Complaint,Petition: Government Employees Insurance Co., Geico Indemnity Co., Geico General Insurance Company, Geico Casualty Co. v. Altai Corp. d/b/a Get Ready Medical Supply

On August 31, 2023 a Complaint,Petition was filed involving a dispute between Geico Casualty Co., Geico General Insurance Company, Government Employees Insurance Co., and Altai Corp. D B A Get Ready Medical Supply, for Commercial - Insurance in the District Court of Nassau County.

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FILED: NASSAU COUNTY CLERK 08/31/2023 03:58 PM INDEX NO. 614141/2023
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
---------------------------------------------------------------------X Index Number:
Government Employees Insurance Co., GEICO Indemnity Co., Date Purchased:
GEICO General Insurance Company and GEICO Casualty Co.
(collectively “GEICO”),

Plaintiff, SUMMONS

-against- Plaintiff designates Nassau
County as the place of trial.
Altai Corp. d/b/a Get Ready Medical Supply, The basis of the venue designated is:
Plaintiff’s and Defendant’s place
of business and residence
CPLR §§ 503(A) and (C)

Defendant.
---------------------------------------------------------------------X

SUMMONS

TO THE ABOVE NAMED DEFENDANT(S):

YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a
copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice of
Appearance, on the plaintiff’s attorney(s) within 20 days after the service of this Summons, exclusive
of the day of service; or within 30 days after the service is complete if this Summons is not personally
delivered to you within the State of New York; and in case of your failure to appear or answer,
judgment will be taken against you by default for the relief demanded in the complaint.

Dated: Melville, New York
August 25, 2023
Respectfully,
Law Office of Goldstein & Hopkins
GEICO Staff Counsel

By: ______________________________
Rachel S. Hochhauser, Esq.
Attorneys for Plaintiff
2 Huntington Quadrangle
Suite 1N01
Melville, New York 11747
(516) 714-7404

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To: Altai Corp. d/b/a Get Ready Medical Supply
Defendant
7122 Bay Parkway, Floor 2
Brooklyn, New York 11204

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
---------------------------------------------------------------------X
Government Employees Insurance Co., GEICO Indemnity Co.,
GEICO General Insurance Company and GEICO Casualty Co. Index Number:
(collectively “GEICO”),

Plaintiffs,
-against-

Altai Corp. d/b/a Get Ready Medical Supply,

Defendant.
---------------------------------------------------------------------X

VERIFIED COMPLAINT

Plaintiffs GEICO (collectively, “Plaintiffs”), by and through its counsel, Law Office of Goldstein &

Hopkins, as and for its Verified Complaint against Defendant, hereby allege as follows:

PRELIMINARY STATEMENT

1. This is an action for a declaratory judgment pursuant to CPLR §3001 in which GEICO

seeks a determination that it is not legally obligated to pay Altai Corp. d/b/a Get Ready Medical

Supply (“Provider” or “Defendant”) for claims that Defendant has submitted to GEICO seeking

reimbursement for durable medical equipment (“DME”) that were allegedly rendered to individuals

who were involved in automobile accidents and eligible for coverage under GEICO insurance policies

(“Insureds”) in New York. GEICO seeks this judicial determination because Defendant has

systemically failed and/or refused to appear for examinations under oath (“EUOs”) that have been

requested by GEICO, which constitutes a failure by Defendant to meet a condition precedent to

coverage and a violation of its obligations under the No-Fault Laws. The claims at issue in this

declaratory judgment action are identified on Exhibit “A.”

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2. This action seeks a declaration that Defendant is not entitled to receive No-Fault

reimbursements as Defendant failed to meet a condition precedent to coverage as set forth in the No-

Fault Regulation and the underlying policies of insurance.

NATURE OF ACTION

3. GEICO alleges that Altai Corp. d/b/a Get Ready Medical Supply failed to meet a

condition precedent to coverage by failing to appear for Examinations Under Oath (“EUOs”).

4. The EUOs of Altai Corp. d/b/a Get Ready Medical Supply were requested pursuant to

the terms and conditions of the applicable policies of insurance and the No-Fault Regulations.

5. By failing to appear for EUOs, Altai Corp. d/b/a Get Ready Medical Supply breached

a material condition precedent to coverage under the applicable insurance policies and the No Fault

Regulations. The failure of Altai Corp. d/b/a Get Ready Medical Supply to meet the condition

precedent to coverage vitiates GEICO’s obligation to honor any bills submitted by Altai Corp. d/b/a

Get Ready Medical Supply for reimbursement pursuant to the Insurance Law and the No Fault

Regulation for which EUOs of Altai Corp. d/b/a Get Ready Medical Supply were requested and Altai

Corp. d/b/a Get Ready Medical Supply failed to appear.

6. As such, Altai Corp. d/b/a Get Ready Medical Supply is not entitled to seek, keep or

receive No-Fault reimbursements from GEICO for all claims in which EUOs of Altai Corp. d/b/a Get

Ready Medical Supply were requested and which Altai Corp. d/b/a Get Ready Medical Supply failed

to appear.

7. Additionally, GEICO is not obligated to pay reimbursement for any No-Fault related

matters pertaining to the claims in which EUOs of Altai Corp. d/b/a Get Ready Medical Supply were

requested and Altai Corp. d/b/a Get Ready Medical Supply failed to appear.

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8. GEICO seeks a declaration that as a result of the failure of Altai Corp. d/b/a Get Ready

Medical Supply to appear for EUOs, Altai Corp. d/b/a Get Ready Medical Supply has no standing or

legal right to seek, keep or receive No-Fault reimbursements from GEICO because Defendant has

systematically failed and/or refused to appear for EUOs.

9. Accordingly, GEICO requests a judgment pursuant to CPLR §3001, declaring that

Altai Corp. d/b/a Get Ready Medical Supply has no right to receive payment for the bills submitted

to GEICO and listed on Exhibit “A” because it failed and/or refused to appear for an EUO requested

by GEICO, and thus breached a condition of coverage and violated its obligations under the No-Fault

Laws.

PARTIES

10. GEICO is a New York insurer that is duly authorized to issue automobile insurance

policies in the State of New York. GEICO maintains an office to conduct business relating to the

administration of claims in Melville, New York.

11. 11. Defendant Altai Corp. d/b/a Get Ready Medical Supply is a professional

service corporation with its principal place of business at 7122 Bay Parkway, Floor 2, Brooklyn, New

York. Altai Corp. was incorporated on or about January 23, 2017. At all relevant times, Get Ready

Medical Supply has conducted business in the State of New York, including but not limited to: at

7122 Bay Parkway, Floor 2, Brooklyn, New York.

JURISDICTION AND VENUE

12. This Court has jurisdiction over Defendant because it is a New York DME supplier

that conducts business within New York State, the insurance policies were issued by GEICO in New

York and the conduct which forms the basis for this declaratory judgment occurred in the State of

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New York. Venue is proper in the County of Nassau pursuant to C.P.L.R. §503(a) inasmuch as

GEICO conducts business in Nassau County.

ALLEGATIONS COMMON TO ALL CAUSES OF ACTION

I. An Overview of the No-Fault Laws and NY Licensing Laws

13. GEICO underwrites automobile insurance in the State of New York.

14. Under New York’s Comprehensive Motor Vehicle Insurance Reparations Act (N.Y.

Ins. Law §§ 5101, et seq.) and the regulations promulgated pursuant thereto (11 N.Y.C.R.R. §§ 65, et

seq.) (collectively referred to as the “No-Fault Laws”), automobile insurers are required to provide

Personal Injury Protection Benefits (“No-Fault Benefits”) to Insureds.

15. No-Fault Benefits include up to $50,000.00 per insured for necessary expenses that

are incurred for healthcare goods and services. In addition to reimbursement for healthcare goods and

services, insured parties may receive up to $2,000.00 per month to cover loss of earnings from work

as an element of their $50,000.00 maximum benefit.

16. Under the No-Fault Laws, Insureds can assign their right to No-Fault Benefits to

professional health service providers and/or DME suppliers, as long as the providers meet applicable

New York State and local licensing requirements to perform such services in New York. With a duly

executed assignment, a healthcare provider may submit claims directly to an insurance company and

receive payment for necessary medical services rendered, using the claim form approved by the New

York State Department of Insurance (known as the “Verification of Treatment by Attending Physician

or Other Provider of Health Service” or, more commonly, as an “NF-3”). Once the healthcare

provider takes an assignment of an Insured’s rights, the provider cannot seek to recover payment from

the Insured.

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17. Finally, pursuant to N.Y. Ins. Law § 403, all bills submitted by a healthcare provider

and/or DME supplier to GEICO and all other insurers must be verified by the healthcare provider

subject to the following warning:

Any person who knowingly and with intent to defraud any insurance company or other
person files an application for insurance or statement of claim containing any
materially false information, or conceals for the purpose of misleading, information
concerning any fact material thereto, commits a fraudulent insurance act, which is a
crime …

18. Under the New York State Medicaid Program, the maximum permissible charge for

DME and orthotic devices is the fee amount that is mandated to be billed and paid for the DME and

orthotic devices at the time such DME and orthotic devices are provided. Specifically, in Gov’t

Emples. Ins. Co. v. Li-Elle Serv., 2013 U.S. Dist. LEXIS 31628 (E.D.N.Y., Mar. 6, 2013), the Court

states in relevant part that:

[i]f the New York State Medicaid program has not established a fee payable for the
specific item, then the fee payable shall be the lesser of the acquisition cost (i.e., the
line item cost from a manufacturer or wholesaler net of any rebates, discounts or other
valuable considerations, mailing, shipping, handling, insurance costs or any sales tax)
to the provider plus 50%, or the usual and customary price charged to the general
public.

19. Altai Corp. d/b/a Get Ready Medical Supply was billing for supplies that did not have

an established fee under the New York State Medicaid Program. Based on that, GEICO sought to

have the fee explained as to whether your charge is the lesser of: (i) the acquisition cost to you plus

50%, or (ii) the usual and customary price charged to the general public. Moreover, GEICO deemed

it necessary to have supporting documentation for your acquisition cost, including (i) a detailed

description of the equipment including the name of the manufacturer, make and model, (ii) any

photographs or pictures identifying the type of supplies provided, (iii) the wholesale invoice, and (iv)

proof of payment to the wholesaler.

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20. According to the New York State Department of Financial Services which governs

no-fault in New York State, any charges for health services submitted for reimbursement under the

no-fault law are subject to the fee schedules put forth by the Workers’ Compensation Board. The

workers’ compensation regulation concerning durable medical equipment (“DME”) in turn adopts

the New York State Medicaid fee schedule in 12 N.Y.C.R.R. § 442.2, which provides:

The maximum permissible charge for the purchase of durable medical equipment,
medical/surgical supplies, and orthotic and prosthetic appliances shall be the fee
payable for such equipment or supplies under the New York State Medicaid program
at the time such equipment and supplies are provided…
21. The above regulations and allegations set forth the basis for this declaratory judgment

action in which GEICO seeks a decision that it is not legally obligated to pay fraudulent claims

submitted by Altai Corp. d/b/a Get Ready Medical Supply

II. An Overview of New York’s No-Fault Regulations Pertaining to Verification of Claims

22. The No-Fault Laws obligate healthcare providers and/or DME supplies that seek

payment of No-Fault Benefits to provide insurers with additional verification in order to establish

proof of their claims.

