a party or an officer
inspection and copying of designated books, papers, documents or of a party to incur substantial expense to travel more than lOO
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 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 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 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 (d) DUTIES 1N RESPONDING TO SUBPOENA
service, serve upon the party or attorney designated in the
subpoena written objection to inspection or copying of any or all (l) A person 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 them to correspond with the
inspect and copy materials or inspect the premises except pursuant categories in the demand. - i
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 infomiation 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 materials, 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 ofthe nature of the documents,
party or an officer of a party from signiHcant expense resulting communications, or things not produced that is sufncient 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 A
was issued shall quash or modify the subpoena if it q
(i) fails to allow reasonable time for compliance, .
(ii) requires a person who is not a party or an officer I · · · _ ‘
of a party to travel to a place more than 100 miles from the place
where that person resides, is employed or regularly transacts
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
_ trial be commanded to travel hom any such place withi.n 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

· 3 f 3
( V Case 1 :04-cv—OO855-KAJ Document 36 Filed O9/O2/2005 Page 0
AUTHORIZATION FOR MEDICAL INFORMATION

TO WHOM IT MAY CONCERN:
2 I iq u i' 5 é l ·
I, ¤» ’=·’·"~ *l\ ‘> ( , the undersigned, hereby authorize the use or
disclosure of health information about me as described below:
1. Representatives or attorneys hom 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.
3. I understand that the information used or disclosed by be subject to re-disclosure 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. I may revoke this authorization by notifying Tighe, Cottrell & Logan, P.A., in writing
of my desire to revoke it. However, I understand that any action already taken in reliance onthis
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 infonnation about me.
6. A photostatic copy of this authorization shall be considered as true and valid as the
original.
.. e- " *7 `l
DATE: . is O; Lf, M ‘ {E /~»w{§£ LC
Social Security No. l ’ 2.`”° Lt
Date of Birth: G" ` ’l kf
JSS: