On April 12, 2021 a
Party Discovery
was filed
involving a dispute between
Advanced Spinal Care,
Integrated Health Solutions, Pl,
Steers, Samantha,
and
Allstate Insurance Company, A Foreign Corporation,
for Civil
in the District Court of Hillsborough County.
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Filing # 124765244 E-Filed 04/12/2021 04:19:40 PM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
SMALL CLAIMS DIVISION
INTEGRATED HEALTH SOLUTIONS, PL,
D/B/A ADVANCED SPINAL CARE, a/a/o
Samantha Steers.
Plaintiff, CASE NO:
DIVISION:
vs.
ALLSTATE INSURANCE COMPANY,
a foreign corporation
Defendant.
___________________________________/
PLAINTIFF’S REQUEST FOR ADMISISONS TO DEFENDANT
COMES NOW the Plaintiff, INTEGRATED HEALTH SOLUTIONS, PL, D/B/A
ADVANCED SPINAL CARE, a/a/o Samantha Steers, pursuant to Florida Rules of Civil
Procedure 1.370, by and through undersigned counsel, hereby files Plaintiff’s Request for
Admissions, and request the Defendant admit or deny the following within thirty (30) days from
the date of service thereof;
1. At all times material to the Complaint, Defendant was and is a foreign corporation
licensed to do business in the State of Florida and engages in the business of automobile
insurance.
2. Defendant maintains agents in Hillsborough County.
3. At the time of the accident referenced in the Complaint, Samantha Steers was insured
under an automobile insurance policy issued by Defendant.
4. The above styled Court, has jurisdiction over the parties and subject matter of Plaintiff’s
claim against the Defendant.
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5. Defendant’s automobile insurance policy that covered Samantha Steers on 05/12/2020,
provided coverage for PIP benefits to Samantha Steers for bodily injuries sustained as a
result of the subject motor vehicle accident.
6. Defendant’s automobile insurance policy that covered Samantha Steers on 05/12/2020,
provided coverage for Medical Payments benefits to Samantha Steers for bodily injuries
sustained as a result of the subject motor vehicle accident.
7. Samantha Steers sustained injuries as a result of the motor vehicle accident on
05/12/2020 as plead in the Plaintiff’s Complaint.
8. Defendant has been furnished with written notice of a covered loss and the amount of the
same with regard to Plaintiff’s claim for personal injury protection benefits which are at
issue in this lawsuit.
9. Defendant received all medical bills from Plaintiff which are at issue in this case within
thirty-five (35) days of the date of service.
10. Plaintiff’s medical expenses submitted by the Plaintiff to the Defendant which have not
yet been paid were reasonable in amount.
11. Plaintiff’s medical expenses submitted by the Plaintiff to the Defendant which have not
yet been paid were related to the motor vehicle accident on 05/12/2020.
12. Plaintiff’s medical expenses submitted by Plaintiff to the Defendant which have not yet
been paid were necessary.
13. All benefits paid on behalf of Samantha Steers for the subject motor vehicle accident
have been for reasonable, related and necessary medical, rehabilitative or remedial
treatment for services.
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14. Defendant has not obtained a compulsory medical examination or independent medical
examination report regarding the treatment, services, or supplies provided to Samantha
Steers as a result of the subject motor vehicle accident.
15. Defendant has not refused to pay Personal Injury Protection benefits on behalf of
Samantha Steers based on the results of a compulsory medical examination or
independent medical examination.
16. Samantha Steers has not unreasonably refused to attend a compulsory medical
examination or independent medical examination.
17. Defendant has not conducted an examination under oath of Samantha Steers.
18. Defendant has not conducted a recorded statement of Samantha Steers.
19. Samantha Steers personal injury benefits from the subject motor vehicle accident have
not been exhausted.
20. Defendant did not make a request to Plaintiff for additional medical information pursuant
to Fla. Stat. 627.736(6)(b).
21. Plaintiff is entitled to a Load Star multiplier for attorney’s fees if Plaintiff prevails in this
matter.
22. Plaintiff has complied with all conditions precedent prior to filing this Complaint.
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
Defendant by e-mail service, pursuant to Rule 2.516, using the Florida Courts E-Filing Portal’s
Notice of Electronic Filing, on April 12, 2021.
Respectfully submitted,
___/s/ Jonathan J. Cagan____________
Jonathan J. Cagan, Esq.
Florida Bar No. 92712
Cagan & Cagan PLLC
121 W. Forsyth St. Ste. 810
Jacksonville, FL 32202
Primary Email: filings@caganlaw.com
Secondary Email: jcagan@caganlaw.com
(904) 990-4747
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Document Filed Date
April 12, 2021
Case Filing Date
April 12, 2021
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Filing # 124765244 E-Filed 04/12/2021 04:19:40 PM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SMALL CLAIMS DIVISION INTEGRATED HEALTH SOLUTIONS, PL, D/B/A ADVANCED SPINAL CARE, a/a/o Samantha Steers. Plaintiff, CASE NO: DIVISION: vs. ALLSTATE INSURANCE COMPANY, a foreign corporation Defendant. ___________________________________/ PLAINTIFF’S REQUEST FOR ADMISISONS TO DEFENDANT COMES NOW the Plaintiff, INTEGRATED HEALTH SOLUTIONS, PL, D/B/A ADVANCED SPINAL CARE, a/a/o Samantha Steers, pursuant to Florida Rules of Civil Procedure 1.370, by and through undersigned counsel, hereby files Plaintiff’s Request for Admissions, and request the Defendant admit or deny the following within thirty (30) days from the date of service thereof; 1. At all times material to the Complaint, Defendant was and is a foreign corporation licensed to do business in the State of Florida and engages in the business of automobile insurance. 2. Defendant maintains agents in Hillsborough County. 3. At the time of the accident referenced in the Complaint, Samantha Steers was insured under an automobile insurance policy issued by Defendant. 4. The above styled Court, has jurisdiction over the parties and subject matter of Plaintiff’s claim against the Defendant. 1 4/12/2021 4:19 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 5. Defendant’s automobile insurance policy that covered Samantha Steers on 05/12/2020, provided coverage for PIP benefits to Samantha Steers for bodily injuries sustained as a result of the subject motor vehicle accident. 6. Defendant’s automobile insurance policy that covered Samantha Steers on 05/12/2020, provided coverage for Medical Payments benefits to Samantha Steers for bodily injuries sustained as a result of the subject motor vehicle accident. 7. Samantha Steers sustained injuries as a result of the motor vehicle accident on 05/12/2020 as plead in the Plaintiff’s Complaint. 8. Defendant has been furnished with written notice of a covered loss and the amount of the same with regard to Plaintiff’s claim for personal injury protection benefits which are at issue in this lawsuit. 9. Defendant received all medical bills from Plaintiff which are at issue in this case within thirty-five (35) days of the date of service. 10. Plaintiff’s medical expenses submitted by the Plaintiff to the Defendant which have not yet been paid were reasonable in amount. 11. Plaintiff’s medical expenses submitted by the Plaintiff to the Defendant which have not yet been paid were related to the motor vehicle accident on 05/12/2020. 12. Plaintiff’s medical expenses submitted by Plaintiff to the Defendant which have not yet been paid were necessary. 13. All benefits paid on behalf of Samantha Steers for the subject motor vehicle accident have been for reasonable, related and necessary medical, rehabilitative or remedial treatment for services. 2 4/12/2021 4:19 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 14. Defendant has not obtained a compulsory medical examination or independent medical examination report regarding the treatment, services, or supplies provided to Samantha Steers as a result of the subject motor vehicle accident. 15. Defendant has not refused to pay Personal Injury Protection benefits on behalf of Samantha Steers based on the results of a compulsory medical examination or independent medical examination. 16. Samantha Steers has not unreasonably refused to attend a compulsory medical examination or independent medical examination. 17. Defendant has not conducted an examination under oath of Samantha Steers. 18. Defendant has not conducted a recorded statement of Samantha Steers. 19. Samantha Steers personal injury benefits from the subject motor vehicle accident have not been exhausted. 20. Defendant did not make a request to Plaintiff for additional medical information pursuant to Fla. Stat. 627.736(6)(b). 21. Plaintiff is entitled to a Load Star multiplier for attorney’s fees if Plaintiff prevails in this matter. 22. Plaintiff has complied with all conditions precedent prior to filing this Complaint. 3 4/12/2021 4:19 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to Defendant by e-mail service, pursuant to Rule 2.516, using the Florida Courts E-Filing Portal’s Notice of Electronic Filing, on April 12, 2021. Respectfully submitted, ___/s/ Jonathan J. Cagan____________ Jonathan J. Cagan, Esq. Florida Bar No. 92712 Cagan & Cagan PLLC 121 W. Forsyth St. Ste. 810 Jacksonville, FL 32202 Primary Email: filings@caganlaw.com Secondary Email: jcagan@caganlaw.com (904) 990-4747 4 4/12/2021 4:19 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4