On February 15, 2024 a
Party Discovery
was filed
involving a dispute between
Grappin Clinic Of Chiropractic Pa,
and
Progressive Select Insurance Company,
for SMALL CLAIMS BETWEEN $100-$500
in the District Court of Sarasota County.
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Filing # 154766106 E-Filed 08/05/2022 12:03:41 PM
GRAPPIN CLINIC OF CHIROPRACTIC, P.A. IN THE COUNTY COURT OF THE 11TH
a/a/o LISA WILLIAMSON, JUDICIAL CIRCUIT, IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
Plaintiff,
vs.
CASE NO: 2022-014501-SP-26
PROGRESSIVE SELECT INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S SUPPLEMENTAL REQUEST FOR ADMISSIONS
REGARDING REASONABLENESS
COMES NOW Plaintiff, by and through the undersigned attorneys and pursuant to
Florida Rule of Civil Procedure 1.370, and requests Defendant, to admit in writing the truth of
the matters set forth below within thirty (30) days after service of this Request for Admissions re:
Reasonableness:
1. Admit that the bills submitted by Plaintiff in this matter were reasonable in price.
2. Admit that the bills submitted by Plaintiff in this matter are not the highest for each code
that Defendant has received in the same area where the treatment was rendered.
3. Admit that the Defendant has paid each of the codes submitted by Plaintiff in this matter
at a rate higher than that billed in this matter.
4. Admit that at this time, Defendant has no Expert opinion that the codes billed in this
matter were not reasonable in price.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via EMail
on August 5, 2022 to Andres Millon, Esq., with Progressive PIP House Counsel, at FLPIPHC-
Miami@Progressive.com.
REIFKIND, THOMPSON & RUDZINSKI, LLP
Attorneys for Plaintiff
3333 W. Commercial Blvd., Suite 200B
Ft. Lauderdale, FL 33309
Office: (954) 370-5152
Fax: (954) 370-1992
Service E-mail: PipService@rtrlaw.com
By: /s/ Gregory Blackburn
Gregory Blackburn, Esq.
Florida Bar No. 15918
Filed 02/15/2024 05:23 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL
Document Filed Date
February 15, 2024
Case Filing Date
February 15, 2024
Category
SMALL CLAIMS BETWEEN $100-$500
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Filing # 154766106 E-Filed 08/05/2022 12:03:41 PM GRAPPIN CLINIC OF CHIROPRACTIC, P.A. IN THE COUNTY COURT OF THE 11TH a/a/o LISA WILLIAMSON, JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA Plaintiff, vs. CASE NO: 2022-014501-SP-26 PROGRESSIVE SELECT INSURANCE COMPANY, Defendant. / PLAINTIFF’S SUPPLEMENTAL REQUEST FOR ADMISSIONS REGARDING REASONABLENESS COMES NOW Plaintiff, by and through the undersigned attorneys and pursuant to Florida Rule of Civil Procedure 1.370, and requests Defendant, to admit in writing the truth of the matters set forth below within thirty (30) days after service of this Request for Admissions re: Reasonableness: 1. Admit that the bills submitted by Plaintiff in this matter were reasonable in price. 2. Admit that the bills submitted by Plaintiff in this matter are not the highest for each code that Defendant has received in the same area where the treatment was rendered. 3. Admit that the Defendant has paid each of the codes submitted by Plaintiff in this matter at a rate higher than that billed in this matter. 4. Admit that at this time, Defendant has no Expert opinion that the codes billed in this matter were not reasonable in price. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via EMail on August 5, 2022 to Andres Millon, Esq., with Progressive PIP House Counsel, at FLPIPHC- Miami@Progressive.com. REIFKIND, THOMPSON & RUDZINSKI, LLP Attorneys for Plaintiff 3333 W. Commercial Blvd., Suite 200B Ft. Lauderdale, FL 33309 Office: (954) 370-5152 Fax: (954) 370-1992 Service E-mail: PipService@rtrlaw.com By: /s/ Gregory Blackburn Gregory Blackburn, Esq. Florida Bar No. 15918 Filed 02/15/2024 05:23 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL