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Filing # 201040966 E-Filed 06/21/2024 08:27:55 AM
IN THE COUNTY COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY FLORIDA
SEMINOLE CHIROPRACTIC CENTER a/a/o
ANNETTE ESCOFFERY,
Plaintiff,
v. Case No:
GEICO INDEMNITY COMPANY,
Defendant.
________________________________________/
NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT
Plaintiff, Seminole Chiropractic Center a/a/o ANNETTE ESCOFFERY, pursuant to Rule
1.340(a) of the Florida Rules of Civil Procedure, hereby files notice of service of interrogatories on
Defendant, GEICO INDEMNITY COMPANY , in the above-captioned case.
CERTICICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing has been furnished to the
Defendant, together with the Summons and Complaint.
Date: June 21, 2024
/ s/ Matthew Quattrochi
Matthew Quattrochi, Esq.
Fla. Bar. No. 120760
Quattrochi, Torres and Taormina, P.A.
950 S. Winter Park Dr. (Ste. 207)
Casselberry, FL 32707
Tel. (407) 452-4918
Fax: (407) 505-4245
matt@priorityjustice.com
brenda@priorityjustice.com
dasilva@priorityjustice.com
pleadings@priorityjustice.com
INTERROGATORIES TO DEFENDANT
GEICO INDEMNITY COMPANY
(Definitions: "You(r)" as used in these Interrogatories mean your corporation, company or
partnership, or anyone who handles, adjusts, or investigates claims on its behalf).
1. State the name of the person(s) answering these interrogatories, the relationship to the
Defendant, the position, and business address.
2. Is the subject claim is covered under the policy of insurance? If no, please state any and all
facts, policy language and statutory provisions which Defendant is relying on to deny
coverage.
3. Does Defendant have knowledge of the basis and method of calculation of reimbursement
of each of the charges by the subject medical provider to the Insured? If yes, please identify
the person within the company with that knowledge. If not, please identify the person or
company with that knowledge and their relationship to Defendant.
4. Did Defendant limit reimbursement pursuant to the schedule of maximum charges
permitted by Section 627.736(5)(a)(1), Florida Statutes (2012) (or Section
627.736(5)(a)(2), Florida Statutes (2008)? If any other factors or data formed the basis for
the amount of reimbursement, please state all such factors or data.
5. Please identify each and every Medicare coding policy and payment methodology of the
federal Centers for Medicare and Medicaid Services that Defendant used to determine the
amount of reimbursement for the charges by the subject medical provider, and the specific
basis in the policy and statute which allow Defendant to use the policy or methodology.
6. Is Defendant alleging that any of the treatment provided to the Insured by the medical
provider was not medically necessary, related to the collision or that the charges were not
reasonable? If yes, please state: a) what treatment Defendant
alleges was not necessary, related or charges were not reasonable; b) the name of the person
and relationship to the Defendant that determined the subject treatment was not necessary,
related or charges were not reasonable; c) the date Defendant determined the treatment was
not necessary, related or the charges were not reasonable; d) the evidence which Defendant
relies upon in determining the subject treatment was not necessary, related or the charges
were not reasonable.
7. Has Defendant denied any of the medical provider’s bills for treatment of the Insured based
upon a report under Section 627.736(7), Florida Statutes (2012)? If so, please identify the
author of the report and the date the report was received by Defendant.
8. Has Defendant denied any of the medical provider’s bills for treatment of the Insured
because it alleges the Insured did not have an emergency medical condition? If so, please
identify the evidence upon which Defendant relies.
9. Has Defendant denied any of the medical provider’s bills for treatment of the Insured
because it alleges the Insured did not receive the bills within the time required by Section
627.736(5)(c), Florida Statutes (2012)? If so, please identify the date or dates of service
and the date Defendant received the corresponding bill.
10. Please state each and every condition precedent or subsequent that any person failed to
perform which Defendant alleges bar recovery of this lawsuit, the prejudice to Defendant and
the date and method each such condition was first raised by Defendant.
11. Have you taken a recorded statement or examination under oath of any person regarding this
claim? If so, please state the name each person who provided a statement or examination and
whether their statement or examination provided a basis for the denial or reduction of
coverage.
12. For every Current Procedural Code (CPT) that was paid below 80% of the Participating
Medicare Fee Schedule Part B pursuant to § 627.736(5)(a)(1)(a-(I-III), please list:
a. each CPT Code,
b. the type of medical service, supply or care the CPT Code was billed for (reference: §
627.736(5)(a)1. f. (1) or f. (II) or f. (III)
c. the Date of Service for each CPT Code,
d. the amount billed to Defendant,
e. the exact amount of 80% of 200% of the Medicare Fee Schedule for each code on that
date of service pursuant to § 627.736(5)(a) 1. a.-f. (I-III),
f. the amount paid by the Defendant for each CPT Code.
13. For every Current Procedural Code (CPT) that was billed less than 80% of 200% of the
Physician’s Fee Schedule Part B, please list:
a. each CPT Code,
b. the type of medical service, supply or care the CPT Code was billed for (reference: §
627.736(5)(a) 1. f. (1) or f. (II) or f. (III)
c. the Date of Service for each CPT Code,
d. the amount billed to Defendant,
e. the exact amount of 80% of 200% of the Medicare Fee Schedule for each code on that
date of service pursuant to § 627.736(5)(a)1. a.-f. (I-III),
f. the amount paid by the Defendant for each CPT Code.
14. State the section, subsection, page number and form number of the relevant policy of
insurance issued in this case, including any and all specific numeral or letter identifying
any of the above information.
GEICO INDEMNITY COMPANY
BY:
STATE OF FLORIDA
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared ___________
______________ this _______ day of 2022, who after first being duly
sworn, states that the above and foregoing is true and correct.
