Party Discovery: Cauthon, Aysha et al vs Progressive Select Insurance Company

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                                Filing # 127339712 E-Filed 05/22/2021 05:15:43 PM



                                   IN THE COUNTY COURT OF THE 13th JUDICIAL CIRCUIT
                                        IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

                DIAGNOSTIC IMAGING CONSULTANTS                                    CASE NO.:        21-CC-034967
                OF ST. PETERSBURG, P.A. D/B/A                                     DIV:             H
                DIAGNOSTIC IMAGING CONSULTANTS,
                         as assignee of Aysha Cauthon
                         Plaintiff,
                vs.

                PROGRESSIVE SELECT INSURANCE
                COMPANY,
                         Defendant.
                ______________________________________/

                              PLAINTIFF’S SECOND REQUEST FOR ADMISSIONS RE: LIMITING

                         COMES       NOW,     the  Plaintiff, by  and   through   undersigned    counsel,   pursuant   to  Rule  1.370,

                Florida   Rules  of  Civil  Procedure    and   Small   Claims    Rule   7.020,  hereby   requests   the  Defendant    to

                admit that the following statements are true:

                          1.      Defendant allowed the following amounts for the CPT Codes at issue in this claim:

                         CPT CODE:                  Allowed by Defendant:

                         72040-26                   $22.88
                         72100-26                   $22.88
                         72070-26                   $22.88

                         2.       The allowed amount(s) indicated in Plaintiff’s Request for Admission # 1 were not
                calculated based on 200% of Medicare Part B’s Non-Facility Limiting Charge for 2007.

                         3.       The following amounts for the CPT Code(s) at issue in this claim represent 200% of
                Medicare Part B’s Non-Facility Limiting Charge for 2007.

                         CPT CODE:

                         72040-26                   $23.02
                         72100-26                   $23.02
                         72070-26                   $23.02




5/22/2021 5:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
                         ANSWERS OR OBJECTIONS, if any, must be served upon the undersigned Attorney, at the
                below   noted   address,  on  or  before  thirty  (30)  days  after  service  hereof.   Otherwise    these  statements
                shall be deemed admitted.

                                                         CERTIFICATE OF SERVICE

                I HEREBY        CERTIFY       that  a true and   correct copy    of the forgoing     was   electronically   served via
                the  Florida   Courts   E-Filing   Portal,  on  Jaimee    R.  Goode,    Esq.,  TampaPIPHC1@Progressive.com,
                Progressive PIP House Counsel, 600 N. Westshore Blvd., Suite 300, Tampa, FL 33609, on May 22,
                2021.



                                                                                                                ____
                                                                               Lorca J. Divale - FBN: 0173622
                                                                               The Physician Collections Group, P.A.
                                                                               701 S. Howard Ave., Ste. 106-391
                                                                               Tampa, Florida      33606
                                                                               (813) 600-3029; LorcaDLG@gmail.com
                                                                               Attorneys for the Plaintiff




5/22/2021 5:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2