On April 09, 2021 a
Party Discovery
was filed
involving a dispute between
Kingdom Chiropractic,
Lafleur, Juliana,
and
Infinity Auto Insurance Company,
for Civil
in the District Court of Hillsborough County.
Preview
Filing # 140383951 E-Filed 12/14/2021 06:31:43 PM
KINGDOM CHIROPRACTIC I N THE COUNTY COURT IN AND FOR
a/a/o Juliana Lafleur HILLSBOROUGH COUNTY, FLORIDA
Plaintiff,
CASE NO.: 21-CC-034152 DIV M
vs.
INFINITY AUTO INSURANCE COMPANY
Defendant,
______________________________/
PLAINTIFF’S SUPPLEMENTAL REQUEST FOR PRODUCTION REGARDING
EXPERT WITNESS
COMES NOW, Plaintiff, by and through the undersigned attorneys, and pursuant to
Florida Rule of Civil Procedure 1.350, and requests Defendant to produce for inspection and
copying at the office of the undersigned attorney within thirty (30) days after service of this
request on Defendant the following:
1. Copies of retained expert’s report for this claim.
2. Copies of all documents and/or correspondence to and from retained expert for
this case regarding this claim and/or claimant.
3. Copies of any invoices or bills from the retained expert for this case to
Defendant for this claim and/or claimant.
4. Copies of any checks or payments made to the retained expert for this case for
this claim and/or claimant.
5. Copies of any and all 1099s for retained expert for this case for the past 5 years.
6. Copies of the retained expert for this case reports submitted to Defendant for the
last 3 years. Any patient names or IDs may be redacted.
[2711-00179/37866078/1]
12/14/2021 6:31 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
7. A list of cases wherein the retained expert for this case has be qualified as an
expert for pricing of medical charges or payments in a PIP claim.
8. Copies of the retained expert for this case trial testimonies for the last 3 years.
9. Copies of the retained expert for this case depositions testimonies for the last 3
years.
10. A list of medical providers the retained expert for this case has contacted in the
last 5 years to determine pricing of medical charges.
11. All documents the retained expert for this case relies on to form their opinion.
12. A list of cases wherein the retained expert for this case has been retained as an
expert for the last 3 years.
13. Copies of any retainer and/or vendor agreement with the retained expert for this
case.
14. Copy of all resumes and CVs for the retained expert for this case for the last 3
years.
15. Copies of any HIPAA Associates Agreement or privacy agreement with the
retained expert for this case.
16. A list of cases wherein the retained expert for this case has testified as an expert
in the last 3 years.
17. A list of training workshops the retained expert for this case has attended or
conducted in the last 5 years.
18. A copy of the correspondence from Defense counsel to the retained expert for
this case in the last 3 years.
[2711-00179/37866078/1]
12/14/2021 6:31 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
19. A list of insurance companies and payors the retained expert for this case is
familiar with for amounts reimbursed or paid for similar charges in this case.
20. A list of all of the retained expert for this case clients for which does medical
billing or coding in the last 3 years.
It is hereby requested that the aforesaid production be made within thirty (30) days from the date
of service at the undersigned law office.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-
Mail on December 14, 2021 to: Amanda Duran, Esq., Law Office of Leslie M. Goodman &
Associates, browardlegal@ipacc.com.
LANDAU & ASSOCIATES, P.A.
1619 NW 136th Avenue
Suite 2C
Sunrise, FL 33323
Telephone (954) 744-8383
Facsimile (954) 391-7805
Email: efilings@pip-lawyers.com
By:
JASON GRAY, ESQ.
Florida Bar No. 94011
[2711-00179/37866078/1]
12/14/2021 6:31 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
Document Filed Date
December 14, 2021
Case Filing Date
April 09, 2021
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Filing # 140383951 E-Filed 12/14/2021 06:31:43 PM KINGDOM CHIROPRACTIC I N THE COUNTY COURT IN AND FOR a/a/o Juliana Lafleur HILLSBOROUGH COUNTY, FLORIDA Plaintiff, CASE NO.: 21-CC-034152 DIV M vs. INFINITY AUTO INSURANCE COMPANY Defendant, ______________________________/ PLAINTIFF’S SUPPLEMENTAL REQUEST FOR PRODUCTION REGARDING EXPERT WITNESS COMES NOW, Plaintiff, by and through the undersigned attorneys, and pursuant to Florida Rule of Civil Procedure 1.350, and requests Defendant to produce for inspection and copying at the office of the undersigned attorney within thirty (30) days after service of this request on Defendant the following: 1. Copies of retained expert’s report for this claim. 2. Copies of all documents and/or correspondence to and from retained expert for this case regarding this claim and/or claimant. 3. Copies of any invoices or bills from the retained expert for this case to Defendant for this claim and/or claimant. 4. Copies of any checks or payments made to the retained expert for this case for this claim and/or claimant. 5. Copies of any and all 1099s for retained expert for this case for the past 5 years. 6. Copies of the retained expert for this case reports submitted to Defendant for the last 3 years. Any patient names or IDs may be redacted. [2711-00179/37866078/1] 12/14/2021 6:31 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 7. A list of cases wherein the retained expert for this case has be qualified as an expert for pricing of medical charges or payments in a PIP claim. 8. Copies of the retained expert for this case trial testimonies for the last 3 years. 9. Copies of the retained expert for this case depositions testimonies for the last 3 years. 10. A list of medical providers the retained expert for this case has contacted in the last 5 years to determine pricing of medical charges. 11. All documents the retained expert for this case relies on to form their opinion. 12. A list of cases wherein the retained expert for this case has been retained as an expert for the last 3 years. 13. Copies of any retainer and/or vendor agreement with the retained expert for this case. 14. Copy of all resumes and CVs for the retained expert for this case for the last 3 years. 15. Copies of any HIPAA Associates Agreement or privacy agreement with the retained expert for this case. 16. A list of cases wherein the retained expert for this case has testified as an expert in the last 3 years. 17. A list of training workshops the retained expert for this case has attended or conducted in the last 5 years. 18. A copy of the correspondence from Defense counsel to the retained expert for this case in the last 3 years. [2711-00179/37866078/1] 12/14/2021 6:31 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 19. A list of insurance companies and payors the retained expert for this case is familiar with for amounts reimbursed or paid for similar charges in this case. 20. A list of all of the retained expert for this case clients for which does medical billing or coding in the last 3 years. It is hereby requested that the aforesaid production be made within thirty (30) days from the date of service at the undersigned law office. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E- Mail on December 14, 2021 to: Amanda Duran, Esq., Law Office of Leslie M. Goodman & Associates, browardlegal@ipacc.com. LANDAU & ASSOCIATES, P.A. 1619 NW 136th Avenue Suite 2C Sunrise, FL 33323 Telephone (954) 744-8383 Facsimile (954) 391-7805 Email: efilings@pip-lawyers.com By: JASON GRAY, ESQ. Florida Bar No. 94011 [2711-00179/37866078/1] 12/14/2021 6:31 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3