On May 09, 2024 a
Proof of Service
was filed
involving a dispute between
Specific Care Chiropractic Inc,
and
Geico Casualty Company,
for 19P - PERSONAL INJURY PROTECTION
in the District Court of Seminole County.
Preview
Filing # 197967363 E-Filed 05/09/2024 11:49:54 AM
IN THE COUNTY COURT OF THE 18TH
JUDICIAL CIRCUIT, IN AND FOR
SEMINOLECOUNTY, FLORIDA
CASE NO.: 2024SC003313
SPECIFIC CARE CHIROPRACTIC, INC.
(a/a/o Calvin Brown)
Plaintiff,
L
GEICO CASUALTY COMPANY
IA
Defendant.
____________________________________/
C
NOTICE OF SERVICE OF INTERROGATORIES AND INTERROGATORIES
I
PROPOUNDED TO DEFENDANT
F
The Plaintiff, SPECIFIC CARE CHIROPRACTIC, INC. by and through
F
undersigned counsel, propounds the attached Interrogatories to Defendant, GEICO
O
CASUALTY COMPANY, to be answered, under oath, within forty five 45) days from the
N
date of service hereof with the Complaint or Petition.
U
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was attached
to the copy of the Summons and Complaint to be served by process on the Defendant
STEINGER, GREENE& FEINER
/s/ Thomas J. Wenzel
THOMAS J. WENZEL, ESQUIRE
Fla. Bar No.: 104117
133 NW 100th Avenue
Plantation, FL 33324
Telephone: 954 491 7701
Fax Number: 954 634 8312
Service: pleadings@injurylawyers.com
Attorney for Plaintiff
IAL
F I C
O F
U N
INTERROGATORIES TO THE DEFENDANT
1. Please state your complete name, your relationship with the Defendant, your
position with the Defendant, and how long you have had that position.
L
2. Please state whether the Defendant’s entire file concerning the No Fault claim of
the Plaintiff against the Defendant has ever been provided to the Plaintiff, whether it is now
IA
available for inspection by Plaintiff’s legal counsel, and when/where it may be examined.
(“Entire file” means each and every document including but not limited to any files of
adjusters, agents, employees, or servants hired by you to work on the file of Calvin Brown.
F I C
3.
O F
Do you dispute in whole or in part that Calvin Brown was involved in a motor
vehicle accident that occurred on 07/14/2021? If so, why do you dispute that the accident
N
occurred as alleged and on what evidence did you rely to make such a determination?
4.
U At the time and place of the automobile accident referenced in the complaint, did
Calvin Brown ave Personal Injury Protection coverage with the Defendant and if so, have
you accepted coverage? If you answer negatively in whole or in part to the foregoing,
please specifically explain why not and what evidence you possess regarding your
conclusion.
5. Please state the name, address, and position of all adjusters/supervisors/contractors
ever in charge of payments, decision making, or control of the PIP claim file of Calvin
Brown as well as the start and end date of each person’s responsibilities.
6. State whether any of Calvin Brown’s treating physicians were contacted by
L
Defendant and if so, by whom.
I C IA
FF
7.
NO
Please specifically list any and all legal reasons and factual support that explains
U
why you have not paid the amount of medical benefits that Plaintiff claims is due and
owing.
8. Stat the names, phone numbers, addresses, and areas of knowledge for all potential
witnesses who may have information about the issues framed in the complaint.
9. When did the Defendant anticipate litigation in regards to the claim at issue in this
lawsuit and what are the reasons why litigation was anticipated at that time?
IAL
F I C By: ______________________________________
F
STATE OF FLORIDA
SS:
O
COUNTY OF ___________
N
BEFORE ME, the undersigned authority, this day personally appeared _________________
U
who being by me first duly sworn, deposes and says that s/he has read the foregoing
Answers to Interrogatories and that the facts contained therein are true and correct.
SWORN AND SUBSCRIBED before me this ____ day of ________________ 20_____.
___________________________
Notary Public
My Commission Expires:
Document Filed Date
May 09, 2024
Case Filing Date
May 09, 2024
Category
19P - PERSONAL INJURY PROTECTION
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Filing # 197967363 E-Filed 05/09/2024 11:49:54 AM IN THE COUNTY COURT OF THE 18TH JUDICIAL CIRCUIT, IN AND FOR SEMINOLECOUNTY, FLORIDA CASE NO.: 2024SC003313 SPECIFIC CARE CHIROPRACTIC, INC. (a/a/o Calvin Brown) Plaintiff, L GEICO CASUALTY COMPANY IA Defendant. ____________________________________/ C NOTICE OF SERVICE OF INTERROGATORIES AND INTERROGATORIES I PROPOUNDED TO DEFENDANT F The Plaintiff, SPECIFIC CARE CHIROPRACTIC, INC. by and through F undersigned counsel, propounds the attached Interrogatories to Defendant, GEICO O CASUALTY COMPANY, to be answered, under oath, within forty five 45) days from the N date of service hereof with the Complaint or Petition. U CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was attached to the copy of the Summons and Complaint to be served by process on the Defendant STEINGER, GREENE& FEINER /s/ Thomas J. Wenzel THOMAS J. WENZEL, ESQUIRE Fla. Bar No.: 104117 133 NW 100th Avenue Plantation, FL 33324 Telephone: 954 491 7701 Fax Number: 954 634 8312 Service: pleadings@injurylawyers.com Attorney for Plaintiff IAL F I C O F U N INTERROGATORIES TO THE DEFENDANT 1. Please state your complete name, your relationship with the Defendant, your position with the Defendant, and how long you have had that position. L 2. Please state whether the Defendant’s entire file concerning the No Fault claim of the Plaintiff against the Defendant has ever been provided to the Plaintiff, whether it is now IA available for inspection by Plaintiff’s legal counsel, and when/where it may be examined. (“Entire file” means each and every document including but not limited to any files of adjusters, agents, employees, or servants hired by you to work on the file of Calvin Brown. F I C 3. O F Do you dispute in whole or in part that Calvin Brown was involved in a motor vehicle accident that occurred on 07/14/2021? If so, why do you dispute that the accident N occurred as alleged and on what evidence did you rely to make such a determination? 4. U At the time and place of the automobile accident referenced in the complaint, did Calvin Brown ave Personal Injury Protection coverage with the Defendant and if so, have you accepted coverage? If you answer negatively in whole or in part to the foregoing, please specifically explain why not and what evidence you possess regarding your conclusion. 5. Please state the name, address, and position of all adjusters/supervisors/contractors ever in charge of payments, decision making, or control of the PIP claim file of Calvin Brown as well as the start and end date of each person’s responsibilities. 6. State whether any of Calvin Brown’s treating physicians were contacted by L Defendant and if so, by whom. I C IA FF 7. NO Please specifically list any and all legal reasons and factual support that explains U why you have not paid the amount of medical benefits that Plaintiff claims is due and owing. 8. Stat the names, phone numbers, addresses, and areas of knowledge for all potential witnesses who may have information about the issues framed in the complaint. 9. When did the Defendant anticipate litigation in regards to the claim at issue in this lawsuit and what are the reasons why litigation was anticipated at that time? IAL F I C By: ______________________________________ F STATE OF FLORIDA SS: O COUNTY OF ___________ N BEFORE ME, the undersigned authority, this day personally appeared _________________ U who being by me first duly sworn, deposes and says that s/he has read the foregoing Answers to Interrogatories and that the facts contained therein are true and correct. SWORN AND SUBSCRIBED before me this ____ day of ________________ 20_____. ___________________________ Notary Public My Commission Expires: