On January 09, 2019 a
Answer
was filed
involving a dispute between
Leyva, Aracelys,
Multimed Care, Inc.,
and
Geico General Insurance Company,
for Personal Injury Protection ($8,001 - $15,000)
in the District Court of Miami-Dade County.
Preview
Filing # 86130001 E-Filed 03/08/2019 05:08:56 PM
IN THE COUNTY COURT, IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
Case No.: 19-629-CC-26
MULTIMED CARE INC A/A/O
ARACELYS LEYVA,
Plaintiff
vs.
GEICO GENERAL INSURANCE
COMPANY,
Defendant
ANSWER AND AFFIRMATIVE DEFENSES
The Defendant, GEICO General Insurance Company, files its Answer and Affirmative
Defenses to the Complaint filed herein as follows:
ADMISSIONS
Defendant admits this Court has jurisdiction. Defendant admits that it is a corporation
qualified and licensed to do business in the State of Florida as a casualty insurance carrier, and is
actively engaged in business in Miami Dade County, Florida. Defendant issued the subject
policy of insurance in the State of Florida, which complies with all Florida statutes.
DENIALS
Defendant is without knowledge and, therefore, denies all allegations in Plaintiff's
complaint not specifically admitted above and demands strict proof thereof.
AFFIRMATIVE DEFENSES
1 Defendant states that with reference to the No-Fault benefits claimed by the Plaintiff,
payment of all reasonable expenses has been made for all necessary and related medical services
and treatment of the Plaintiff as provided by the policy and Section 627.736(a), Florida Statutes.Any services, treatment or expenses for which the Plaintiff seeks medical benefits in this litigation
are not reasonable, necessary or related under Section 627.736(a), Florida Statutes.
2 Defendant reserves the right to assert additional affirmative defenses.
DEMAND FOR JURY TRIAL
The Defendant requests a trial by jury of all triable issues.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Electronic Mail on this the 8" day of March, 2019 to the following designated service email
addresses: Majid Vossoughi, Esq., Majid Vossoughi, P.A., mail@piplawsuit.com,
majid@piplawsuit.com.
LAW OFFICE OF HAYDEE DE LA ROSA-
TOLGYESI
/s/ Manuel Mendoza, Esq.
(Employees of GEICO General Insurance
Company)
Florida Bar No.: 67246
2600 Douglas Road, Suite 700
Coral Gables, FL 33134
Phone: 786-483-1800
Facsimile: 305-373-3661
Attorney for Defendant GEICO General Insurance
Service Email: Miamipipgeico@geico.com
Document Filed Date
March 08, 2019
Case Filing Date
January 09, 2019
Category
Personal Injury Protection ($8,001 - $15,000)
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Filing # 86130001 E-Filed 03/08/2019 05:08:56 PM IN THE COUNTY COURT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA Case No.: 19-629-CC-26 MULTIMED CARE INC A/A/O ARACELYS LEYVA, Plaintiff vs. GEICO GENERAL INSURANCE COMPANY, Defendant ANSWER AND AFFIRMATIVE DEFENSES The Defendant, GEICO General Insurance Company, files its Answer and Affirmative Defenses to the Complaint filed herein as follows: ADMISSIONS Defendant admits this Court has jurisdiction. Defendant admits that it is a corporation qualified and licensed to do business in the State of Florida as a casualty insurance carrier, and is actively engaged in business in Miami Dade County, Florida. Defendant issued the subject policy of insurance in the State of Florida, which complies with all Florida statutes. DENIALS Defendant is without knowledge and, therefore, denies all allegations in Plaintiff's complaint not specifically admitted above and demands strict proof thereof. AFFIRMATIVE DEFENSES 1 Defendant states that with reference to the No-Fault benefits claimed by the Plaintiff, payment of all reasonable expenses has been made for all necessary and related medical services and treatment of the Plaintiff as provided by the policy and Section 627.736(a), Florida Statutes.Any services, treatment or expenses for which the Plaintiff seeks medical benefits in this litigation are not reasonable, necessary or related under Section 627.736(a), Florida Statutes. 2 Defendant reserves the right to assert additional affirmative defenses. DEMAND FOR JURY TRIAL The Defendant requests a trial by jury of all triable issues. CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic Mail on this the 8" day of March, 2019 to the following designated service email addresses: Majid Vossoughi, Esq., Majid Vossoughi, P.A., mail@piplawsuit.com, majid@piplawsuit.com. LAW OFFICE OF HAYDEE DE LA ROSA- TOLGYESI /s/ Manuel Mendoza, Esq. (Employees of GEICO General Insurance Company) Florida Bar No.: 67246 2600 Douglas Road, Suite 700 Coral Gables, FL 33134 Phone: 786-483-1800 Facsimile: 305-373-3661 Attorney for Defendant GEICO General Insurance Service Email: Miamipipgeico@geico.com