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Filing # 129383376 E-Filed 06/23/2021 06:09:07 PM
IN THE COUNTY COURT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO:
MAZEL MEDICAL CENTER INC a/a/o Leon Moreno,
Plaintiff,
vs.
UNITED AUTOMOBILE INSURANCE COMPANY,
Defendant(s).
__________________________________/
COMPLAINT
Plaintiff, MAZEL MEDICAL CENTER INC a/a/o Leon Moreno, (hereinafter "Plaintiff"), by
and through the undersigned counsel sues the Defendant, UNITED AUTOMOBILE INSURANCE
COMPANY, (hereinafter "Defendant"), and alleges as follows:
1. This is an action for damages that do not exceed $10,000.00, exclusive of interest, costs,
and attorney's fees, and is within the jurisdiction of this court.
2. That Leon Moreno assigned Plaintiff the rights and benefits to his/her PIP policy for
valuable consideration. This gives the Plaintiff the right to pursue an action directly against the
Defendant insurance company for any payment of any treatment incurred by Leon Moreno covered by
Defendant’s policy of insurance and collect all reasonable attorney’s fees pursuant to Florida Statutes
Section 627.736 and 627.428.
3. That at all times material to this cause, Leon Moreno received treatment from Plaintiff
whose main place of business is in Miami-Dade County, Florida.
4. That at all times material hereto, Defendant was a corporation duly licensed to transact
insurance business in the State of Florida and was doing business in Miami-Dade County, Florida.
5. This is an action brought pursuant to the “Florida Motor Vehicle No-Fault Law.”
6. On or about June 23, 2020, Leon Moreno was involved in a motor vehicle accident in
Miami-Dade County, Florida, in which Leon Moreno sustained personal injuries and was subsequently
treated by Plaintiff.
7. That at all times material to this cause, Leon Moreno was covered or entitled to coverage
through UNITED AUTOMOBILE INSURANCE COMPANY and had personal injury protection
benefits attached to a policy and said benefits covered loss of income and medical bills.
8. Plaintiff does not have a copy of the insurance contract to attach hereto, but Defendant
is in possession of the original policy which includes the standard amendatory endorsement issued in
accordance to the “Florida Motor Vehicle No-Fault Law.”
9. The insurance contract was in full force and effect on the date of the said accident. The
INSURED’S policy number is UAD831140 and reference number is 0100229902-002.
10. The insurance contract provided Personal Injury Protection coverage and medical
expense coverage for Leon Moreno for the personal injuries Leon Moreno sustained in the accident.
11. That the Assignment of Benefits gives the Plaintiff the right to seek all amounts owed
to him/her from the Defendant and makes the Plaintiff an assignee under the above described insurance
contract.
12. Pursuant to said assignment, Plaintiff submitted to Defendant bills for reasonable,
related,
and medically necessary treatment of Leon Moreno totaling $7,700.00 for dates of service July 2, 2020
through July 2, 2020.
13. Demand was made upon Defendant to pay benefits pursuant to the policy and Plaintiff
and Leon Moreno have otherwise complied with all conditions precedent to recover thereon.
14. Defendant has failed or refused to make timely payment of benefits pursuant to the
policy and has in turn breached same.
15. That as a result of the accident, Leon Moreno has sustained injuries which necessitated
the incurring of medical bills and other expenses which were reasonable and necessary as provided for
in Florida Statute §627.736. That as a result of the Defendant’s breach of this policy of insurance, Leon
Moreno has suffered damages which have been assigned to Plaintiff. These damages include the
incurring of medical bills resulting from said accident, and interest on the amount of said bills after a
period of thirty (30) days.
16. That as a result of this breach, Plaintiff had to retain an attorney to represent it and has
incurred a reasonable attorney fee and Plaintiff requests that a reasonable attorney’s fee be awarded
pursuant to Florida Statute §627.428.
WHEREFORE, the Plaintiff, MAZEL MEDICAL CENTER INC a/a/o Leon Moreno sues the
Defendant, UNITED AUTOMOBILE INSURANCE COMPANY, for damages, Personal Injury
Protection Benefits, prejudgment and post-judgment interest, costs and attorney fees pursuant to Section
627.428, Florida Statutes.
DEMAND FOR JURY TRIAL IS SOUGHT ON ALL ISSUES SO TRIABLE.
DATED this 23rd day of June, 2021.
Respectfully submitted,
Andreu, Palma, Lavin & Solis, PLLC
Attorneys for Plaintiff
815 NW 57th Avenue, Suite 401
Miami, FL 33126-2363
Tel. (305) 631-0175
Fax. (305) 631-1816
E-mails: pleadings4@andreupalma.com;ysolis@andreupalma.com
By:____/s/Yulexy Solis_________
Yulexy Solis, Esq.
