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Case Number: 16-011967-SC
Filing # 50393178 E-Filed 12/21/2016 03:42:32 PM
IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
CIVIL DIVISION
Case No.:
ADVANCED CHIROPRACTIC AND REHABILITATION, INC.,
As Assignee of ZACKARY GOLDING,
Plaintiff,
vs.
GEICO GENERAL INSURANCE COMPANY,
Defendant.
/
REQUEST TO PRODUCE
COMES NOW, the Plaintiff, ADVANCED CHIROPRACTIC AND
REHABILITATION, INC., As Assignee of ZACKARY GOLDING, by and through the
undersigned attorney, and pursuant to rule 1.350, Florida Rules of Civil Procedure, hereby
propound to Defendant, GEICO GENERAL INSURANCE COMPANY, produce for inspection,
and/or copying, the following documents, said documents to be produced within forty-five (45)
days from the date of service hereof.
DEFENDANT SHALL PRODUCE THE FOLLOWING ITEMS AND MATTER:
1. All insurance policies that would inure to the benefit of the Plaintiff, 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. The entire Personal Injury Protection and medical payments file maintained by the
Defendant and/or anyone on Defendant’s behalf with regard to Plaintiff, cover to cover,
including original jackets and everything contained within the file, including, but not
limited to:
a. All notations regarding notice of the accident;
b. All telephone messages to or from Defendant and/or from any of Defendant’s
agents on Defendant’s behalf;
c. All accident reports prepared by Defendant and/or any law enforcement agencies,
Plaintiff, or your insured;
d. All interoffice memoranda;
***ELECTRONICALLY FILED 12/21/2016 03:42:31 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***12.
e. All correspondence to and/or from anyone, including any insurance agencies,
doctors’ offices, employers, agencies hired to select doctors for
“compulsory/independent medical examinations” and law enforcement agencies;
f. Any and all Personal Injury Protection and medical payment forms, including
Personal Injury Protection applications, medical report forms, employer
verification forms, authorization forms and any other forms contained in said file;
Any and all records on file concerning the time expended or the costs expended in
the handling of any aspect of Plaintiffs claim; and
h. All computerized memoranda, notes, or other information relating to the claim for
benefits at issue herein.
a9
All internal procedural memos regarding the handling of PIP and medical payments
claims in effect during the last twelve (12) months.
Your latest claims manual on processing PIP and medical payments claims.
Your latest claims manual on processing and handling of auto insurance claims in
general.
A copy of your standards for the proper investigation of claims which were in effect at
any time during the last twelve (12) months.
Copies of any and all leaflets, brochures, memoranda, correspondence, warnings, or
policies disseminated by you or any of your agents, employers and/or representatives in
effect during the last twelve (12) months setting forth procedures, comments,
suggestions, guidelines or criteria for the handling, adjusting, investigating, or settling of
all PIP and medical payments claims.
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
the Insured’s physical and/or mental condition.
All correspondence, forms, notations, memoranda, or information that Defendant
transmitted in any form whatsoever, to any physician’s office or healthcare provider’s
office concerning the Insured’s physical or mental condition.
. Any and all surveillance reports, claims history reports or other investigative reports
claims Defendant and/or anyone acting on Defendant’s behalf prepared with regard to the
Insured.
. Any and all surveillance films, photographs, whether stored on conventional film, or
digitally, of the Plaintiff, its agents, employees, principles, premises, facilities, or
equipment.
An up-to-date Personal Injury Protection and medical payments payout sheet on the
Insured.13. Any and all statements of the Insured and/or of any witnesses.
14. Any and all photographs showing any of the vehicles involved in the accident.
15. Any and all photographs of the scene of the accident.
16. Any and all estimates of repair, or statement, concerning the nature and extent of damage
to any of the vehicles involved in the accident.
17. Any and all writings, memoranda, notes or other materials reflecting Defendant’s
examination of any of the vehicles involved in the accident.
18. Any and all records reflecting the towing of any vehicles involved in the accident from
the scene of the accident.
1 HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the
Defendant along with the Summons and Complaint in this matter.
Reeder & Nussbaum, P.A.
