23 Fla. L. Weekly Supp. 973a
Online Reference: FLWSUPP 2309COLLInsurance — Personal injury protection — Discovery — Failure to comply — Sanctions — Where insurer has deliberately failed to comply with multiple orders requiring production of geozip information, and failure has prejudiced medical provider in its attempts to obtain discoverable evidence and prosecute action, provider’s charge is deemed reasonable
HEALTH DIAGNOSTICS OF FORT LAUDERDALE, LLC, d/b/a STAND-UP MRI OF FORT LAUDERDALE, a/a/o Stacy Collazo, Plaintiff, vs. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. County Court, 17th Judicial Circuit in and for Broward County. Case No. CONO13-008530(70). February 11, 2016. Honorable John D. Fry, Judge. Counsel: Andrew J. Weinstein, Weinstein Law Firm, Coral Springs, for Plaintiff. Kathyrn M. Winkler, Kirwan, Spellacy & Danner, Fort Lauderdale, for Defendant.
ORDER ON PLAINTIFF’S MOTION TO STRIKEDEFENDANT’S PLEADINGS AND FOR SANCTIONS
THIS CAUSE having come to be considered on January 06, 2016 on Plaintiff’s motion to strike Defendant’s pleadings and for sanctions, and the Court having heard argument from counsel, having reviewed the Court file, and being otherwise advised in the Premises, it is hereupon ORDERED AND ADJUDGED as follows:
FINDINGS OF FACT
1. This lawsuit arises out of a claim for unpaid personal injury protection benefits filed by the Plaintiff.
2. On October 21, 2015, Plaintiff propounded discovery titled “Plaintiff’s Second Request to Produce to Defendant” seeking the following information:
9. A copy of the “geozip” showing amounts charged by other MRI providers (including hospitals), equal to or higher than Plaintiff’s charge, in the County where the services were rendered for the same CPT code at issue in this case. This request for production may be limited to a 90-day period before and a 90-day period after the dates of service at issue in this lawsuit.”
3. Paragraph 3 of the Court’s Order on Case Management and Imposing Time Limitations states, in pertinent part, as follows:
If any party objects to the discovery request served upon them in whole or in any part they must file with the court and serve upon opposing counsel their objections within 20 days of the date of their receipt of the said discovery request along with a Notice of Hearing for the said matter. . . . Objections not heard by the court within the proscribed [time period] may be deemed waived.
4. The deadline to serve objections was November 10, 2015. Defendant failed to comply.
5. On November 18, 2015, Defendant filed the following untimely objection to Plaintiff’s second request for production:
State Farm objects to the request as it is vague and ambiguous as to the term “usual and customary charges” and/or “GeoZip” and overly broad in scope and time. Further, the request seeks irrelevant information, is not reasonably calculated to lead to admissible evidence, and has no nexus to the claims or events at issue in this litigation. Each claim is handled on its own individual merits. As State Farm can understand this request, it appears to be seeking confidential and proprietary business information belonging to State Farm and invades the competitive proprietary information or third party providers who are not parties to this litigation. Due to the overly broad and vague nature of this request, it might also implicate confidential, proprietary and trade secret information of a third party not a party to this litigation. Further, State Farm does not have an existing report or document with this information as requested and a party cannot be compelled to produce documents that do not exist. Allstate Ins. Co. v. Pinder, 746 So. 2d 1255 (Fla. 5th DCA 1999) [25 Fla. L. Weekly D136a].
Finally, this is premature bad faith discovery and an improper request for claim handling information. “Until the obligation to provide coverage and damages has been determined, a party is not entitled to discovery related to the claims file or to the insurer’s business policies or practices regarding handling of claims.” State Farm Mut. Auto. Ins. Co. v. Tranchese, 49 So. 3d 809, 810 (Fla. 4th DCA 2010) [35 Fla. L. Weekly D2590a]. See also, State Farm Florida Ins. Co. v. Desai, 106 So. 3d 5, 38 (Fla. 3d DCA 2013) [38 Fla. L. Weekly D85b] and State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389, 390 (Fla. 2d DCA 2003) [28 Fla. L. Weekly D330a].
6. Despite the fact that this Court, at a minimum of over 60 times, and numerous other Courts in Broward County and throughout the State have now overruled Defendant’s objections and have entered an order requiring the Defendant to produce the requested information, Defendant still raises objections, which this Court has found to be frivolous and meritless, rather than producing the documents.
7. The Court is also mindful of the fact that Defendant has also taken completely contrary positions with respect to the GeoZip information in its various discovery responses involving cases in this County.
a. By way of example, in State Farm’s July 16, 2015 objection to the GeoZip information request in the case of Health Diagnostics of Miami, LLC (a/a/o Sophia Santiago) v. State Farm,1 Defendant objected on the grounds that the information was “. . . trade secret, proprietary information belonging to third party, Mitchell Medical and confidential. Additionally, State Farm does not possess or is not aware of any outside vendor or entity that possesses or can produce a “GeoZip” report. State Farm does not know what this report is as this appears to be a term coined by Plaintiffs counsel. . . .” (Emphasis added).
b. In its September 24, 2015 objection to the GeoZip information request in the same exact case listed in the preceding paragraph, Defendant objected on the grounds that the information was “. . . confidential and proprietary business information belonging to State Farm and invades the competitive proprietary information of third party providers who are not parties to this litigation . . .” (Emphasis added).
c. After taking both of these completely inconsistent positions, State Farm ultimately produced the information on November 05, 2015.
d. In fact, State Farm has actually produced this information no less than 16 different times (of which the Court is aware) in the following cases:
i. Health Diagnostics of Fort Lauderdale, LLC (a/a/o Della Hope) v. State Farm, CONO1300997(70) [23 Fla. L. Weekly Supp. 188d] — produced 7/16/15.
ii. Health Diagnostics of Fort Lauderdale, LLC (a/a/o Adelphonce Origuet) v. State Farm, CONO13009968(70) [23 Fla. L. Weekly Supp. 181d] — produced 7/16/15.
iii. Health Diagnostics of Fort Lauderdale, LLC (a/a/o Sonia Morency) v. State Farm, CONO13009971(70) [23 Fla. L. Weekly Supp. 181b] — produced 7/16/15.
iv. Health Diagnostics of Fort Lauderdale, LLC (a/a/o Martin Leiter) v. State Farm, CONO139972(70) — produced 10/29/15.
v. Health Diagnostics of Fort Lauderdale, LLC (a/a/o Daniel Wasserman) v. State Farm, CONO1210893(70) — produced 10/29/15.
vi. Health Diagnostics of Miami, LLC (a/a/o David Kogan) v. State Farm, CONO13007858(70) — produced 10/29/15.
vii. Health Diagnostics of Miami, LLC (a/a/o Celina Rodriguez) v. State Farm, CONO139951(70) [23 Fla. L. Weekly Supp. 615a] — produced 10/29/15.
viii. Health Diagnostics of Miami, LLC (a/a/o Sophia Santiago) v. State Farm, CONO139952(70) — produced 11/11/15.
ix. Health Diagnostics of Fort Lauderdale, LLC (a/a/o Arthulia Wright) v. State Farm, CONO12009378(70) — produced 11/9/15.
x. Health Diagnostics of Orlando, LLC (a/a/o Alejandra Delgado) v. State Farm, CONO12009394(70) — produced on or about 11/3/15.
xi. Health Diagnostics of Fort Lauderdale, LLC (a/a/o Sasha Shaw) v. State Farm, CONO12009428(70) — produced 11/24/15.
xii. Health Diagnostics of Fort Lauderdale, LLC (a/a/o Nana Iosava) v. State Farm, CONO12010903(70) — produced 11/25/15.
xiii. Health Diagnostics of Orlando, LLC (a/a/o Gloria Castano) v. State Farm, CONO14012103(70) — produced 12/7/15.
xiv. Health Diagnostics of Orlando, LLC (a/a/o Grace Torres) v. State Farm, CONO12009355(70) — produced 11/5/15.
xv. Open MRI of Boca, LLC (a/a/o Lola Irvine) v. State Farm, CONO12009432(70) — produced 11/25/15.
xvi. Open MRI of Boca, LLC (a/a/o Joseph Magenie) v. State Farm, CONO12009380(70) — produced 11/25/15.
e. In Health Diagnostics of Orlando, LLC (a/a/o Alejandra Delgado) v. State Farm, CONO12009394(70) [23 Fla. L. Weekly Supp. 628a], this Court sua sponte compelled a corporate representative of State Farm to appear for a hearing to explain State Farm’s repeated noncompliance with the Court’s orders. In attempting to ascertain for the record exactly what Mitchell Medical’s role is in the compiling of the Geozip, the Court questioned State Farm’s corporate representative witness, Dean Rogers, asking him the following:
THE COURT: But you would agree with me that the data that Mitchell Medical gets is from State Farm? In other words, the claim comes in, State Farm processes the claim, which includes the amount that’s billed and forwards it to Mitchell Medical, which apparently compiles this Geo-zip form. So State Farm has access to this information; would you agree with that?
MR. ROGERS: Well you’re going a bit beyond my scope, Your Honor, with regards to my knowledge but it’s — the information that is contained on that report, a lot of that information we do not have access to. It’s not ours. So our columns that are completely not ours, obviously, when the bill comes into State Farm we are aware of the charges on the bill and things like that, so those components of the report obviously —
THE COURT: Doesn’t State Farm pay the bill, or does Mitchell pay the bill?
MR. ROGERS: No, State Farm pays the bill.
THE COURT: Ok. So, State Farm would have in its possession how much was billed and how much was paid on all State Farm’s claims?
MR. ROGERS: Yes, we should. Yes.
THE COURT: Ok. And who the provider was because that’s who you’ve got to write the check to?
MR. ROGERS: Correct.
THE COURT: Which appears to be, unless I’m wrong, Mr. Weinstein, the crux of the Geozip report.
MR. WEINSTEIN
[Plaintiff’s counsel: Essentially, yes, Judge.
THE COURT: There’s ancillary information. I have reviewed Geozip as a mechanism to assist State Farm as well as the plaintiff’s firms. I haven’t said that before, or I think I may have said it once or twice, not at an open hearing.
The plaintiff has a right to the information I found, and I believe all the judges in the circuit have found at some point, the right to this information. The easiest least burdensome mechanism to make what happened [sic] is for a Geozip report to be created versus y’all searching your entire database to come up with the information. Do you understand what I’m saying? (pp. 11-13).
i. On September 25, 2015, Plaintiff, in this same case, took the deposition of Mr. Yacorps sitting as State Farm’s 1.310(b)(6) corporate designee. Plaintiff’s counsel plainly asked the witness about why State Farm violated the Court’s order. As he testified under oath:
When the order was actually sent to me I requested the report as according to the court order. Unfortunately, there are thousands upon thousands from different attorneys, different plaintiffs’ attorneys, such as yourself, who are requesting Geozip requests. Unfortunately, it takes time. At this time, we’re not saying we’re not producing it, it’s taking the time. There’s an abundant — I mean, a vast amount of requests, so that’s why the delay. (Deposition Transcript of Steve Yacorps, 9/25/15)
ii. When plaintiffs’ counsel pressed Mr. Yacorps regarding State Farm’s defiance of this Court’s Order to produce the Geozips within 30 days, his answer was “It just takes time” (Deposition Transcript of Steve Yacorps, 9/25/15, p. 9). As he continued, “There are thousands — I mean, hundreds of these requests out there at this particular time.” Id.
iii. A bit later, Mr. Yacorps was asked whether he had ever been ordered to produce Geozip information before, to which he testified that yes, he had (Deposition Transcript of Steve Yacorps, 9/25/15, p. 14). Mr. Yacorps noted that he has produced Geozip information either less or more than ten times, but he could testify that he has gotten “at least five requests per week on average. . .” (Deposition Transcript of Steve Yacorps, 9/25/15, p. 14).
f. On July 17, 2013, Miriam Encarnacion, a corporate representative of Mitchell Medical, was deposed in a different case. Ms. Encarnacion testified explicitly that she had the knowledge to respond on behalf of Mitchell Medical regarding these important issues (Deposition of Miriam Encarnacion, 7/17/13, p. 8). When asked about a specific Geozip document that had been attached to the subpoena duces tecum, the provider’s counsel asked:
Q. [By the provider’s counsel]: Ok. And can you tell me what was required from a technical standpoint? How difficult was it for Mitchell to prepare a report that provided this information in this format?
A. [By Ms. Encarnacion]: Well, the request came in from State Farm, and they provide the criteria as to the date that needs to be extracted in the content of the report that needs to be sent back with that request. So as far as difficulty in extracting this data, I would say they probably took probably no more than two hours (Deposition of Miriam Encarnacion, 7/17/13, pp. 10-11).
i. The transcript itself is replete with questions and answers showing that Ms. Encarnacion agrees that every relevant piece of data on the Mitchell Medical report was supplied to it by State Farm (Deposition of Miriam Encarnacion, 7/17/13, pp. 14; 16-17; 19).
Q. Ma’am, in the charged amount column, those pieces of information, those dollar amounts, under what circumstances were the dollar amounts contained under the charged amount, be different from the amounts that were on the CMS-1500 form that was provided by the medical provider to State Farm?
A. I — I wouldn’t know that answer. I don’t know that answer.
Q. It should not be; right? Because all Mitchell was doing was taking the electronic information from State Farm and putting it into that report.
A. Yes.
Q. I mean, is that right?
A. That’s correct.
Q. Ok. So for whatever reason there was some type of difference, that was nothing more than an error; is that right?
A. I would believe so, yes.
Q. And that would be true of the information contained in the provider group column; is that right?
A. Correct.
Q. And the procedure code column?
A. Correct.
Q. And the date of service column?
A. Correct.
Q. Ok. The information that’s contained on this particular report, is there any limitation to what type of parameters that Mitchell can have a report created for? And what I’m asking you is, do you have the — do you have the ability to pull a report solely by CPT code and geographic area?
A. Yes.
Q. And you would have the ability to limit a report to certain time frames, like a six-month time frame?
A. Again, that would be up to what the customer is requesting.
(Deposition of Miriam Encarnacion, 7/17/13, pp. 22-23).
* * *
Q. And is Mitchell providing State Farm with any type of recommendations regarding what a reasonable reimbursement rate would be for a particular CPT code in Florida?
A. No, we do not.
Q. So that is not a service that Mitchell provides to State Farm; is that correct?
A. That’s correct.
Q. And does Mitchell simply follow the instructions or, I guess, the — or comply with the contractual obligation between it and State Farm and providing State Farm with this automated service?
A. That’s correct.
Q. And it’s State Farm who has decided what the reimbursement calculation will be for Florida no-fault claims.
A. That’s correct.
(Deposition of Miriam Encarnacion, 7/17/13, p. 28).
g. In Health Diagnostics of Orlando, LLC (a/a/o Vanessa Flowers) v. State Farm, CONO12009387(70), State Farm filed an affidavit of Jane Dominguez dated June 12, 2015. Ms. Dominguez testified under oath, in pertinent part, as follows:
There is no available software mechanism by which State Farm can generate a document, disclosure, chart, matrix or other survey containing reimbursement amount rates per CPT code within a certain geographical area and/or time frame . . .
There is simply no means via a computer/software program to generate an accurate disclosure as requested by the Plaintiff.
