Preview
Electronically Filed 04/29/2013 11:27:36 AM ET
IN THE COUNTY COURT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO:
PREMIUM QUALITY MEDICAL CENTER CORP a/a/o Rosa E Bustillos Wong,
Plaintiff,
vs.
GEICO GENERAL INSURANCE COMPANY,
Defendant(s).
REQUEST TO PRODUCE
Plaintiff, PREMIUM QUALITY MEDICAL CENTER CORP a/a/o Rosa E Bustillos Wong, by
and through the undersigned attorneys, pursuant to Rule 1.350, Florida Rules of Civil Procedure,
hereby requests the Defendant to produce the items and matters hereinafter set forth.
YOUR ATTENTION IS INVITED TO THE REQUIREMENTS
OF RULE 1.350(b) WHEREIN THE PARTY TO WHOM THIS
REQUEST IS DIRECTED IS REQUIRED TO SERVE A WRITTEN
RESPONSE HERETO WITHIN FORTY-FIVE (45) DAYS AFTER
THE SERVICE HEREOF SUBJECT TO THE ALLOWANCE OF A
SHORTER OR LONGER TIME BY THE COURT.
PLAINTIFF REQUESTS THAT ALL COPIES OR ITEMS
PRODUCED BE AT LEAST FULL-SIZE (8 4” X 11” OR
8 4” X 14”) AND LEGIBLE, OTHERWISE ORIGINALS ARE
REQUIRED.
The items and matters to be produced are as follows:
1. All insurance policies that would cover Rosa E Bustillos Wong and/or Rosa E Bustillo,
together with any declaration of coverage page and sworn statement of a corporate officer of
Defendant attesting to the coverage and authenticity of the policy as required by Florida Statutes.
2. All sworn statements and/or Examinations Under Oath taken of any interested party to this
action including but not limited Rosa E Bustillos Wong.
3. The entire PIP file maintained by you or anyone on your behalf with regard to Rosa E
Bustillos Wong, cover to cover, including original jackets and everything contained within the file,
including, without limitation:(a) All notations regarding notice of the accident;
(b) All telephone messages to or from you, or any of your agents on your behalf;
(c) All accident reports prepared by you, any law enforcement agencies or the Plaintiff or your
insured;
(d) All interoffice memoranda;
(e) All correspondence to or from anyone, including any insurance agencies, any doctors’
offices, any employers, any agencies hired to select doctors for “independent medical
examinations” and any law enforcement agencies;
(f) Any and all PIP forms, including PIP applications, medical report forms, employer
verification forms, authorization forms and any other forms contained in said file; and,
(g) All records of the time expended on file or costs expended on file in the handling of any
aspect of the Plaintiff's claim.
4. Any and all reports or statements from any expert indicating that the treatment rendered by
Plaintiff was not reasonable, related or necessary.
5. Any and all contracts or agreements between GEICO GENERAL INSURANCE
COMPANY, and any medical review or bill review company utilized in evaluating the bills received
by Plaintiff.
6. A copy of the C.V, of any doctor utilized in determining whether or not to pay the bills
submitted by Plaintiff.
7. Any and all information or files maintained by the Defendant regarding the handling of
bills submitted by Plaintiff.
8. Documentation indicating the amount of money Defendant has paid any IME doctor
utilized in the instant case over the last 3 years.
9. Documentation indicating the amount of money Defendant has paid any IME doctor
utilized in the instant case for work done in this case.10. Copies of any and all forms, correspondence, or reports received by you or any of your
agents on your behalf concerning Rosa E Bustillos Wong’s medical condition from anyone.
11. All correspondence, forms, notations, memoranda or information transmitted by you in
any form whatsoever to any physician’s office or health care provider’s office concerning Rosa E
Bustillos Wong’s physical and/or mental condition.
12. Any and all surveillance films or photographs taken by you or anyone on your behalf of
Rosa E Bustillos Wong.
13. Any and all statements taken by the Defendant of any witnesses with regard to any fact
relevant to any fact in this case, such as was taken prior to the filing of suit in this matter.
14. Any and all photographs taken by the Defendant showing the extent of damage to any of
the vehicles involved in the accident as were taken prior to the filing of suit.
15. Any and all photographs taken by the Defendant of the scene of the accident at any time
prior to the filing of suit.
16. Any and all estimates of repair or statements concerning the nature and extent of damage to any
of the vehicles involved in the accident.
17. Any and all writings, memorandums, notes or other materials reflecting examination by the
Defendant of any of the vehicles involved in the accident.
18. Any correspondence, memo or documentation of contact between any PIP adjuster on the
file and any physician, health care provider or employer to retrieve information necessary for the
processing of Rosa E Bustillos Wong’s claim for benefits.
As good cause for same, the Plaintiff would show unto the Court that the referenced
documents requested above are in the exclusive care, custody and control of the Defendants, agents,
servants, employees, insurance companies or attorneys; that they are relevant and material to the
issues of this lawsuit, and the Plaintiff cannot secure same or the equivalent thereof but for leave of
this Court.WHEREFORE, for the good cause set forth above, the Plaintiff would petition the Court that
the requested documents be produced pursuant to the applicable Rules of Civil Procedure.
I HEREBY CERTIFY that a copy of the foregoing was attached to the copy of the Summons
and Complaint to be served on the Defendant herein and the original filed with the Clerk of the Court
at the time of filing this law suit.
Law Offices of Andreu, Palma & Andreu, PL
Attorneys for Plaintiff
701 SW 27" Avenfe,
Miami, FL 3313
13-02074
Preview
Electronically Filed 04/29/2013 11:27:36 AM ET IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO: PREMIUM QUALITY MEDICAL CENTER CORP a/a/o Rosa E Bustillos Wong, Plaintiff, vs. GEICO GENERAL INSURANCE COMPANY, Defendant(s). REQUEST TO PRODUCE Plaintiff, PREMIUM QUALITY MEDICAL CENTER CORP a/a/o Rosa E Bustillos Wong, by and through the undersigned attorneys, pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby requests the Defendant to produce the items and matters hereinafter set forth. YOUR ATTENTION IS INVITED TO THE REQUIREMENTS OF RULE 1.350(b) WHEREIN THE PARTY TO WHOM THIS REQUEST IS DIRECTED IS REQUIRED TO SERVE A WRITTEN RESPONSE HERETO WITHIN FORTY-FIVE (45) DAYS AFTER THE SERVICE HEREOF SUBJECT TO THE ALLOWANCE OF A SHORTER OR LONGER TIME BY THE COURT. PLAINTIFF REQUESTS THAT ALL COPIES OR ITEMS PRODUCED BE AT LEAST FULL-SIZE (8 4” X 11” OR 8 4” X 14”) AND LEGIBLE, OTHERWISE ORIGINALS ARE REQUIRED. The items and matters to be produced are as follows: 1. All insurance policies that would cover Rosa E Bustillos Wong and/or Rosa E Bustillo, together with any declaration of coverage page and sworn statement of a corporate officer of Defendant attesting to the coverage and authenticity of the policy as required by Florida Statutes. 2. All sworn statements and/or Examinations Under Oath taken of any interested party to this action including but not limited Rosa E Bustillos Wong. 3. The entire PIP file maintained by you or anyone on your behalf with regard to Rosa E Bustillos Wong, cover to cover, including original jackets and everything contained within the file, including, without limitation:(a) All notations regarding notice of the accident; (b) All telephone messages to or from you, or any of your agents on your behalf; (c) All accident reports prepared by you, any law enforcement agencies or the Plaintiff or your insured; (d) All interoffice memoranda; (e) All correspondence to or from anyone, including any insurance agencies, any doctors’ offices, any employers, any agencies hired to select doctors for “independent medical examinations” and any law enforcement agencies; (f) Any and all PIP forms, including PIP applications, medical report forms, employer verification forms, authorization forms and any other forms contained in said file; and, (g) All records of the time expended on file or costs expended on file in the handling of any aspect of the Plaintiff's claim. 4. Any and all reports or statements from any expert indicating that the treatment rendered by Plaintiff was not reasonable, related or necessary. 5. Any and all contracts or agreements between GEICO GENERAL INSURANCE COMPANY, and any medical review or bill review company utilized in evaluating the bills received by Plaintiff. 6. A copy of the C.V, of any doctor utilized in determining whether or not to pay the bills submitted by Plaintiff. 7. Any and all information or files maintained by the Defendant regarding the handling of bills submitted by Plaintiff. 8. Documentation indicating the amount of money Defendant has paid any IME doctor utilized in the instant case over the last 3 years. 9. Documentation indicating the amount of money Defendant has paid any IME doctor utilized in the instant case for work done in this case.10. Copies of any and all forms, correspondence, or reports received by you or any of your agents on your behalf concerning Rosa E Bustillos Wong’s medical condition from anyone. 11. All correspondence, forms, notations, memoranda or information transmitted by you in any form whatsoever to any physician’s office or health care provider’s office concerning Rosa E Bustillos Wong’s physical and/or mental condition. 12. Any and all surveillance films or photographs taken by you or anyone on your behalf of Rosa E Bustillos Wong. 13. Any and all statements taken by the Defendant of any witnesses with regard to any fact relevant to any fact in this case, such as was taken prior to the filing of suit in this matter. 14. Any and all photographs taken by the Defendant showing the extent of damage to any of the vehicles involved in the accident as were taken prior to the filing of suit. 15. Any and all photographs taken by the Defendant of the scene of the accident at any time prior to the filing of suit. 16. Any and all estimates of repair or statements concerning the nature and extent of damage to any of the vehicles involved in the accident. 17. Any and all writings, memorandums, notes or other materials reflecting examination by the Defendant of any of the vehicles involved in the accident. 18. Any correspondence, memo or documentation of contact between any PIP adjuster on the file and any physician, health care provider or employer to retrieve information necessary for the processing of Rosa E Bustillos Wong’s claim for benefits. As good cause for same, the Plaintiff would show unto the Court that the referenced documents requested above are in the exclusive care, custody and control of the Defendants, agents, servants, employees, insurance companies or attorneys; that they are relevant and material to the issues of this lawsuit, and the Plaintiff cannot secure same or the equivalent thereof but for leave of this Court.WHEREFORE, for the good cause set forth above, the Plaintiff would petition the Court that the requested documents be produced pursuant to the applicable Rules of Civil Procedure. I HEREBY CERTIFY that a copy of the foregoing was attached to the copy of the Summons and Complaint to be served on the Defendant herein and the original filed with the Clerk of the Court at the time of filing this law suit. Law Offices of Andreu, Palma & Andreu, PL Attorneys for Plaintiff 701 SW 27" Avenfe, Miami, FL 3313 13-02074