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Filing # 39795333 E-Filed 04/04/2016 11:29:33 AM
XTREME MEDICAL CENTER, CORP. a/a/o IN THE COUNTY COURT, IN AND FOR
LEYBELYS SARDINAS MIAMI-DADE COUNTY, FLORIDA
Plaintiff, CIVIL DIVISION
VS. CASE NO.
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY
Defendant
/
PLAINTIFF’S REQUEST FOR PRODUCTION
COMES NOW, the Plaintiff, VALLES & ASSOCIATES REHABILITATION SERVICES,
INC., by and through their undersigned counsel and pursuant to Florida Rules of Civil Procedure,
Rule 1.350, files this their Request to Produce requesting that Defendant produce Copies of the
following documents within the time limits required by the aforesaid rule;
1. All insurance policies that would provide coverage to the Plaintiff herein, including a
declaration of coverage page and sworn statement of a corporate office attesting to the
coverage and authenticity of the policy as required by Florida Statutes.
2. The entire PIP file maintained by you or anyone on your behalf with regard to the Plaintiff
and Plaintiffs assignee, insured or beneficiary of the policy referred to above, cover to cover,
including but not limited to original jackets, everything contained within the file, and
electronic file notes not physically transcribed on paper.
3. All notations and documents regarding Defendant’s first notice of the accident, including but
not limited to correspondence with the claimant’s attorney, telephone notations regarding
reporting of the accident, medical bills which alerted Defendant of the accident, ete.
4. All telephone messages, logs or notations evidencing all telephone calls made and received
by you, or any of your agents on your behalf, regarding this claim.
5. All accident reports prepared by law enforcement agencies regarding the accident referred to
in Plaintiffs complaint.
6. All accident reports prepared by you regarding the accident referred to in Plaintiff's
Complaint.10.
dl.
12.
13
14,
1S.
16.
17.
18.
All interoffice memoranda regarding Plaintiff's or LEYBELYS SARDINAS claim for
benefits under the policy of insurance at issue.
All correspondence a) received by you, your agents, or employees from any source or b) sent
by you, your agents or employees to any source, regarding the claim at issue, including but
not limited to any insurance agencies, doctors’ offices, any employers, agencies hired to
select doctors and/or schedule “independent medical examinations,” “peer review,” and/or
“examinations under oath,” law enforcement agencies, investigative agencies, attorneys,
insureds and/or their relatives
Any and all PIP forms, including PIP applications, attending physician and/or medical report
forms, employer verification/lost wage forms, medical authorization forms, insurance
disclosure, policy defense statement and other requests for information sent and/or received
by you, your agents, and employees to anyone associated with the claim for no-fault
insurance benefits at issue in this case.
If the Defendant is contesting that the policy did not provide coverage for the bills at issue,
the entire underwriting file including the application for insurance and all renewals.
All documents pertaining to or LEYBELYS SARDINAS attendance or non attendance at an
Examination Under Oath notice letters, fax confirmations, greed card receipts, proof of
mailing, all security logs and sign in sheets for the dates of any Examinations Under Oath.
All documents pertaining to or LEYBELYS SARDINAS attendance or non attendance at an
Independent Medical Examinations, including but not limited to Independent Medical
Examinations notice letters, fax confirmations, greed card receipts, proof of mailing, all
security logs and sign in sheets for the dates of any Independent Medical Examinations.
Copies of any and all independent medical examinations or peer review reports.
Copies of all examinations under oath, recorded statements, written statements, whether
transcribed or in recorded form (tapes, discs, electronic media, etc.) regarding the claim at
issue.
The most recent no-fault payout sheet.
All checks issued for payment of any no-fault benefits to any insured, medical provider or
other beneficiary under LEYBELYS SARDINAS claim.
All letters, explanation of benefits and other correspondence sent explaining decisions to pay,
reduce, deny, suspend, terminate or cancel payment of benefits to any medical provider.
Copies of all medical records, bills, notices of intent to initiate treatment and any other
correspondence received by Defendant from any medical provider in connection with
services rendered to LEYBELYS SARDINAS in connection with this claim.19. Copies of all photographs, videotapes, writings, drawings maps, vehicle repair estimates and
or other notes that Defendant has in their possession regarding the accident scene, the
property damage to any of the automobiles in the subject accident, and the injuries sustained
by the patient in this lawsuit.
20. Copies of all prior and subsequent no-fault insurance claim files that Defendant has for the
patient alleged in Plaintiff's complaint.
21. Any and all surveillance reports, surveillance films, surveillance photographs, claims history
reports or other investigative reports prepared by you or on your behalf with regard to the
Plaintiff or the patient involved in the subject accident.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon
Defendant by service of process.
THE LAW OFFICES OF FELICIA B. BROWN, ESO.
RICHARD J. MARKOWITZ, P.A BROWN LAW GROUP, P.A.
(CO-COUNSEL) PO BOX 558427
13701 N. KENDALL DRIVE, MIAMI, FLORIDA 33255
SUITE 201 TEL: (305) 667-3244
MIAMI, FLORIDA 33186 FAX: (305) 667-3248
BY: /S/ FELICIA B. BROWN
FELICIA B. BROWN, ESQ.