FBN 91230
20-05525
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Filing # 129383376 E-Filed 06/23/2021 06:09:07 PM IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO: MAZEL MEDICAL CENTER INC a/a/o Leon Moreno, Plaintiff, vs. UNITED AUTOMOBILE INSURANCE COMPANY, Defendant(s). __________________________________/ COMPLAINT Plaintiff, MAZEL MEDICAL CENTER INC a/a/o Leon Moreno, (hereinafter "Plaintiff"), by and through the undersigned counsel sues the Defendant, UNITED AUTOMOBILE INSURANCE COMPANY, (hereinafter "Defendant"), and alleges as follows: 1. This is an action for damages that do not exceed $10,000.00, exclusive of interest, costs, and attorney's fees, and is within the jurisdiction of this court. 2. That Leon Moreno assigned Plaintiff the rights and benefits to his/her PIP policy for valuable consideration. This gives the Plaintiff the right to pursue an action directly against the Defendant insurance company for any payment of any treatment incurred by Leon Moreno covered by Defendant’s policy of insurance and collect all reasonable attorney’s fees pursuant to Florida Statutes Section 627.736 and 627.428. 3. That at all times material to this cause, Leon Moreno received treatment from Plaintiff whose main place of business is in Miami-Dade County, Florida. 4. That at all times material hereto, Defendant was a corporation duly licensed to transact insurance business in the State of Florida and was doing business in Miami-Dade County, Florida. 5. This is an action brought pursuant to the “Florida Motor Vehicle No-Fault Law.” 6. On or about June 23, 2020, Leon Moreno was involved in a motor vehicle accident in Miami-Dade County, Florida, in which Leon Moreno sustained personal injuries and was subsequently treated by Plaintiff. 7. That at all times material to this cause, Leon Moreno was covered or entitled to coverage through UNITED AUTOMOBILE INSURANCE COMPANY and had personal injury protection benefits attached to a policy and said benefits covered loss of income and medical bills. 8. Plaintiff does not have a copy of the insurance contract to attach hereto, but Defendant is in possession of the original policy which includes the standard amendatory endorsement issued in accordance to the “Florida Motor Vehicle No-Fault Law.” 9. The insurance contract was in full force and effect on the date of the said accident. The INSURED’S policy number is UAD831140 and reference number is 0100229902-002. 10. The insurance contract provided Personal Injury Protection coverage and medical expense coverage for Leon Moreno for the personal injuries Leon Moreno sustained in the accident. 11. That the Assignment of Benefits gives the Plaintiff the right to seek all amounts owed to him/her from the Defendant and makes the Plaintiff an assignee under the above described insurance contract. 12. Pursuant to said assignment, Plaintiff submitted to Defendant bills for reasonable, related, and medically necessary treatment of Leon Moreno totaling $7,700.00 for dates of service July 2, 2020 through July 2, 2020. 13. Demand was made upon Defendant to pay benefits pursuant to the policy and Plaintiff and Leon Moreno have otherwise complied with all conditions precedent to recover thereon. 14. Defendant has failed or refused to make timely payment of benefits pursuant to the policy and has in turn breached same. 15. That as a result of the accident, Leon Moreno has sustained injuries which necessitated the incurring of medical bills and other expenses which were reasonable and necessary as provided for in Florida Statute §627.736. That as a result of the Defendant’s breach of this policy of insurance, Leon Moreno has suffered damages which have been assigned to Plaintiff. These damages include the incurring of medical bills resulting from said accident, and interest on the amount of said bills after a period of thirty (30) days. 16. That as a result of this breach, Plaintiff had to retain an attorney to represent it and has incurred a reasonable attorney fee and Plaintiff requests that a reasonable attorney’s fee be awarded pursuant to Florida Statute §627.428. WHEREFORE, the Plaintiff, MAZEL MEDICAL CENTER INC a/a/o Leon Moreno sues the Defendant, UNITED AUTOMOBILE INSURANCE COMPANY, for damages, Personal Injury Protection Benefits, prejudgment and post-judgment interest, costs and attorney fees pursuant to Section 627.428, Florida Statutes. DEMAND FOR JURY TRIAL IS SOUGHT ON ALL ISSUES SO TRIABLE. DATED this 23rd day of June, 2021. Respectfully submitted, Andreu, Palma, Lavin & Solis, PLLC Attorneys for Plaintiff 815 NW 57th Avenue, Suite 401 Miami, FL 33126-2363 Tel. (305) 631-0175 Fax. (305) 631-1816 E-mails: pleadings4@andreupalma.com;ysolis@andreupalma.com By:____/s/Yulexy Solis_________ Yulexy Solis, Esq. FBN 91230 20-05525