TRI-COUNTY DIAGNOSTIC & IMAGING CENTERS LLC Plaintiff vs. State Farm Mutual Automobile Insurance Company Defendant, CONO17002237, 08-03-2017_Interrogatories & Notice of Filing (Fla. Broward Cty. Ct. A (2024)

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`INTERROGATORIES TO DEFENDANT
`STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
`
`"You(r)" as used in these interrogatories means your corporation, company or
`(Definitions:
`partnership, or anyone who handles, adjusts or investigates claims on its behalf.)
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`’1.
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`State your complete corporate name, nature of your business, whether you are licensed to do
`business in the State of Florida, whether you maintain agents for the transacting of your
`customary business in BROWARD, and whether Ismael Bazelais is an "Insured" as defined
`by your policy at any point in time, the nature of the insurance, the place of issue of the
`policies and the policy period.
`
`For the person answering and the person initially generating the response to these
`interrogatories on behalf of the Defendant, please state your name, address and relationship
`and/or employment position with the Defendant.
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`List the names, addresses and telephone numbers of all persons (other than medical
`witnesses, your agents, representatives or employees) believed or known by you, your
`agents or attorneys to have any knowledge concerning any of the issues raised by the
`pleadings, specifying the subject matter about which the witnesses have knowledge and
`state whether you have obtained any statements (oral, written and/or recorded) from any of
`said witnesses, list the dates any such witness statements were taken, by whom any such
`witness statements were taken and who has present possession, custody and control of any
`such statements.
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`Names
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`Addresses
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`Telephone #3
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`Statement
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`For each medical bill received by you from the Plaintiff for which you are denying payment
`state: the date of the bill, the date(s) of service for which the bill was incurred, the date you
`first received the bill, the dollar amount for the bill received, the date your first acted to
`determine whether or not the bill reflected reasonable, necessary and related charges, the
`date you first decided that it was not reasonable, necessary or related, and the exact reason
`that you believed the bill was not either reasonable or necessary or related.
`
`
`Bill
`Date Bill Date Service Received Date Act Date Decide Reason
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`5.
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`Please state the name, address and telephone number of the pre-litigation adjuster, litigation
`adjuster, pre-litigation adjuster supervisor and the litigation adjuster supervisor or persons
`the adjusters would go to if they had a question about the handling of this claim.
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`For each medical bill received by you from the Plaintiff for which you are reducing the amount
`of the bill as opposed to denying it based on whether it is reasonable, necessary or related in
`any other sense, please state: the date of the bill, the date of service for which the bill was
`incurred, the date you first received the bill, the dollar amount for the bill received, the date
`your first acted to determine whether or not the bill was in the correct amount, the date you
`first decided that it was not in the correct amount,
`the correct amount that you calculated,
`the date when you calculated the correct amount, and the exact method by which you
`calculated the correct amount, and the date you first informed Plaintiff of the correct amount.
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`Bill
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`Date Bill Date Service $Amount Received Date Act
`
`Date Decide $ Correct Amount Date Calculated Method Date Inform
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`List the names, addresses and official positions of each and every person in your employ or
`in the employment of anyone on your behalf who has had any involvement whatsoever in the
`review of the bills involved herein for the determination that the bills were not reasonable,
`necessary or related or who has any involvement in the determination ofthe correct amount,
`state in what capacity each person was involved, the dates when they were involved and the
`exact nature of their involvement.
`
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`Names
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`Addresses
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`Telephone #3
`
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`Dates
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`Did Defendant utilize a third-party company or vendor in calculating the reimbursable
`amounts for the medical services billed by Plaintiff.
`If yes, provide the name and address of
`the company. State, in detail, the company’s involvement in processing the medical bills
`Plaintiff submitted to Defendant and whether or not this medical review company is an agent
`of yours charged with the responsibility to determine whether bills are paid, reduced, or
`denied in accordance with Defendant’s contract of insurance.
`
`Please state if you, your agents, or employees have ever provided the patient or the named
`insured with a copy of the policy of insurance.
`If so, provide the name and address of the
`person that provided the policy, on what date, and in what manner.
`
`

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`’10.
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`’ll.
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`12.
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`13.
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`’14.
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`15.
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`16.
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`’17.
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`Please state all methods utilized by Defendant to determine whether the Plaintiff’s treatment
`and bills for treatment were reasonable, medically necessary, or related to the accident.
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`Please state the first date that Defendant was notified or learned of any proof of loss
`involving the patient, the name and address of who received the proof of loss, and the date,
`if you have required it, that you requested written notice be given to you of said loss.
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`If Defendant asserts that there is no coverage for this loss, please provide specific details as
`to why there is no coverage under the policy of insurance issued by Defendant.
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`State in detail all facts to support Defendant’s Affirmative Defenses.
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`Please state the first date, and any subsequent dates, you received any written notice of a
`covered loss, No-Fault Application, and/or medical bills pursuant to such claim ofthe patient,
`and identify the date received.
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`Please state all medical benefits that have been paid to the present date by Defendant
`pursuant to the policy of insurance.
`
`Please state all basis in law or fact upon which you are denying or reducing Plaintiff’s claim
`against your company for the payment of PIP Benefits or Medical Payment Benefits.
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`With respect to this claim, please list each Doctor hired by Defendant, or doctors hired by
`third-party vendors used by the Defendant, to conduct an IME or issue a report and indicate
`the amount of money paid to such doctor for his involvement in the instant action.
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`

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`SIGNATURE PAGE TO INITIAL INTERROGATORIES
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`
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`Representative of STATE FARM MUTUAL
`AUTOMOBILE INSURANCE COMPANY
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`STATE OF FLORIDA
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`COUNTY OF
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`§
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`The foregoing instrument was acknowledged before me on this
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`day of
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`, 2017, by
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`
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`who is personally known to me or has
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`produced
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`as identification and who (did/did not) take an oath.
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`
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`Commission No.:
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`Notary Public
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