FL BAR NO.: 68319
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Filing # 39795333 E-Filed 04/04/2016 11:29:33 AM XTREME MEDICAL CENTER, CORP. a/a/o IN THE COUNTY COURT, IN AND FOR LEYBELYS SARDINAS MIAMI-DADE COUNTY, FLORIDA Plaintiff, CIVIL DIVISION VS. CASE NO. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY Defendant / PLAINTIFF’S REQUEST FOR PRODUCTION COMES NOW, the Plaintiff, VALLES & ASSOCIATES REHABILITATION SERVICES, INC., by and through their undersigned counsel and pursuant to Florida Rules of Civil Procedure, Rule 1.350, files this their Request to Produce requesting that Defendant produce Copies of the following documents within the time limits required by the aforesaid rule; 1. All insurance policies that would provide coverage to the Plaintiff herein, including a declaration of coverage page and sworn statement of a corporate office attesting to the coverage and authenticity of the policy as required by Florida Statutes. 2. The entire PIP file maintained by you or anyone on your behalf with regard to the Plaintiff and Plaintiffs assignee, insured or beneficiary of the policy referred to above, cover to cover, including but not limited to original jackets, everything contained within the file, and electronic file notes not physically transcribed on paper. 3. All notations and documents regarding Defendant’s first notice of the accident, including but not limited to correspondence with the claimant’s attorney, telephone notations regarding reporting of the accident, medical bills which alerted Defendant of the accident, ete. 4. All telephone messages, logs or notations evidencing all telephone calls made and received by you, or any of your agents on your behalf, regarding this claim. 5. All accident reports prepared by law enforcement agencies regarding the accident referred to in Plaintiffs complaint. 6. All accident reports prepared by you regarding the accident referred to in Plaintiff's Complaint.10. dl. 12. 13 14, 1S. 16. 17. 18. All interoffice memoranda regarding Plaintiff's or LEYBELYS SARDINAS claim for benefits under the policy of insurance at issue. All correspondence a) received by you, your agents, or employees from any source or b) sent by you, your agents or employees to any source, regarding the claim at issue, including but not limited to any insurance agencies, doctors’ offices, any employers, agencies hired to select doctors and/or schedule “independent medical examinations,” “peer review,” and/or “examinations under oath,” law enforcement agencies, investigative agencies, attorneys, insureds and/or their relatives Any and all PIP forms, including PIP applications, attending physician and/or medical report forms, employer verification/lost wage forms, medical authorization forms, insurance disclosure, policy defense statement and other requests for information sent and/or received by you, your agents, and employees to anyone associated with the claim for no-fault insurance benefits at issue in this case. If the Defendant is contesting that the policy did not provide coverage for the bills at issue, the entire underwriting file including the application for insurance and all renewals. All documents pertaining to or LEYBELYS SARDINAS attendance or non attendance at an Examination Under Oath notice letters, fax confirmations, greed card receipts, proof of mailing, all security logs and sign in sheets for the dates of any Examinations Under Oath. All documents pertaining to or LEYBELYS SARDINAS attendance or non attendance at an Independent Medical Examinations, including but not limited to Independent Medical Examinations notice letters, fax confirmations, greed card receipts, proof of mailing, all security logs and sign in sheets for the dates of any Independent Medical Examinations. Copies of any and all independent medical examinations or peer review reports. Copies of all examinations under oath, recorded statements, written statements, whether transcribed or in recorded form (tapes, discs, electronic media, etc.) regarding the claim at issue. The most recent no-fault payout sheet. All checks issued for payment of any no-fault benefits to any insured, medical provider or other beneficiary under LEYBELYS SARDINAS claim. All letters, explanation of benefits and other correspondence sent explaining decisions to pay, reduce, deny, suspend, terminate or cancel payment of benefits to any medical provider. Copies of all medical records, bills, notices of intent to initiate treatment and any other correspondence received by Defendant from any medical provider in connection with services rendered to LEYBELYS SARDINAS in connection with this claim.19. Copies of all photographs, videotapes, writings, drawings maps, vehicle repair estimates and or other notes that Defendant has in their possession regarding the accident scene, the property damage to any of the automobiles in the subject accident, and the injuries sustained by the patient in this lawsuit. 20. Copies of all prior and subsequent no-fault insurance claim files that Defendant has for the patient alleged in Plaintiff's complaint. 21. Any and all surveillance reports, surveillance films, surveillance photographs, claims history reports or other investigative reports prepared by you or on your behalf with regard to the Plaintiff or the patient involved in the subject accident. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon Defendant by service of process. THE LAW OFFICES OF FELICIA B. BROWN, ESO. RICHARD J. MARKOWITZ, P.A BROWN LAW GROUP, P.A. (CO-COUNSEL) PO BOX 558427 13701 N. KENDALL DRIVE, MIAMI, FLORIDA 33255 SUITE 201 TEL: (305) 667-3244 MIAMI, FLORIDA 33186 FAX: (305) 667-3248 BY: /S/ FELICIA B. BROWN FELICIA B. BROWN, ESQ. FL BAR NO.: 68319