Party Notice: THE RIGHT SPINAL CLINIC, INC. VS GEICO GENERAL INS. CO.

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                                Filing # 141202328 E-Filed 01/03/2022 10:51:15 AM



                                                                           IN THE COUNTY COURT OF THE 11TH JUDICIAL
                                                                           CIRCUIT IN AND FOR MIAMI-DADE COUNTY,
                                                                           FLORIDA

                THE RIGHT SPINAL CLINIC, INC. A/A/O LOIDA GENERAL JURISDICTION DIVISION
                HERNANDEZ,                                CASE NO. 2021-009772-CC-21
                        Plaintiff/s
                vs.
                GEICO INDEMNITY COMPANY,
                       Defendant/s
                ____________________________________/
                                         DEFENDANT’S PROPOSAL FOR SETTLEMENT TO PLAINTIFF

                            Defendant, by and through undersigned counsel, state that at least 90 days have passed since the

                commencement of this action, and there are at least 45 days remaining before the date set for trial or the

                first day of the docket on which this case is set for trial, whichever is earlier. THEREFORE, Defendant(s)

                hereby serves this proposal for settlement pursuant to Florida Rule of Civil Procedure 1.442 and F.S.

                768.79. This proposal for settlement must be accepted in writing, within thirty (30) days or it shall be

                deemed rejected. The Proposal for Settlement is as follows:

                            1.       This Proposal for Settlement is being made pursuant to § 768.79 Fla. Stat., by the Defendant

                            to the Plaintiff.

                            2.       This Proposal for Settlement is an attempt to resolve all Personal Injury Protection (PIP)

                            claims, Personal Injury Protection (PIP) causes of action, PIP benefits and interest thereon, and

                            attorneys’ fees and costs, resulting from the incident or accident giving rise to this Personal Injury

                            Protection (PIP) lawsuit.

                            3.       The Defendant will pay the Plaintiff the total sum of one dollars and fifity Cents ($0.50 in

                            benefits and $.50 which includes attorneys’ fees and costs).

                            4.       In exchange for the payment set forth above, the Plaintiff will dismiss this Personal Injury

                            Protection (PIP) lawsuit with prejudice.




Sensitivity: Confidential
                            5.        This Proposal for Settlement is made in alternative to, and not in addition to, any other offer

                            to settle of any type, including but not limited to, oral offers, written offers, Offers of Settlement,

                            Offers of Judgment, or Proposals for Settlement, which either have been made or will be made in the

                            future.

                            6.        ACCEPTANCE AND REJECTION: This Proposal shall be deemed by the Plaintiff(s) to be

                            rejected unless accepted by delivery of a written notice of acceptance within thirty (30) days after

                            service of the Proposal. The provisions of Florida Rule of Civil Procedure 1.090(e) do not apply to this

                            Proposal. No oral communications shall constitute an acceptance, rejection or counteroffer of this

                            Proposal.

                            7. CONSEQUENCES OF REJECTION: In the event this proposal is rejected, the Defendant(s) is/are

                            subject to sanctions, including, but not limited to, those as outlined in Rules 1.442(g) and (h) of the

                            Florida Rules of Civil Procedure, Fla. Stat. 768.79 and any other relief Plaintiff(s) is/are entitled to as a

                            matter of law and which the Court deems just and proper.

                                                           CERTIFICATE OF SERVICE
                            I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic
                Mail on this the 3rd day of January, 2022 to the following designated service email address(es)
                serviceELG@theevolutionlawgroup.com




                                                                       LAW OFFICE OF HAYDEE DE LA ROSA-TOLGYESI


                                                                         /s/ Marcus Griggs, Esq.
                                                                       Marcus Griggs, Esq
                                                                       (Employees of GEICO General Insurance Company)
                                                                       Florida Bar No.: 696021
                                                                       806 S. Douglas Road, South Tower, Suite 570
                                                                       Coral Gables, Fl 33134
                                                                       Phone: (786) 483-1854
                                                                       Fax: (305) 373-3661




Sensitivity: Confidential
                            Attorney for Defendant: GEICO General Insurance Company,
                            Service Email: Miamipipgeico@geico.com




Sensitivity: Confidential