23. The prescribed No-Fault policy endorsement set forth in 11 N.Y.C.R.R. § 65-1.1

includes a specific section entitled “Conditions”, which states in part, that “upon request by the

Company, the eligible injured person or that person’s assignee . . . shall (b) as may reasonably be

required, submit to an examination under oath by any person named by the Company, and shall

subscribe to same . . . , and (d) provide any other pertinent information that may assist the Company

in determining the amount that is payable.”

24. The prescribed No-Fault policy endorsement set forth in 11 N.Y.C.R.R. § 65-1.1 also

states that “No action shall lie against the Company, unless, as a condition precedent thereto, there

shall have been full compliance with the terms of this coverage.”

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25. The proof of claim requirement in the No-Fault policy endorsement, 11 N.Y.C.R.R. §

65-3.5(b) states in relevant part:

Subsequent to the receipt of one or more of the completed verification forms, any
additional verification required by the insurer to establish proof of claim shall be
requested within 15 business days of receipt of the prescribed verification forms. Any
requests by an insurer for additional verification need not be made on any prescribed
or particular form . . .

26. Additionally, 11 N.Y.C.R.R. § 65-3.5(c) states in relevant part:

The insurer is entitled to receive all items necessary to verify the claim directly from
the parties from whom such verification was requested.

27. An insurer is entitled to any information that is necessary for the insurer to determine

whether the claim submitted by the healthcare provider and/or DME supplier is payable. The issues

for which additional verification can be properly sought are not limited, and can include, for example:

(i) whether the supplies provided by the DME provider were rendered and/or
medically necessary;

(ii) whether the supplies provided were billed in accordance with the New York
State Medicaid Program; and
(iii) whether the items billed for were actually provided to the eligible injured
persons.

28. Under 11 N.Y.C.R.R. § 65-3.5(b) and 65-3.6, upon receipt of a bill, an insurer has 15

business days to issue a verification request, including a request for an EUO. Upon a party’s failure

to provide such verification within 30 days, i.e., failure to appear for an EUO, an insurer within 10

calendar days, shall contact the party from whom verification has been requested and not been

provided. At which time a follow-up EUO is scheduled.

29. Because an EUO is a condition of coverage, an insurer may deny a healthcare

provider’s or individual’s claim for No-Fault Benefits if the healthcare provider or individual claimant

refuses to appear for an EUO, which constitutes a material breach of the insurance policy and violation

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of the regulations. The New York State Department of Insurance has confirmed this conclusion by

opinion letter, dated December 22, 2006 which states:

As referenced above in Section 65-1.1(d), the prescribed No-Fault endorsement
requires that, as a condition to coverage, an eligible injured person or that person’s
assignee shall “…as may be reasonably required, submit to examinations under oath
by any person named by the Company…”

***

When an EUO is required and the party required to appear fails to attend a scheduled
EUO, the insurer must meet its obligations under N.Y. Comp Codes R. & Regs. tit 11,
§65-3.6(b) and within 10 calendar days, contact the party from whom verification (the
EUO) has been requested and not provided, i.e., non-attendance at the scheduled EUO,
in order to afford the party a second opportunity to attend an EUO. If the party fails
to appear at the rescheduled EUO, an insurer may issue a denial of pending claims
based upon the failure to meet the condition for coverage in not submitting to the
requested EUO, as required under the prescribed endorsement. There is no
requirement in the regulation that the denial must state the specific reason(s) why the
insurer required the EUO.
See N.Y. State Dep’t of Ins., Opinions of General Counsel, Op. Letter dated December 22, 2006,

attached hereto as Exhibit “B.”

III. GEICO’s Basis For Requesting an EUO of the Provider

30. Prior to seeking the EUO of the Provider, GEICO conducted an investigation into

Defendant’s billing and treatment practices.

