On September 07, 2021 a
Party Discovery
was filed
involving a dispute between
Foster, Elizabeth,
Rose Radiology Centers, Inc.,
and
Government Employees Insurance Company,
for Civil
in the District Court of Hillsborough County.
Preview
Filing # 143832543 E-Filed 02/14/2022 09249: 17 AM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
ROSE RADIOLOGY CENTERS, INC. a/a/o
ELIZABETH FOSTER,
Plaintiff, CASE NO.: 21»CC-093638
vs. DIVISION: I
GOVERNMENT EMPLOYEES
INSURANCE COMPANY,
Defendant.
/
PLA]NTIFF'S SECOND REQUEST FOR ADMISSIONS TO DEFENDANT
COMES now, the plaining ROSE RADIOLOGY CENTERS, INC. a/a/o ELIZABETH
FOSTER, by and through the undersigned counsel, and hereby requests the Defendant,
GOVERNMENT EMPLOYEES INSURANCE COMPANY, admit that the following statements
are true:
1. Defendant paid personal injuzy protection benefits in response to PlaintifFs Demand
Lelter(s) under Fla Stat. § 627.736(10) for treatment rendered by Plaintiff to Elizabeth Foster under
claim number 0187445920101096.
2. Defendant paid interest in response to Plaintiffs Demand Letter(s) under Fla. Stat. §
62'7.'736(10) for treatment rendered by Plaintiff to Elizabeth Foster under claim number
0187445920101096.
3. Defendant did not pay penalty 'm response to PlaintifFs Demand Letten(s) under Fla.
Stat. §627.736(10) for treatment rendered by Plaintiff to Elizabeth Foster under claim number
0187445920101096.
4. Defendant did not pay postage in response to Plaintiii°s Demand Letter(s) under Fla
Stat. §627.736(10) for treatment rendered by Plaintiff to Elizabeth Foster under claim number
0187445920101096.
2/14/2022 9:49 AM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 1
ANSWERS OR OBJECTIONS, if any, must be sewed upon the undersigned Attorney, at
the below noted address, on or before thirty (30) days airer service hereof Otherwise these statements
shall be deemed admitted.
CERTIFICATE OF SERVICE
certify that the foregoing document has been famished by electronic mail to all electronic service
recipients listed on duel-I_Ql§b_orough County Clerk of Courts E-Filing Portal
this ` day of 22022.
/s/ Jason F Lamoureux
Jason F. Lamoureux, Esquire
HOLLAND & LAMOUREUX, P.A.
611 S. Kings Avenue
Brendon, Florida 33511
Telephone: (813)655-9069
Service @HollandLamoureux.com
Ldonegan@HollandLamoureux.com
Attorney for Plainti1T
Florida Bar # 107433
2/14/2022 9:49 AM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 2
Preview
Filing # 143832543 E-Filed 02/14/2022 09249: 17 AM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION ROSE RADIOLOGY CENTERS, INC. a/a/o ELIZABETH FOSTER, Plaintiff, CASE NO.: 21»CC-093638 vs. DIVISION: I GOVERNMENT EMPLOYEES INSURANCE COMPANY, Defendant. / PLA]NTIFF'S SECOND REQUEST FOR ADMISSIONS TO DEFENDANT COMES now, the plaining ROSE RADIOLOGY CENTERS, INC. a/a/o ELIZABETH FOSTER, by and through the undersigned counsel, and hereby requests the Defendant, GOVERNMENT EMPLOYEES INSURANCE COMPANY, admit that the following statements are true: 1. Defendant paid personal injuzy protection benefits in response to PlaintifFs Demand Lelter(s) under Fla Stat. § 627.736(10) for treatment rendered by Plaintiff to Elizabeth Foster under claim number 0187445920101096. 2. Defendant paid interest in response to Plaintiffs Demand Letter(s) under Fla. Stat. § 62'7.'736(10) for treatment rendered by Plaintiff to Elizabeth Foster under claim number 0187445920101096. 3. Defendant did not pay penalty 'm response to PlaintifFs Demand Letten(s) under Fla. Stat. §627.736(10) for treatment rendered by Plaintiff to Elizabeth Foster under claim number 0187445920101096. 4. Defendant did not pay postage in response to Plaintiii°s Demand Letter(s) under Fla Stat. §627.736(10) for treatment rendered by Plaintiff to Elizabeth Foster under claim number 0187445920101096. 2/14/2022 9:49 AM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 1 ANSWERS OR OBJECTIONS, if any, must be sewed upon the undersigned Attorney, at the below noted address, on or before thirty (30) days airer service hereof Otherwise these statements shall be deemed admitted. CERTIFICATE OF SERVICE certify that the foregoing document has been famished by electronic mail to all electronic service recipients listed on duel-I_Ql§b_orough County Clerk of Courts E-Filing Portal this ` day of 22022. /s/ Jason F Lamoureux Jason F. Lamoureux, Esquire HOLLAND & LAMOUREUX, P.A. 611 S. Kings Avenue Brendon, Florida 33511 Telephone: (813)655-9069 Service @HollandLamoureux.com Ldonegan@HollandLamoureux.com Attorney for Plainti1T Florida Bar # 107433 2/14/2022 9:49 AM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 2