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Filing # 139278373 E-Filed 11/29/2021 04:02:39 PM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO. 50-2020-CA-007463-XX
ROODY ST. GERMAIN,
Plaintiff,
vs.
ROADRUNNER SERVICES, LLC and
MANHEIM REMARKETING, INC.,
Defendants.
NOTICE OF LIEN FOR PAYMENT OF COMPENSATION
AND MEDICAL BENEFITS
Comes now, Employers Insurance of Wausau, a Liberty Mutual Insurance Group company
(“Liberty Mutual”), by and through its undersigned counsel, and as the Workers’ Compensation
cartier for Alliance Inspection Management, employer at the time of the subject August 26, 2018
accident and injury to the Plaintiff, Roody St. Germain, and hereby gives notice pursuant to Section
440.39 of the Florida Statutes to all parties to the above styled action, including their insurance
carriers, that the Plaintiff, Roody St. Germain, while in the course and scope of his employment, was
injured at the time and place alleged in the Complaint filed in this cause. Liberty Mutual has, to date,
paid workers compensation benefits, to or on behalf of Roody St. Germain, in the total sum of
$127,291.10, which includes indemnity in the amount of $62,890.93 and medical benefits in the
amount of $64,400.17, to date, as a result of his compensable accident. (See attached Exhibit A)
WHEREFORE, Liberty Mutual, serves this as its Notice and Lien pursuant to Florida
Statute 440.39, Florida Statutes.
This _29th__ day of November, 2021.
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/29/2021 04:02:39 PM ***CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been e-
served in accordance with the Florida Rule of Judicial Administration 2.516, on this _29th__ day of
November, 2021, to:
Attorney for Plaintiff:
Gregory M. Cummings, Esq.
Schuler, Halvorson, Weisser, Zoeller, Overbeck & Baxter, P.A.
1615 Forum Place, Suite 4D
West Palm Beach, FL 33401
Primary E-Mail: gcummings@shw-law.com
Secondary E-Mail: jdaza@shw-law.com
Defendant, Manheim Remarketing, Inc.:
Steven R. Main, Esq.
Hill, Rugh, Keller & Main, P.L.
390 N. Orange Avenue, Suite 1610
P. O. Box 2311
Orlando, FL 32802-2311
Primary E-Mail: smain@hrkmlaw.com
Secondary E-Mail: filings@hrkmlaw.com
Defendant, Roadrunner Services, LLC:
Jessica R. King, Esq.
Law Office of Ignacio M. Sarmiento
P. O. Box 7217
London, KY 40742
Primary E-Mail: bocalegalmail@libertymutual.com
Secondary E-Mail: Jessica.king@libertymutual.com
Law Offices of J. Christopher Norris
J. Christopher Norris, Esquire
P.O. Box 7217
London, KY 40742
(407) 563-3400
Attorney for Employers Insurance of Wausau,
a Liberty Mutual Insurance Group company
S/J. Christopher Norris
J. Christopher Norris, FBN# 980651
Primary E-Mail (eservice only): OrlandoLegalMail@LibertyMutual.com
Secondary E-Mail: james.nortis@libertymutual.comST. GERMAIN v. ROADRUNNER SERVICES, LLC,
ET AL.
CASE NO: 50-2020-CA-007463-xx
EXHIBIT A
Claim Cost Summary
Processed thru:
11/12/2021
Claim Number: 550-C07610
SERVICE TOTAL COLLECTED
TYPE TOTALPAID TOTALREFUND NET TOTAL DEDUCTIBLE AMOUNT
I 62890.93 .00 62890.93 .00
M 64400.17 .00 64400.17 .00
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Filing # 139278373 E-Filed 11/29/2021 04:02:39 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50-2020-CA-007463-XX ROODY ST. GERMAIN, Plaintiff, vs. ROADRUNNER SERVICES, LLC and MANHEIM REMARKETING, INC., Defendants. NOTICE OF LIEN FOR PAYMENT OF COMPENSATION AND MEDICAL BENEFITS Comes now, Employers Insurance of Wausau, a Liberty Mutual Insurance Group company (“Liberty Mutual”), by and through its undersigned counsel, and as the Workers’ Compensation cartier for Alliance Inspection Management, employer at the time of the subject August 26, 2018 accident and injury to the Plaintiff, Roody St. Germain, and hereby gives notice pursuant to Section 440.39 of the Florida Statutes to all parties to the above styled action, including their insurance carriers, that the Plaintiff, Roody St. Germain, while in the course and scope of his employment, was injured at the time and place alleged in the Complaint filed in this cause. Liberty Mutual has, to date, paid workers compensation benefits, to or on behalf of Roody St. Germain, in the total sum of $127,291.10, which includes indemnity in the amount of $62,890.93 and medical benefits in the amount of $64,400.17, to date, as a result of his compensable accident. (See attached Exhibit A) WHEREFORE, Liberty Mutual, serves this as its Notice and Lien pursuant to Florida Statute 440.39, Florida Statutes. This _29th__ day of November, 2021. *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/29/2021 04:02:39 PM ***CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been e- served in accordance with the Florida Rule of Judicial Administration 2.516, on this _29th__ day of November, 2021, to: Attorney for Plaintiff: Gregory M. Cummings, Esq. Schuler, Halvorson, Weisser, Zoeller, Overbeck & Baxter, P.A. 1615 Forum Place, Suite 4D West Palm Beach, FL 33401 Primary E-Mail: gcummings@shw-law.com Secondary E-Mail: jdaza@shw-law.com Defendant, Manheim Remarketing, Inc.: Steven R. Main, Esq. Hill, Rugh, Keller & Main, P.L. 390 N. Orange Avenue, Suite 1610 P. O. Box 2311 Orlando, FL 32802-2311 Primary E-Mail: smain@hrkmlaw.com Secondary E-Mail: filings@hrkmlaw.com Defendant, Roadrunner Services, LLC: Jessica R. King, Esq. Law Office of Ignacio M. Sarmiento P. O. Box 7217 London, KY 40742 Primary E-Mail: bocalegalmail@libertymutual.com Secondary E-Mail: Jessica.king@libertymutual.com Law Offices of J. Christopher Norris J. Christopher Norris, Esquire P.O. Box 7217 London, KY 40742 (407) 563-3400 Attorney for Employers Insurance of Wausau, a Liberty Mutual Insurance Group company S/J. Christopher Norris J. Christopher Norris, FBN# 980651 Primary E-Mail (eservice only): OrlandoLegalMail@LibertyMutual.com Secondary E-Mail: james.nortis@libertymutual.comST. GERMAIN v. ROADRUNNER SERVICES, LLC, ET AL. CASE NO: 50-2020-CA-007463-xx EXHIBIT A Claim Cost Summary Processed thru: 11/12/2021 Claim Number: 550-C07610 SERVICE TOTAL COLLECTED TYPE TOTALPAID TOTALREFUND NET TOTAL DEDUCTIBLE AMOUNT I 62890.93 .00 62890.93 .00 M 64400.17 .00 64400.17 .00