On December 29, 2015 a
Letter,Correspondence
was filed
involving a dispute between
Tower Imaging Inc,
and
Owners Insurance Company,
for SMALL CLAIMS PIP 1 - UNDER $100
in the District Court of Pinellas County.
Preview
Filing # 97967102 E-Filed 10/28/2019 02: 1 5:20 PM
CHANDLER P. IRVIN, ESQ,
C. SPENCER Pm, ESQ
IRVIN
111
ST-
&
SECOND AVE.
PE'I'I'Y,
PETERSBURG:
P.A.
NE SUITE 63o
FL 33701
©
OFFICE: (727) 350-7770
FAX: (727) 350-7771
irvinandpettyxom
October 28th 2019
RE: SETTLEMENT OFFER
Provider Name : Tower Imaging, Inc.
Name 0f Assignor : Lawrence Pollin
Insurance Company : Auto-Owners Insurance Company
Case Number : 15-011058-SC-S
County : Pinellas
Dear Sir 0r Madam,
After conducting a recent review 0f this file Iwanted t0 reach out in hopes 0f resolving matters.
We’re currently seeking the full benefits and interest sought by our client, and our reasonable
fees and costs t0 date in prosecuting this action. Should you wish t0 propose an offer, please d0
so Via email t0 tschofield@irvinandpetty.com by close 0f business, next Friday.
Should you not wish t0 resolve, please note that we have yet t0 depose your client. T0 that end,
please provide your client’s adjuster, person with most knowledge regarding the adjustment and
handling 0f the PIP claim PRIOR t0 the filing 0f the subject lawsuit who actually adjusted the
claim PRIOR t0 the filing 0f the subject lawsuit. In addition, we are requesting the deposition 0f
the person who responded t0 the pre-suit demand letter. Please cooperate in setting the
depositions 0f the requested person(s) t0 occur within the next 90 days.
Please provide my office with dates 0f availability for your client within 20 days from receipt 0f
this letter. If we are not available for any 0f the proposed dates/times, we will reply t0 you with
alternative dates and times. Please provide written response as t0 availability Via fax t0
(727)350-7771 and/or email asalvin0@irvinandpetty.com, so that it may be directed t0 the
assigned paralegal t0 confirm availability and schedule the same.
Thank you in advance for your assistance, I 100k forward t0 your response.
Sincerely,
/s/ C. Spencer Peny
csp@irvinandpetty.com
***ELECTRONICALLY FILED 10/28/2019 02:15:20 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
CHANDLER P. IRVIN, ESQ,
C. SPENCER Pm, ESQ
IRVIN
111
S-r.
&
SECOND AVE.
PETrY,
PETERSBURG, FL 33701
RA.
NE SUITE 63o
©
OFFICE: (727) 3507770
FAX: (727) 350-7771
C. Spencer Petty, Esq. irvinandpetty.com
Document Filed Date
October 28, 2019
Case Filing Date
December 29, 2015
Category
SMALL CLAIMS PIP 1 - UNDER $100
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Preview
Filing # 97967102 E-Filed 10/28/2019 02: 1 5:20 PM CHANDLER P. IRVIN, ESQ, C. SPENCER Pm, ESQ IRVIN 111 ST- & SECOND AVE. PE'I'I'Y, PETERSBURG: P.A. NE SUITE 63o FL 33701 © OFFICE: (727) 350-7770 FAX: (727) 350-7771 irvinandpettyxom October 28th 2019 RE: SETTLEMENT OFFER Provider Name : Tower Imaging, Inc. Name 0f Assignor : Lawrence Pollin Insurance Company : Auto-Owners Insurance Company Case Number : 15-011058-SC-S County : Pinellas Dear Sir 0r Madam, After conducting a recent review 0f this file Iwanted t0 reach out in hopes 0f resolving matters. We’re currently seeking the full benefits and interest sought by our client, and our reasonable fees and costs t0 date in prosecuting this action. Should you wish t0 propose an offer, please d0 so Via email t0 tschofield@irvinandpetty.com by close 0f business, next Friday. Should you not wish t0 resolve, please note that we have yet t0 depose your client. T0 that end, please provide your client’s adjuster, person with most knowledge regarding the adjustment and handling 0f the PIP claim PRIOR t0 the filing 0f the subject lawsuit who actually adjusted the claim PRIOR t0 the filing 0f the subject lawsuit. In addition, we are requesting the deposition 0f the person who responded t0 the pre-suit demand letter. Please cooperate in setting the depositions 0f the requested person(s) t0 occur within the next 90 days. Please provide my office with dates 0f availability for your client within 20 days from receipt 0f this letter. If we are not available for any 0f the proposed dates/times, we will reply t0 you with alternative dates and times. Please provide written response as t0 availability Via fax t0 (727)350-7771 and/or email asalvin0@irvinandpetty.com, so that it may be directed t0 the assigned paralegal t0 confirm availability and schedule the same. Thank you in advance for your assistance, I 100k forward t0 your response. Sincerely, /s/ C. Spencer Peny csp@irvinandpetty.com ***ELECTRONICALLY FILED 10/28/2019 02:15:20 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** CHANDLER P. IRVIN, ESQ, C. SPENCER Pm, ESQ IRVIN 111 S-r. & SECOND AVE. PETrY, PETERSBURG, FL 33701 RA. NE SUITE 63o © OFFICE: (727) 3507770 FAX: (727) 350-7771 C. Spencer Petty, Esq. irvinandpetty.com