Party Discovery: KINGDOM CHIROPRACTIC,Lafleur, Juliana vs INFINITY AUTO INSURANCE COMPANY

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                                Filing # 140081877 E-Filed 12/09/2021 05:34:58 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,

                    ______________________________/

                       SUPPLEMENTAL REQUEST FOR PRODUCTION REGARDING RELATEDNESS
                                                          AND MEDICAL NECESSITY

                             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)   All documents that demonstrate that the injuries which Plaintiff assert are related to the

                             automobile     accident   are  actually   related  to  a worker’s    compensation      claim   or  injury

                             resulting from claimant’s job.

                         2)   All documents that demonstrate that the injuries which Plaintiff assert are related to the

                             automobile accident are in fact related to a sports-related injury of the claimant.

                         3)   All medical reports including Independent Medical              Examination (“IME”) and/ or Peer

                             Review reports which Defendant requested for this claim.

                         4)   All addendums to the medical reports produced in response to Request to Product No. 3

                             above.


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                         5)   All documents sent      to the IME and/or Peer Review           Doctor that   were reviewed      for the

                             purposes of drafting the IME/Peer Review Report Addendum in this case.

                         6)   All  medical   records   submitted    from    any  other  medical    provider    besides   Plaintiff  for

                             medical    treatment    and/or   services    provided    to  claimant.    This   request   includes    all

                             documents, notes, medical reports, and paperwork submitted to Defendant on behalf of

                             the referring medical provider(s).

                         7)   A copy of the most updated and current PIP payout log for this claim.

                         8)   All  invoices   received    by   Defendant     for  the  IME    and/or   Peer   Review     reports   that

                             Defendant requested in this case.

                         9)   All documents Defendant is relying on as a basis to contest relatedness and/or medical

                             necessity in this case.

                         10) All  documents sent      to the IME and/or Peer Review           Doctor that   were reviewed      for the

                             purposes of drafting the IME and/or Peer Review Report for this claim.

                         11) All documents Defendant has in its possession evidencing that the services provided by

                             Plaintiff were not related to the underlying accident.

                         12) All documents Defendant has in its possession evidencing that the services provided by

                             Plaintiff were not medically necessary.

                         13) All   Explanation    of  Benefits    or Explanations     of  Review    issued   to  any   provider   who

                             submitted bills relating to claimant’s claim for PIP benefits.

                    It is hereby requested that the aforesaid production be made within thirty (30) days from the
                    date of service at the undersigned law office.



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12/9/2021 5:34 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
                                                         CERTIFICATE OF SERVICE

                             I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-

                    Mail on December 9, 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




                    [2711-00179/37858748/1]




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