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Case Number: CACE-15-021427 Division: 02
Filing # 35189209 E-Filed 12/04/2015 04:26:56 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
TWO AND TWO, LLC d/b/a
COMPLETE REHAB AND MEDICAL
CENTER OF HOLLYWOOD, TWO CASE NO.:
AND TWO, LLC d/b/a COMPLETE
REHAB AND MEDICAL CENTER OF
DEERFIELD, ORTHOPEDIC AND
SPINE CENTER OF SOUTH FLORIDA
d/b/a NEUROSURGICAL ASSOCIATES
OF SOUTH FLORIDA, ORTHOPEDIC
AND SPINE CENTER OF SOUTH FLORIDA,
LLC, and UNIVERSAL MEDIQUIP, LLC,
Plaintiffs,
Vv.
TODD CASH ALOFS d/b/a
THE ALOFS LAW FIRM, and
DAVID GUNTER,
Defendants.
/
PLAINTIFF, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA’S, FIRST
REQUEST FOR ADMISSIONS TO DEFENDANT, TODD CASH ALOFS d/b/a
THE ALOFS LAW FIRM
COMES NOW, the Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH
FLORIDA, by and through undersigned counsel and pursuant to Rule 1.370, Florida Rules of Civil
Procedure, hereby requests that Defendant, TODD CASH ALOFS d/b/a THE ALOFS LAW
FIRM, admit or deny the following within forty-five (45) days hereof:
l. Admit that you knew Defendant, DAVID GUNTER, had entered into the Letter of
Protection agreement attached to the Complaint and marked as composite Exhibit “D.”
2. Admit that prior to disbursal of the proceeds of the settlement of the Underlying
Tort Action, you knew Defendant, DAVID GUNTER, had entered into Letter of Protection
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/4/2015 4:26:54 PM.****agreement for medical services with the Plaintiff, ORTHOPEDIC AND SPINE CENTER OF
SOUTH FLORIDA.
3. Admit that prior to disbursal of the proceeds of the settlement of the Underlying
Tort Action, you received a copy of Defendant, DAVID GUNTER’s, Letter of Protection with
Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA.
4. Admit that prior to disbursal of the proceeds of the settlement of the Underlying
Tort Action, you knew Defendant, DAVID GUNTER, had provided the Plaintiff, ORTHOPEDIC
AND SPINE CENTER OF SOUTH FLORIDA, with a lien in the proceeds of settlement of the
Underlying Tort Action, (as defined in the Complaint).
5. Admit that that prior to disbursal of the proceeds of settlement of the Underlying
Tort Action, you knew Defendant, DAVID GUNTER, had an outstanding medical bill with
Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA.
6. Admit that prior to disbursal of the proceeds of settlement of the Underlying Tort
Action, you received a copy of Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH
FLORIDA’s, invoice for Defendant, DAVID GUNTER, reflecting an outstanding balance of
$42,507.95.
7. Admit that you did not pay Plaintiff, ORTHOPEDIC AND SPINE CENTER OF
SOUTH FLORIDA’s, medical bill of $42,507.95 for Defendant, DAVID GUNTER.
8. Admit that the charges reflected on the invoices from Plaintiff, ORTHOPEDIC
AND SPINE CENTER OF SOUTH FLORIDA, are fair and reasonable.
9. Admit that you submitted, on behalf of Defendant, DAVID GUNTER, the invoices
from Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA, to the insurance
company and/or defense in the Underlying Tort Action, in order to induce settlement.10. Admit that at no time prior to the entry of the settlement relating to the Underlying
Tort Action, did anyone contest the reasonableness of the invoices from the Plaintiff,
ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA.
Dated: December 4, 2015 SPYREDES LAW FIRM, P.A.
4400 North Federal Hwy., Suite 408
Boca Raton, Florida 33431
Tel: 561-405-9000; Fax: 561-221-6730
Designated Emails:
Primary: ServiceDocuments@spylaw.net
Secondary: monica(@/spylaw.net
/s! Sheena D. Smith
Sheena D. Smith, Esq.
Florida Bar No.: 118919
CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that a copy of Plaintiff ORTHOPEDIC AND SPINE CENTER OF
SOUTH FLORIDA’s, First Request for Admissions to Defendant, TODD CASH ALOFS d/b/a
THE ALOFS LAW FIRM, has been delivered to a process server for service along with the
Complaint in this action.
/s/ Sheena D. Smith
Sheena D. Smith, Esq.
Florida Bar No.: 118919
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Case Number: CACE-15-021427 Division: 02 Filing # 35189209 E-Filed 12/04/2015 04:26:56 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA TWO AND TWO, LLC d/b/a COMPLETE REHAB AND MEDICAL CENTER OF HOLLYWOOD, TWO CASE NO.: AND TWO, LLC d/b/a COMPLETE REHAB AND MEDICAL CENTER OF DEERFIELD, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA d/b/a NEUROSURGICAL ASSOCIATES OF SOUTH FLORIDA, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA, LLC, and UNIVERSAL MEDIQUIP, LLC, Plaintiffs, Vv. TODD CASH ALOFS d/b/a THE ALOFS LAW FIRM, and DAVID GUNTER, Defendants. / PLAINTIFF, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA’S, FIRST REQUEST FOR ADMISSIONS TO DEFENDANT, TODD CASH ALOFS d/b/a THE ALOFS LAW FIRM COMES NOW, the Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA, by and through undersigned counsel and pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant, TODD CASH ALOFS d/b/a THE ALOFS LAW FIRM, admit or deny the following within forty-five (45) days hereof: l. Admit that you knew Defendant, DAVID GUNTER, had entered into the Letter of Protection agreement attached to the Complaint and marked as composite Exhibit “D.” 2. Admit that prior to disbursal of the proceeds of the settlement of the Underlying Tort Action, you knew Defendant, DAVID GUNTER, had entered into Letter of Protection *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/4/2015 4:26:54 PM.****agreement for medical services with the Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA. 3. Admit that prior to disbursal of the proceeds of the settlement of the Underlying Tort Action, you received a copy of Defendant, DAVID GUNTER’s, Letter of Protection with Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA. 4. Admit that prior to disbursal of the proceeds of the settlement of the Underlying Tort Action, you knew Defendant, DAVID GUNTER, had provided the Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA, with a lien in the proceeds of settlement of the Underlying Tort Action, (as defined in the Complaint). 5. Admit that that prior to disbursal of the proceeds of settlement of the Underlying Tort Action, you knew Defendant, DAVID GUNTER, had an outstanding medical bill with Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA. 6. Admit that prior to disbursal of the proceeds of settlement of the Underlying Tort Action, you received a copy of Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA’s, invoice for Defendant, DAVID GUNTER, reflecting an outstanding balance of $42,507.95. 7. Admit that you did not pay Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA’s, medical bill of $42,507.95 for Defendant, DAVID GUNTER. 8. Admit that the charges reflected on the invoices from Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA, are fair and reasonable. 9. Admit that you submitted, on behalf of Defendant, DAVID GUNTER, the invoices from Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA, to the insurance company and/or defense in the Underlying Tort Action, in order to induce settlement.10. Admit that at no time prior to the entry of the settlement relating to the Underlying Tort Action, did anyone contest the reasonableness of the invoices from the Plaintiff, ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA. Dated: December 4, 2015 SPYREDES LAW FIRM, P.A. 4400 North Federal Hwy., Suite 408 Boca Raton, Florida 33431 Tel: 561-405-9000; Fax: 561-221-6730 Designated Emails: Primary: ServiceDocuments@spylaw.net Secondary: monica(@/spylaw.net /s! Sheena D. Smith Sheena D. Smith, Esq. Florida Bar No.: 118919 CERTIFICATE OF SERVICE I HEREBY CERTIFY, that a copy of Plaintiff ORTHOPEDIC AND SPINE CENTER OF SOUTH FLORIDA’s, First Request for Admissions to Defendant, TODD CASH ALOFS d/b/a THE ALOFS LAW FIRM, has been delivered to a process server for service along with the Complaint in this action. /s/ Sheena D. Smith Sheena D. Smith, Esq. Florida Bar No.: 118919