31. Specifically, for DME suppliers, an EUO can be requested in order to establish the

medical necessity and quality of the durable medical equipment/orthotics provided to GEICO

patients. In addition, GEICO sought to confirm the accuracy of the billing and coding practices that

are associated with the claim submissions made to GEICO including the manner/method in which the

charges have been calculated. Furthermore, GEICO is permitted under 11 N.Y.C.R.R.§ 65-3.16 to

verify the items billed for were the actual items provided to the eligible injured persons and that those

items billed for were actually provided to the patients.

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32. Based upon GEICO’s investigation and the totality of the circumstances GEICO

concluded that serious questions existed that warranted the Provider’s formal appearance for an EUO.

Inexplicably, the Provider continues to fail and/or refuse to appear for EUOs that have been requested

by GEICO.

IV. Altai Corp. d/b/a Get Ready Medical Supply’s Failure to Comply with GEICO’s
Requests for Additional Verification

33. Beginning on or about May 2022, GEICO elected to make formal requests for an EUO

of Altai Corp. d/b/a Get Ready Medical Supply in connection with the claims listed on Exhibit “A”.

These requests were made in accordance with the insurance policies under which the claims were

submitted, and pursuant to the No-Fault Laws.

34. Each request was timely made and based upon the application of objective standards

justifying the EUO and the information/documentation sought by GEICO.

35. Each request endeavored to select places and times for the EUO that would be

convenient to GEICO but also advised that a change of time, date and location would be considered

if requested by Altai Corp. d/b/a Get Ready Medical Supply Each request advised Altai Corp. d/b/a

Get Ready Medical Supply that it would be reimbursed for any loss of earnings and reasonable

transportation expenses incurred in complying with the request.

36. The EUO Scheduling Chart identifies each claim/bill where an EUO was requested,

and which is subject to this declaratory judgment action. For each claim/bill, the respective dates of

the written requests made by GEICO and the dates when Altai Corp. d/b/a Get Ready Medical Supply

was scheduled to appear are listed, as well as the dates of the non-appearance by Altai Corp. d/b/a

Get Ready Medical Supply and the dates that the claims were denied by GEICO. See Affidavit of

Jillian Gardella, attached hereto as Exhibit “C,” and the Affidavit of Paul Clay, attached hereto as

Exhibit “C.1.”

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37. Since June 2022, Altai Corp. d/b/a Get Ready Medical Supply has systematically

failed and/or refused to appear for an EUO.

38. For each claim/bill, Altai Corp. d/b/a Get Ready Medical Supply failed to appear for

its scheduled EUO on no less than two occasions, and thus, Altai Corp. d/b/a Get Ready Medical

Supply breached a material condition precedent to coverage contained in the No-Fault laws and the

underlying insurance policies.

39. The systemic failure and/or refusal to appear for an EUO constitutes a material breach

of GEICO’s insurance policies and the No-Fault Laws under which the claims have been made and,

as such, relieves GEICO from any obligation to pay Altai Corp. d/b/a Get Ready Medical Supply on

any of the claims.

40. In each instance where Altai Corp. d/b/a Get Ready Medical Supply has refused to

appear for an EUO, GEICO issued a timely denial on the prescribed NF-10 form stating in relevant

part that Altai Corp. d/b/a Get Ready Medical Supply failed to comply with its obligation to present

a proper proof of claim by failing to provide the EUO, and that Altai Corp. d/b/a Get Ready Medical

Supply’s claim was denied because it failed to satisfy a condition of coverage.

41. All of GEICO’s denials of Altai Corp. d/b/a Get Ready Medical Supply’s bills and

charges were timely, proper, and consistent with the No-Fault Laws. The chart annexed hereto as

Exhibit “A” identifies (i) each claim/bill where an EUO was requested by GEICO, (ii) the respective

dates of the requests and appearance dates, (iii) the dates of the non-appearances, and (iv) the dates

that the claims were denied by GEICO.

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AS AND FOR A FIRST CAUSE OF ACTION
Against Altai Corp. d/b/a Get Ready Medical Supply
(Declaratory Relief Under CPLR §3001)

42. Plaintiffs incorporate, as though fully set forth herein, each and every allegation in the

paragraphs set forth above.

43. There is an actual case in controversy between GEICO and Altai Corp. d/b/a Get

Ready Medical Supply regarding more than $60,000.00 in billing for durable medical equipment that

has been submitted to GEICO. The claims in dispute are listed on Exhibit “A.”

44. Altai Corp. d/b/a Get Ready Medical Supply has no right to receive payment for any

of the claims listed on Exhibit “A” because it failed and/or refused to appear for EUOs requested by

GEICO, and therefore, breached a condition of coverage and violated its obligations under the No-

Fault Laws.

45. Accordingly, GEICO requests a judgment pursuant to CPLR §3001, declaring that

Altai Corp. d/b/a Get Ready Medical Supply has no right to receive payment for the bills submitted

to GEICO and listed on Exhibit “A” because it failed and/or refused to appear for an EUO requested

by GEICO, and thus breached a condition of coverage and violated its obligations under the No-Fault

Laws.

WHEREFORE, GEICO respectfully requests that this Court enter a declaratory judgment

pursuant to CPLR §3001 in its favor and against Defendant, as follows:

A. On the First Cause of Action, a declaration that Altai Corp. d/b/a Get Ready Medical

Supply has no right to receive payment for the bills submitted to GEICO and listed on Exhibit “A”

because it failed and/or refused to appear for an EUO requested by GEICO, and thus breached a

condition of coverage and violated its obligations under the No-Fault Laws; and

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B. Reimbursement of the costs and disbursements associated with the prosecution of this

action, and such other and further relief as the Court may deem just and proper.

Dated: Melville, New York
August 25, 2023 Yours, etc.,

Law Office of Goldstein & Hopkins
GEICO Staff Counsel

By: ______________________________
Rachel S. Hochhauser, Esq.
Attorneys for Plaintiffs
2 Huntington Quadrangle
Suite 1N01
Melville, New York 11747
(516)714-7404

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Index No.

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
Government Employees Insurance Co., GEICO
Indemnity Co., GEICO General Insurance
Company and GEICO Casualty Co. (collectively
“GEICO”),

Plaintiff(s) SUMMONS AND VERIFIED
COMPLAINT
- against -

Altai Corp. d/b/a Get Ready Medical Supply

Defendant(s)

PURSUANT TO 22 NYCRR 130-1.1(a), I CERTIFY THAT BASED ON MY KNOWLEDGE,
INFORMATION AND BELIEF, FORMED AFTER AN INQUIRY REASONABLE UNDER THE
CIRCUMSTANCES, THE WITHIN SUMMONS AND VERIFIED COMPLAINT ARE NOT
FRIVOLOUS.

Law Office of Goldstein & Hopkins
GEICO
Attorneys for Plaintiff(s)
2 Huntington Quadrangle, Suite 1N01
Melville, NY 11747
516-714-7404

TO:

Altai Corp. d/b/a Get Ready Medical Supply
Defendant
7122 Bay Parkway, Floor 2
Brooklyn, New York 11204

Defendant(s)

Due and timely service of a copy of the within ______________________________
is hereby admitted. Dated, 2023

Attorney(s) for

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VERIFICATION

STATE OF NEW YORK }
COUNTY OF SUFFOLK }

JILLIAN GARDELLA, being duly sworn, deposes and says:

I am employed as a claims manager in the claims department of Plaintiff herein, an
insurance corporation duly licensed by the State of New York. I have read the foregoing Verified
Complaint and know the contents thereof, and the same is true to my own knowledge except as
to the matters therein stated to be alleged upon information and belief, and that as to those
matters, I believe it to be true.

I further state that the grounds of my belief as to all matters therein stated on information
and belief are derived from statements of the Plaintiff, Plaintiff's office records, and my review
into the facts of this case.

I declare under penalty of perjury that the foregoing is true and correct.

RL IAN GARDELLA

ACKNOWLEDGMENT

STATE OF NEW YORK )
) ss:
COUNTY OF SUFFOLK )

On this day of August 2023, before me personally appeared2 b rm ¬a// /dL , to me

known and known to me to be the individual described in and who executed the foregoing
affidavit, and they duly acknowledged that they executed the same.

NOTARY PUBLIC
ANN FRANCES RAGONE
Notary Public, State of New York
No. 01RA0000009
Qualified in Suffolk
County
Commission Expires February 1, 2027

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Exhibit “A”

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Claim No. IP's Name Bill Recvd. DOS From DOS To Billed Amnt. 1st EUO Ltr. 1st EUO Dt. 2nd EUO Ltr. 2nd EUO Dt. 3rd EUO Ltr. 3rd EUO Dt. 4th EUO Ltr. 4th EUO Dt. 5th EUO Ltr. 5th EUO Dt. 6th EUO Ltr. 6th EUO Dt. 7th EUO Ltr. 7th EUO Dt. Denial Dt.

Batch No. 20220531-0025
0666329500000001 ARLENE CUNNINGHAM 05/02/2022 03/29/2022 04/25/2022 $3,076.04 05/31/2022 06/21/2022 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/18/2022 12/01/2022 11/07/2022 12/01/2022 12/08/2022 01/06/2023 01/27/2023
0682431770000001 LATACIA HEPBURN 05/02/2022 03/29/2022 04/25/2022 $3,076.04 05/31/2022 06/21/2022 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/18/2022 12/01/2022 11/07/2022 12/01/2022 12/08/2022 01/06/2023 01/27/2023
8707478840000002 MICHAEL GLOVER 05/02/2022 03/29/2022 04/25/2022 $3,076.04 05/31/2022 06/21/2022 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/18/2022 12/01/2022 11/07/2022 12/01/2022 12/08/2022 01/06/2023 01/27/2023

Batch No. 20220701-0008
0294271040101252 SATIN NEWLAND 06/09/2022 04/30/2022 04/30/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/2022 11/07/2022 12/01/2022 12/07/2022 01/06/2023 01/25/2023 02/21/2023 02/16/2023 03/02/2023 03/20/2023
8718421270000003 MILLICENT WRIGHT 06/09/2022 05/01/2022 05/01/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/2022 11/07/2022 12/01/2022 12/07/2022 01/06/2023 01/25/2023 02/21/2023 02/16/2023 03/02/2023 03/20/2023
8742636580000001 CORY WILLIAMS 06/09/2022 04/29/2022 05/26/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/2022 11/07/2022 12/01/2022 12/07/2022 01/06/2023 01/25/2023 02/21/2023 02/16/2023 03/02/2023 03/20/2023
8748142910000001 QITUWRA MUHAMMAD 06/13/2022 04/29/2022 05/26/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/2022 11/07/2022 12/01/2022 12/07/2022 01/06/2023 01/25/2023 02/21/2023 02/16/2023 03/02/2023 03/20/2023

Batch No. 20220701-0009
0460634020101020 BARRY ROWE 06/16/2022 05/15/2022 05/15/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/18/2022 12/01/2022 11/07/2022 12/01/2022 12/08/2022 01/06/2023 01/26/2023 02/21/2023 02/17/2023 03/02/2023 03/20/2023
0675874170000001 FERGUSON IGBINEDION 06/13/2022 04/29/2022 05/26/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/18/2022 12/01/2022 11/07/2022 12/01/2022 12/08/2022 01/06/2023 01/26/2023 02/21/2023 02/17/2023 03/02/2023 03/20/2023
8709786290000001 JOSE RODRIGUEZ 06/13/2022 04/30/2022 04/30/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/18/2022 12/01/2022 11/07/2022 12/01/2022 12/08/2022 01/06/2023 01/26/2023 02/21/2023 02/17/2023 03/02/2023 03/20/2023
8725190870000001 SABRINA GOLDING 06/16/2022 05/10/2022 06/06/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/18/2022 12/01/2022 11/07/2022 12/01/2022 12/08/2022 01/06/2023 01/26/2023 02/21/2023 02/17/2023 03/02/2023 03/20/2023

Batch No. 20220701-0011
0285378310101059 RAYMOND SMITH 06/16/2022 05/15/2022 06/11/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/2022 11/07/2022 12/01/20222 12/08/2022 01/06/2023 01/26/2023 02/21/2023 02/17/2023 03/02/2023 03/20/2023
0527436270000002 YURIY POSTERNAK 06/17/2022 07/05/2021 08/01/2021 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/20222 11/07/2022 12/01/20222 12/08/2022 01/06/2023 01/26/2023 02/21/2023 02/17/2023 03/02/2023 03/20/2023
8755566900000001 SHAKERIA WILSON 06/16/2022 05/10/2022 06/06/2022 $3,076.04 07/01/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/20222 11/07/2022 12/01/20222 12/08/2022 01/06/2023 01/26/2023 02/21/2023 02/17/2023 03/02/2023 03/20/2023

Batch No. 20220722-0056
8701545140000001 DANDRE ROLLINS 06/30/2022 05/20/2022 06/09/2022 $2,446.04 07/22/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/20222 11/07/2022 12/01/20222 12/08/2022 01/06/2023 01/27/2023 02/21/2023 02/17/2023 03/02/2023 03/20/2023

Batch No. 20220722-0090
0408622500101045 DIAMOND SANDERS 07/11/2022 06/01/2022 06/28/2022 $3,076.04 07/22/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/20222 11/07/2022 12/01/20222 12/07/2022 01/06/2023 01/26/2023 02/21/2023 02/16/2023 03/02/2023 03/20/2023
0682855580000002 DELEON MCINTOSH 07/11/2022 06/01/2022 06/28/2022 $3,076.04 07/22/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/20222 11/07/2022 12/01/20222 12/07/2022 01/06/2023 01/26/2023 02/21/2023 02/16/2023 03/02/2023 03/20/2023
8737473160000002 GIANNI HEMMINGS 07/11/2022 06/01/2022 06/28/2022 $3,076.04 07/22/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/20222 11/07/2022 12/01/20222 12/07/2022 01/06/2023 01/26/2023 02/21/2023 02/16/2023 03/02/2023 03/20/2023
8737473160000002 JEANAE JORDAN 07/11/2022 06/01/2022 06/28/2022 $3,076.04 07/22/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/20222 11/07/2022 12/01/20222 12/07/2022 01/06/2023 01/26/2023 02/21/2023 02/16/2023 03/02/2023 03/20/2023
8753882210000001 CANDI LUE 07/11/2022 06/01/2022 06/28/2022 $3,076.04 07/22/2022 08/02/2022 08/09/2022 10/07/2022 10/17/2022 12/01/20222 11/07/2022 12/01/20222 12/07/2022 01/06/2023 01/26/2023 02/21/2023 02/16/2023 03/02/2023 03/20/2023

$60,890.80

# Sensitivity: Public

18 of 56
FILED: NASSAU COUNTY CLERK 08/31/2023 03:58 PM INDEX NO. 614141/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/31/2023

Exhibit “B”

19 of 56
FILED: NASSAU COUNTY CLERK 08/31/2023 03:58 PM INDEX NO. 614141/2023
No-Fault: Examination unCler Oath Page 1 of 2
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/31/2023

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The Office of General Counsel issued the following opinion on December 22, 2006, representing the position of the New York State
Insurance Department.

Re: No-Fault: Examination under Oath

QUESTIONS PRESENTED

1) Must a No-Fault insurer's reasonable and objective standards, used in determining whether an examination under oath of an eligibl

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Complaint,Petition: Government Employees Insurance Co., Geico Indemnity Co., Geico General Insurance Company, Geico Casualty Co. v. Altai Corp. d/b/a Get Ready Medical Supply

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