On September 21, 2021 a
Party Discovery
was filed
involving a dispute between
Bowles, William,
Florida Physical Medicine, Llc,
and
Allstate Indemnity Company,
for Civil
in the District Court of Hillsborough County.
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Filing # 136356033 E-Filed 10/12/2021 10:30:25 AM
Florida Physical Medicine, LLC a/a/o William IN THE COUNTY COURT IN AND FOR
Bowles, HILLSBOROUGH COUNTY, FLORIDA
Plaintiff, CASE NO.: 21-CC-097777
vs.
Allstate Indemnity Company,
Defendant,
______________________________/
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS
COMES NOW the Plaintiff, by and through the undersigned attorney, and files this
REQUEST FOR ADMISSIONS to Defendant pursuant to R.1.370 and in support thereof requests the
following:
1. Admit that the patient qualified for PIP coverage with Defendant for the motor vehicle
accident (“MVA”).
2. Admit that PIP benefits are not exhausted.
3. Admit that the patient was injured in the MVA.
4. Admit that patient obtained reasonable medical care, services and/or supplies from Plaintiff
for the MVA.
5. Admit that the patient obtained medically necessary medical care, services and/or supplies
from Plaintiff for the MVA.
6. Admit that the patient obtained medical care, services and/or supplies from Plaintiff related to
the MVA.
7. Admit that a qualified medical provider determined that the patient had an Emergency
Medical Condition.
8. Admit that all conditions precedent were completed by Plaintiff and the patient.
9. Admit that Defendant is not alleging fraud in this claim or case.
10. Admit that a PIP deductible does not apply to this claim.
11. Admit that no other provider is owed additional benefits.
12. Admit that the Explanations of Review/Reimbursements/Benefits do not show that additional
benefits are owed.
10/12/2021 10:30 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
13. Admit that PIP is not governed by the English rule of priorities. See Northwoods Sports Med.
& Physical Rehab., Inc. v. State Farm Mut. Auto. Ins. Co., 137 So. 3d 1049 (Fla. 4th DCA
2014).
14. Admit that PIP only covers valid claims.
15. Admit that allowable/approved amounts on Explanations of Review/Reimbursements/Benefits
do not show the service is reasonable, related, and necessary.
16. Admit that Defendant agrees that the policy includes Medicare coding and payment
methodologies for PIP.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was uploaded and served
via the e-filing portal on October 12, 2021 and has been forwarded through email (via e-filing portal
designated email addresses) to counsel for the Defendant.
PIP PORTAL LAW GROUP, P.A. (formerly)
8551 W. Sunrise Blvd, Suite 304
Plantation, FL 33322
p. (954) 741-2000
f. (954) 337-4642
e. PIPPortalLaw@gmail.com (primary)
By: /s/John C. Daly____
JOHN C. DALY, ESQ.
Florida Bar No.: 98363
MATTHEW C. BARBER, ESQ.
Florida Bar No.: 63822
10/12/2021 10:30 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Document Filed Date
October 12, 2021
Case Filing Date
September 21, 2021
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Filing # 136356033 E-Filed 10/12/2021 10:30:25 AM Florida Physical Medicine, LLC a/a/o William IN THE COUNTY COURT IN AND FOR Bowles, HILLSBOROUGH COUNTY, FLORIDA Plaintiff, CASE NO.: 21-CC-097777 vs. Allstate Indemnity Company, Defendant, ______________________________/ PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS COMES NOW the Plaintiff, by and through the undersigned attorney, and files this REQUEST FOR ADMISSIONS to Defendant pursuant to R.1.370 and in support thereof requests the following: 1. Admit that the patient qualified for PIP coverage with Defendant for the motor vehicle accident (“MVA”). 2. Admit that PIP benefits are not exhausted. 3. Admit that the patient was injured in the MVA. 4. Admit that patient obtained reasonable medical care, services and/or supplies from Plaintiff for the MVA. 5. Admit that the patient obtained medically necessary medical care, services and/or supplies from Plaintiff for the MVA. 6. Admit that the patient obtained medical care, services and/or supplies from Plaintiff related to the MVA. 7. Admit that a qualified medical provider determined that the patient had an Emergency Medical Condition. 8. Admit that all conditions precedent were completed by Plaintiff and the patient. 9. Admit that Defendant is not alleging fraud in this claim or case. 10. Admit that a PIP deductible does not apply to this claim. 11. Admit that no other provider is owed additional benefits. 12. Admit that the Explanations of Review/Reimbursements/Benefits do not show that additional benefits are owed. 10/12/2021 10:30 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 13. Admit that PIP is not governed by the English rule of priorities. See Northwoods Sports Med. & Physical Rehab., Inc. v. State Farm Mut. Auto. Ins. Co., 137 So. 3d 1049 (Fla. 4th DCA 2014). 14. Admit that PIP only covers valid claims. 15. Admit that allowable/approved amounts on Explanations of Review/Reimbursements/Benefits do not show the service is reasonable, related, and necessary. 16. Admit that Defendant agrees that the policy includes Medicare coding and payment methodologies for PIP. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was uploaded and served via the e-filing portal on October 12, 2021 and has been forwarded through email (via e-filing portal designated email addresses) to counsel for the Defendant. PIP PORTAL LAW GROUP, P.A. (formerly) 8551 W. Sunrise Blvd, Suite 304 Plantation, FL 33322 p. (954) 741-2000 f. (954) 337-4642 e. PIPPortalLaw@gmail.com (primary) By: /s/John C. Daly____ JOHN C. DALY, ESQ. Florida Bar No.: 98363 MATTHEW C. BARBER, ESQ. Florida Bar No.: 63822 10/12/2021 10:30 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2