`
`VERIFIED RETURN OF SERVICE
`
`State of Florida
`
`County of Palm Beach
`
`Circuit Court
`
`Case Number: 2022-CA-001269 Court Date: 7/7/2022
`
`Petitioner:
`IN RE: THE ESTATE OF
`ROSALIA DIGIOVANNI (deceased)
`
`JVS2022008347
`
`.V
`
`INCENT DIOGIOVANNI, AN INDIVIDUAL and JOHN DIGIOVANNIE, AN
`INDIVIDUAL
`vs.
`Respondent:
`LEONORA DATTILO, AN INDIVIDUAL
`
`NOT A CERTIFIED COPY
`
`For:
`Jennifer N. Grant, Esq.
`Law Offices of Jennifer Grant, P.A.
`6619 S DIXIE HIGWAY
`STE 623
`MIAMI, FL 33143
`
`Received by COMPASS INVESTIGATIONS on the 27th day of June, 2022 at 4:55 pm to be served on RECORDS
`CUSTODIAN ELEVATE CARE F/K/A MENORAH HOUSE, 9945 N CENTRAL PARK BLVD, BOCA RATON, FL
`33428.
`
`I, Donald Moore, do hereby affirm that on the 29th day of June, 2022 at 11:10 am, I:
`
`Served an AUTHORIZED: entity by delivering a true copy of the SUBPOENA DUCES TECUM and EXHIBIT "A"
`with the date and hour of service endorsed thereon by me, to: PENNY R as SOCIAL SERVICES, who stated they
`are authorized to accept service for: RECORDS CUSTODIAN ELEVATE CARE F/K/A MENORAH HOUSE at the
`address of: 9945 N CENTRAL PARK BLVD, BOCA RATON, FL 33428, and informed said person of the contents
`therein, in compliance with state statutes.
`
`Description of Person Served: Age: 58, Sex: F, Race/Skin Color: White, Height: 5'6", Weight: 170, Hair: Light
`Brown, Glasses: Y
`
`I certify that I am over the age of 18, have no interest in the above action, and I am a Certified Process Server, in
`good standing, in the judicial circuit in which the process was served. Under penalties of perjury, I declare that I
`have read the foregoing document and that the facts stated in it are true.
`
`Donald Moore
`CPS 2047
`
`COMPASS INVESTIGATIONS
`927 S.E. 1st Street
`Pompano Beach, FL 33060
`(954) 527-5722
`
`Our Job Serial Number: JVS-2022008347
`Ref: Jennifer Grant
`
`Copyright © 1992-2022 Database Services, Inc. - Process Server's Toolbox V8.2i
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 07/01/2022 12:54:48 PM ***
`
`
`
`DELIVERED 6/29/2022 11:10 AM
`SERVER
`DM
`LICENSE
`CPS 2047
`
`IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR
`PALM BEACH COUNTY, FLORIDA
`
`In Re: Estate of
`
`ROSALIA DIGIOVANNI,
`
`CASE NO: 2022-CA-00I269
`
`Deceased._/VINCENT DIGIOVANNI, an individual,
`NOT A CERTIFIED COPY
`Respondent.__/SUBPOENA DUCES TECUM
`
`Record Custodian
`Elevate Care f/k/a Menorah House
`9945 N. Central Park Blvd
`Boca Raton, FL 33428
`YOU ARE COMMANDED to produce to undersigned counsel on or before the 7th of
`July, 2022 all records as set forth on Exhibit “A” attached to this subpoena.
`These items will be inspected and may be copied at that time. You will not be required to
`surrender the original items. You can comply with this Subpoena by providing legible copies of
`the items to be produced to: Jennifer Grant, Esq., Law Offices of Jennifer Grant, P.A., 2436 N.
`Federal Highway, Suite 410, Lighthouse Point, FL 33064 whose telephone number is (561) 595¬
`8007 and/or via email at brenna@jennifergrantlaw.com, on or before the scheduled date of the
`production. You may condition the preparation of the copies upon payment in advance for the
`
`and JOHN DIGIOVANNI, an individual,
`
`Petitioners,
`
`vs.
`
`LEONORA DATTILO, an individual.
`
`THE STATE OF FLORIDA:
`
`(records only)
`
`TO:
`
`3
`
`
`
`reasonable cost of preparation. You should contact undersigned counsel with an estimate of the
`copying charges before you begin making copies. You have the right to object to the production
`pursuant to this subpoena at any time before production by giving written notice to the attorney
`whose name appears on this
`subpoena. THIS WILL NOT BE A DEPOSITION. NO
`TESTIMONY WILL BE TAKEN.
`If you are a person with a disability who needs any accommodation in
`order to participate in this proceeding, you are entitled, at no cost to you, to
`the provision of certain assistance. Please contact Tammy Anton, Americans
`with Disabilities Act Coordinator, Palm Beach County Courthouse, 205 North
`Dixie Highway West Palm Beach, Florida 33401;
`telephone number (561)
`355-4380 at
`least 7 days before your scheduled court appearance, or
`immediately upon receiving this notification if the time before the scheduled
`appearance is less than 7 days; if you are hearing or voice impaired, call 711
`If you fail to comply with this subpoena, you may be in contempt of Court.
`You are subpoenaed to produce the documents in exhibit “A” by the following attorneys
`and unless excused from this Subpoena by these attorneys or the Court, you shall respond to this
`Subpoena as directed.
`
`WITNESS my hand and Seal of this Court on this 13th day of June, 2022.
`For the Court
`
`Jennifer N. Grant
`
`NOT A CERTIFIED COPY
`
`LAW OFFICES OF JENNIFER GRANT, P.A.
`200 East Palmetto Park Road; Suite 103
`Boca Raton, Florida 33432
`Telephone: (561) 595-8007
`Jennifer@jennifergrantlaw.com
`
`Jennifer N. Grant, Esq.
`Florida Bar No. 515051
`Brenna McGee Fitzpatrick, Esq.
`Florida Bar No. 1030962
`
`By:
`
`4
`
`
`
`EXHIBIT “A”
`DOCUMENTS REQUESTED
`
`INSTRUCTIONS
`As used herein, the following terms are defined as indicated:
`A.
`“You,” “your,” “yours,” “yourself,” to the person/entity to whom this subpoena is
`directed and includes any of its agents, representatives, attorneys, employees,
`investigators,
`partners or consultants, and any other person and/or entity acting or purporting to act on its
`behalf or under its control.
`The “relevant time period” shall mean from January 1,2019 to the present date.
`B.
`
`All medical
`records
`in your possession, custody, or control
`1.
`Digiovanni, whose date of birth was January 28, 1935.
`All notes in your possession, custody, or control
`2.
`Rosalia Digiovanni.
`All records showing the name, address and telephone number for your employees
`3.
`or independent contractors that worked with or for Rosalia.
`4.
`All
`records which relate the Rosalia’s care,
`medications.
`
`for Rosalia
`
`related to and/or regarding
`
`treatment, diagnosis, and/or
`
`5.
`
`6.
`
`7.
`
`All records related to any other doctors Rosalia saw.
`All communications between you and Leonora Dattilo.
`All communications between you and Rosalia Digiovanni.
`All evidence of payment to you for work related to Rosalia Digiovanni including
`8.
`without limitation, copies of checks.
`
`5
`
`NOT A CERTIFIED COPY
`
`