NOTARY PUBLIC
State of Florida
My Commission expires:
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Filing # 201040966 E-Filed 06/21/2024 08:27:55 AM IN THE COUNTY COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY FLORIDA SEMINOLE CHIROPRACTIC CENTER a/a/o ANNETTE ESCOFFERY, Plaintiff, v. Case No: GEICO INDEMNITY COMPANY, Defendant. ________________________________________/ NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT Plaintiff, Seminole Chiropractic Center a/a/o ANNETTE ESCOFFERY, pursuant to Rule 1.340(a) of the Florida Rules of Civil Procedure, hereby files notice of service of interrogatories on Defendant, GEICO INDEMNITY COMPANY , in the above-captioned case. CERTICICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing has been furnished to the Defendant, together with the Summons and Complaint. Date: June 21, 2024 / s/ Matthew Quattrochi Matthew Quattrochi, Esq. Fla. Bar. No. 120760 Quattrochi, Torres and Taormina, P.A. 950 S. Winter Park Dr. (Ste. 207) Casselberry, FL 32707 Tel. (407) 452-4918 Fax: (407) 505-4245 matt@priorityjustice.com brenda@priorityjustice.com dasilva@priorityjustice.com pleadings@priorityjustice.com INTERROGATORIES TO DEFENDANT GEICO INDEMNITY COMPANY (Definitions: "You(r)" as used in these Interrogatories mean your corporation, company or partnership, or anyone who handles, adjusts, or investigates claims on its behalf). 1. State the name of the person(s) answering these interrogatories, the relationship to the Defendant, the position, and business address. 2. Is the subject claim is covered under the policy of insurance? If no, please state any and all facts, policy language and statutory provisions which Defendant is relying on to deny coverage. 3. Does Defendant have knowledge of the basis and method of calculation of reimbursement of each of the charges by the subject medical provider to the Insured? If yes, please identify the person within the company with that knowledge. If not, please identify the person or company with that knowledge and their relationship to Defendant. 4. Did Defendant limit reimbursement pursuant to the schedule of maximum charges permitted by Section 627.736(5)(a)(1), Florida Statutes (2012) (or Section 627.736(5)(a)(2), Florida Statutes (2008)? If any other factors or data formed the basis for the amount of reimbursement, please state all such factors or data. 5. Please identify each and every Medicare coding policy and payment methodology of the federal Centers for Medicare and Medicaid Services that Defendant used to determine the amount of reimbursement for the charges by the subject medical provider, and the specific basis in the policy and statute which allow Defendant to use the policy or methodology. 6. Is Defendant alleging that any of the treatment provided to the Insured by the medical provider was not medically necessary, related to the collision or that the charges were not reasonable? If yes, please state: a) what treatment Defendant alleges was not necessary, related or charges were not reasonable; b) the name of the person and relationship to the Defendant that determined the subject treatment was not necessary, related or charges were not reasonable; c) the date Defendant determined the treatment was not necessary, related or the charges were not reasonable; d) the evidence which Defendant relies upon in determining the subject treatment was not necessary, related or the charges were not reasonable. 7. Has Defendant denied any of the medical provider’s bills for treatment of the Insured based upon a report under Section 627.736(7), Florida Statutes (2012)? If so, please identify the author of the report and the date the report was received by Defendant. 8. Has Defendant denied any of the medical provider’s bills for treatment of the Insured because it alleges the Insured did not have an emergency medical condition? If so, please identify the evidence upon which Defendant relies. 9. Has Defendant denied any of the medical provider’s bills for treatment of the Insured because it alleges the Insured did not receive the bills within the time required by Section 627.736(5)(c), Florida Statutes (2012)? If so, please identify the date or dates of service and the date Defendant received the corresponding bill. 10. Please state each and every condition precedent or subsequent that any person failed to perform which Defendant alleges bar recovery of this lawsuit, the prejudice to Defendant and the date and method each such condition was first raised by Defendant. 11. Have you taken a recorded statement or examination under oath of any person regarding this claim? If so, please state the name each person who provided a statement or examination and whether their statement or examination provided a basis for the denial or reduction of coverage. 12. For every Current Procedural Code (CPT) that was paid below 80% of the Participating Medicare Fee Schedule Part B pursuant to § 627.736(5)(a)(1)(a-(I-III), please list: a. each CPT Code, b. the type of medical service, supply or care the CPT Code was billed for (reference: § 627.736(5)(a)1. f. (1) or f. (II) or f. (III) c. the Date of Service for each CPT Code, d. the amount billed to Defendant, e. the exact amount of 80% of 200% of the Medicare Fee Schedule for each code on that date of service pursuant to § 627.736(5)(a) 1. a.-f. (I-III), f. the amount paid by the Defendant for each CPT Code. 13. For every Current Procedural Code (CPT) that was billed less than 80% of 200% of the Physician’s Fee Schedule Part B, please list: a. each CPT Code, b. the type of medical service, supply or care the CPT Code was billed for (reference: § 627.736(5)(a) 1. f. (1) or f. (II) or f. (III) c. the Date of Service for each CPT Code, d. the amount billed to Defendant, e. the exact amount of 80% of 200% of the Medicare Fee Schedule for each code on that date of service pursuant to § 627.736(5)(a)1. a.-f. (I-III), f. the amount paid by the Defendant for each CPT Code. 14. State the section, subsection, page number and form number of the relevant policy of insurance issued in this case, including any and all specific numeral or letter identifying any of the above information. GEICO INDEMNITY COMPANY BY: STATE OF FLORIDA COUNTY OF BEFORE ME, the undersigned authority, personally appeared ___________ ______________ this _______ day of 2022, who after first being duly sworn, states that the above and foregoing is true and correct. NOTARY PUBLIC State of Florida My Commission expires: