22 Fla. L. Weekly Supp. 728b
Online Reference: FLWSUPP 2206MOBLInsurance — Personal injury protection — Discovery — Depositions — Corporate representative of insurer — Scope of inquiry
HEALTH DIAGNOSTICS OF ORLANDO, LLC DBA STAND-UP MRI OF ORLANDO, as assignee of Sherikey Mobley, Plaintiff, v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. County Court, 9th Judicial Circuit in and for Orange County. Case No. 2013-SC-10095-O. November 13, 2014. Faye L. Allen, Judge. Counsel: William England, Bradford Cederberg, P.A., Orlando, for Plaintiff. Alexis L. Lombard, Winter Park, for Defendant.
ORDER
THIS MATTER having come before this Honorable Court on Plaintiff’s Motion to Compel the Deposition of Defendant’s Corporate Representative on November 10, 2014 and this Honorable Court having heard arguments of counsel and being otherwise fully advised in the premises, it is hereby,
ORDERED AND ADJUDGED that:
1. Plaintiff’s Motion to Compel the Deposition of Defendant’s Corporate Representative pursuant to Fla. R. Civ. P. 1.310(b)(6) is GRANTED. State Farm shall produce its Corporate Representative for deposition, pursuant to Florida Rule of Civil Procedure 1.310(b)(6), the scope of the deposition is limited to the areas of inquiry specified in Exhibit “A.”
__________________Exhibit A
1. State Farm’s precise methodology to determine an allowable and appropriate amount/charge for Plaintiff’s services at issue in this matter, including supporting basis such as facts and evidence.
2. Any and all Affirmative Defenses raised (or reserved) by Defendant in this matter, including any facts or evidence supporting the affirmative defenses.
3. Explanation(s) of Review for the assignor’s claim at issue in this matter, including basis of reason codes.
4. The handling of receipt of bills and responses within the assignor’s claim at issue in this matter.
5. Receipt of any and all pre-suit demand and responses generated by Defendant regarding the assignor’s claim at issue in this matter.
6. Payment of the CPT code at issue in this matter.
7. Applicable policy of insurance to the assignor’s claim at issue in this matter inclusive of endorsements.
8. Any and all instances where State Farm informed the insured/assignor that it would limit reimbursement for MRI services to 200% of Medicare Part B.
9. The processing of Plaintiff’s bill at issue in this matter.
10. Authentication and inquiry regarding any of the documents listed in the duces tecum included herein.
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