On January 31, 2024 a
Party Discovery
was filed
involving a dispute between
Mosher Chiropractic, P.A.,
Robertson, Ryan,
and
State Farm Mutual Automobile Insurance Company,
for Civil
in the District Court of Hillsborough County.
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Filing # 195579212 E-Filed 04/05/2024 12:42:13 PM
IN THE COUNTY COURT, OF THE
THIRTEENTH JUDICIAL CIRCUIT, IN
AND FOR HILLSBOROUGH COUNTY,
FLORIDA
CASE NO: 24-CC-005332
DIVISION: L
MOSHER CHIROPRACTIC, P.A
a/a/o RYAN ROBERTSON,
Plaintiff,
vs.
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,
Defendant.
/
Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, hereby
requests the Plaintiff to produce to the undersigned, within thirty (30) days from the date hereof
the following items on the grounds that the items requested contain or constitute material and
relevant evidence to this cause and are unavailable to Defendant and without which Defendant
cannot adequately and properly prepare this case.
1. All “SOAP” notes, progress notes, treatment records or other documents describing the
medical treatment rendered to RYAN ROBERTSON for the subject date of loss.
2. All billing records, including HCFA 1500, CMS 1500 and/or UB 92 forms for
treatment rendered to RYAN ROBERTSON for the subject date of loss.
3. An updated, un-redacted patient ledger where all services, payments and outstanding
balances are reflective.
4. All documents, including but not limited to copies of checks, patient ledgers, receipts,
etc., that reflects any and all payments received for treatment from any payor for
claimant.
4/5/2024 12:42 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
5. Any and all correspondence sent by Plaintiff, pursuant to Florida Statute 627.736(10),
in which Plaintiff demanded payment from State Farm for the alleged benefits at issue.
6. Any and all documents Plaintiff will rely to establish that additional damages are due
or owing.
7. Any and all documents Plaintiff will rely on to establish the existence of a valid
assignment of benefits.
8. A Privilege Log for any withheld documents.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of April, 2024, a true and correct copy of the
foregoing was sent to Matthew Emanuel, Esq. - Landau & Associates, P.A. - 1619 NW 136th
Avenue, Suite 2C Sunrise, FL 33323; efilings@pip-lawyers.com through the Florida Courts E-
Filing Portal system.
MIMI L. SMITH & ASSOCIATES
BY:
(Original signed electronically by Attorney.)
DAVID M. BOSSONE, ESQ.
Florida Bar No. 1008048
Attorney for Defendant, State Farm Mutual
Automobile Insurance Company
390 N. Orange Avenue, Suite 1700
Orlando, FL 32801
Telephone: (407) 481-6070
Facsimile: (855) 561-8864
E-mail for service (FL R. Jud. Admin. 2.516):
flor.law-pip.501o19@statefarm.com
Email: david.bossone@statefarm.com
Attorneys and Staff of Mimi L. Smith & Associates
are Employees of the Law Department of State Farm
Mutual Automobile Insurance Company
4/5/2024 12:42 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Document Filed Date
April 05, 2024
Case Filing Date
January 31, 2024
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Filing # 195579212 E-Filed 04/05/2024 12:42:13 PM IN THE COUNTY COURT, OF THE THIRTEENTH JUDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CASE NO: 24-CC-005332 DIVISION: L MOSHER CHIROPRACTIC, P.A a/a/o RYAN ROBERTSON, Plaintiff, vs. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. / Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, hereby requests the Plaintiff to produce to the undersigned, within thirty (30) days from the date hereof the following items on the grounds that the items requested contain or constitute material and relevant evidence to this cause and are unavailable to Defendant and without which Defendant cannot adequately and properly prepare this case. 1. All “SOAP” notes, progress notes, treatment records or other documents describing the medical treatment rendered to RYAN ROBERTSON for the subject date of loss. 2. All billing records, including HCFA 1500, CMS 1500 and/or UB 92 forms for treatment rendered to RYAN ROBERTSON for the subject date of loss. 3. An updated, un-redacted patient ledger where all services, payments and outstanding balances are reflective. 4. All documents, including but not limited to copies of checks, patient ledgers, receipts, etc., that reflects any and all payments received for treatment from any payor for claimant. 4/5/2024 12:42 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 5. Any and all correspondence sent by Plaintiff, pursuant to Florida Statute 627.736(10), in which Plaintiff demanded payment from State Farm for the alleged benefits at issue. 6. Any and all documents Plaintiff will rely to establish that additional damages are due or owing. 7. Any and all documents Plaintiff will rely on to establish the existence of a valid assignment of benefits. 8. A Privilege Log for any withheld documents. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 5th day of April, 2024, a true and correct copy of the foregoing was sent to Matthew Emanuel, Esq. - Landau & Associates, P.A. - 1619 NW 136th Avenue, Suite 2C Sunrise, FL 33323; efilings@pip-lawyers.com through the Florida Courts E- Filing Portal system. MIMI L. SMITH & ASSOCIATES BY: (Original signed electronically by Attorney.) DAVID M. BOSSONE, ESQ. Florida Bar No. 1008048 Attorney for Defendant, State Farm Mutual Automobile Insurance Company 390 N. Orange Avenue, Suite 1700 Orlando, FL 32801 Telephone: (407) 481-6070 Facsimile: (855) 561-8864 E-mail for service (FL R. Jud. Admin. 2.516): flor.law-pip.501o19@statefarm.com Email: david.bossone@statefarm.com Attorneys and Staff of Mimi L. Smith & Associates are Employees of the Law Department of State Farm Mutual Automobile Insurance Company 4/5/2024 12:42 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2