/s Andrew D Reeder
Andrew D. Reeder, Esquire
2201 4th Street North, Suite G
St. Petersburg, FL 33704
727 521-2889
FBN 0388424
Attorney for Plaintiff
attorney@counselorsoflaw.com
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Case Number: 16-011967-SC Filing # 50393178 E-Filed 12/21/2016 03:42:32 PM IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION Case No.: ADVANCED CHIROPRACTIC AND REHABILITATION, INC., As Assignee of ZACKARY GOLDING, Plaintiff, vs. GEICO GENERAL INSURANCE COMPANY, Defendant. / REQUEST TO PRODUCE COMES NOW, the Plaintiff, ADVANCED CHIROPRACTIC AND REHABILITATION, INC., As Assignee of ZACKARY GOLDING, by and through the undersigned attorney, and pursuant to rule 1.350, Florida Rules of Civil Procedure, hereby propound to Defendant, GEICO GENERAL INSURANCE COMPANY, produce for inspection, and/or copying, the following documents, said documents to be produced within forty-five (45) days from the date of service hereof. DEFENDANT SHALL PRODUCE THE FOLLOWING ITEMS AND MATTER: 1. All insurance policies that would inure to the benefit of the Plaintiff, 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. The entire Personal Injury Protection and medical payments file maintained by the Defendant and/or anyone on Defendant’s behalf with regard to Plaintiff, cover to cover, including original jackets and everything contained within the file, including, but not limited to: a. All notations regarding notice of the accident; b. All telephone messages to or from Defendant and/or from any of Defendant’s agents on Defendant’s behalf; c. All accident reports prepared by Defendant and/or any law enforcement agencies, Plaintiff, or your insured; d. All interoffice memoranda; ***ELECTRONICALLY FILED 12/21/2016 03:42:31 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***12. e. All correspondence to and/or from anyone, including any insurance agencies, doctors’ offices, employers, agencies hired to select doctors for “compulsory/independent medical examinations” and law enforcement agencies; f. Any and all Personal Injury Protection and medical payment forms, including Personal Injury Protection applications, medical report forms, employer verification forms, authorization forms and any other forms contained in said file; Any and all records on file concerning the time expended or the costs expended in the handling of any aspect of Plaintiffs claim; and h. All computerized memoranda, notes, or other information relating to the claim for benefits at issue herein. a9 All internal procedural memos regarding the handling of PIP and medical payments claims in effect during the last twelve (12) months. Your latest claims manual on processing PIP and medical payments claims. Your latest claims manual on processing and handling of auto insurance claims in general. A copy of your standards for the proper investigation of claims which were in effect at any time during the last twelve (12) months. Copies of any and all leaflets, brochures, memoranda, correspondence, warnings, or policies disseminated by you or any of your agents, employers and/or representatives in effect during the last twelve (12) months setting forth procedures, comments, suggestions, guidelines or criteria for the handling, adjusting, investigating, or settling of all PIP and medical payments claims. 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 the Insured’s physical and/or mental condition. All correspondence, forms, notations, memoranda, or information that Defendant transmitted in any form whatsoever, to any physician’s office or healthcare provider’s office concerning the Insured’s physical or mental condition. . Any and all surveillance reports, claims history reports or other investigative reports claims Defendant and/or anyone acting on Defendant’s behalf prepared with regard to the Insured. . Any and all surveillance films, photographs, whether stored on conventional film, or digitally, of the Plaintiff, its agents, employees, principles, premises, facilities, or equipment. An up-to-date Personal Injury Protection and medical payments payout sheet on the Insured.13. Any and all statements of the Insured and/or of any witnesses. 14. Any and all photographs showing any of the vehicles involved in the accident. 15. Any and all photographs of the scene of the accident. 16. Any and all estimates of repair, or statement, concerning the nature and extent of damage to any of the vehicles involved in the accident. 17. Any and all writings, memoranda, notes or other materials reflecting Defendant’s examination of any of the vehicles involved in the accident. 18. Any and all records reflecting the towing of any vehicles involved in the accident from the scene of the accident. 1 HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the Defendant along with the Summons and Complaint in this matter. Reeder & Nussbaum, P.A. /s Andrew D Reeder Andrew D. Reeder, Esquire 2201 4th Street North, Suite G St. Petersburg, FL 33704 727 521-2889 FBN 0388424 Attorney for Plaintiff attorney@counselorsoflaw.com