The only possible mechanism to gather this information would be to employ a staff of personnel to individually review every single claim that potentially contains one or more of the services at issue.
h. In Orthopaedic Center of South Florida, P.A. (a/a/o Alan Annichiarico) v. State Farm, COCE14004827(52), State Farm filed an affidavit of Donald Vinciguerra dated November 10, 2015. Mr. Vinciguerra testified under oath, in pertinent part, as follows:
My name is Donald Vinciguerra. I am an Analyst in Claims Analytics at State Farm Mutual Automobile Insurance Company (“State Farm”). I have been an Analyst in Claims Analytics for the past 7 years and have been employed by State Farm for the last 27 years. Claims Analytics designs search protocols to retrieve data concerning claims that are stored in State Farm’s databases of electronically stored claims information. . .
State Farm electronically stores claim-related information in the “Enterprise Claim System (ECS).” The ECS is a very complex relational database containing a variety of claim information regarding claims made by State Farm policyholders. The system organizes and stores data in certain “fields;” these fields have been chosen and are maintained for business-related reasons. The Enterprise Claim System is electronically searchable by fields recognized by the system. The fields include, among others, CPT code, reason code, date of service and zip code.
State Farm does not maintain the information implicated by the above referenced discovery requests in a prepared or existing report, but must create a new report from electronically stored claim-related information in the ECS. This is a live system used in the regular course of business to handle claims for State Farm. To create this report, the parameters were defined pursuant to the Court Order. Next, a systems programmer wrote the code to request the data, which was approved, and additional code was written to run against the data once it was accumulated. Then the data was pulled. Finally, the report was validated.
i. In Health Diagnostics of Miami, LLC (a/a/o Celina Rodriguez) v. State Farm, CONO13009951(70), State Farm an filed an “Emergency Motion to Extend the Court Order Requiring State Farm to Produce “GeoZip” Report, Decision Point Report, or its Equivalent on or before November 10, 2015 at 5:00 p.m.”2 In its motion, Defendant makes it clear that “the Defendant fully intends to comply with the Order” and “the Defendant can comply with this Order within the next ten (10) business days.”
i. In support of this motion, State Farm filed the affidavit of Donald Vinciguerra dated November 10, 2015. Mr. Vinciguerra testified under oath, in pertinent part, as follows:
My name is Donald Vinciguerra. I am an Analyst in Claims Analytics at State Farm Mutual Automobile Insurance Company (“State Farm”). I have been an Analyst in Claims Analytics for the past 9 years and have been employed by State Farm for the last 29 years. Claims Analytics designs search protocols to retrieve data concerning claims that are stored in State Farm’s databases of electronically stored claims information. . .
State Farm electronically stores claim-related information in the “Enterprise Claim System (ECS).” The ECS is a very complex relational database containing a variety of claim information regarding claims made by State Farm policyholders.
State Farm does not maintain the information implicated by the above referenced discovery requests in a prepared or existing report, but must create a new report from electronically stored claim-related information in the ECS. This is a live system used in the regular course of business to handle claims for State Farm.
To create this report, we must receive the required information from business areas to define the report parameters. Then we must fully define those parameters. Then a systems programmer must write the code to request the data, that code must be approved, and more code has to be written which will run against the data once it is accumulated. Then the data must be pulled, and the report validated.
Those requests typically take between 5 to 10 business days to run after all the steps identified in paragraph number 5 above.
8. As a direct result of State Farm’s frivolous position with regard to the production of this relevant and discoverable information, this Court has had to cancel multiple hearings on Plaintiff’s motion for final summary judgment or summary disposition, and has wasted countless hours entertaining Defendant’s same objections raised in every single case, which this Court has overruled every single time.ANALYSIS AND CONCLUSIONS OF LAW
1. The production of geozips and there use in PIP litigation is not a novel concept for this Court or the litigants and has been utilized for years. In fact, the Court was able to locate a case that dates back to 2006 where geozip information was required to be produced. Additionally, this Court has held countless hearings regarding the production of geozips, this Court has reviewed geozips previously produced by State Farm, this Court has reviewed other Courts’ orders requiring the production of geozips, and this Court has ordered State Farm to produce geozips in other cases at least 250 times. To date, this Court is unaware of any appellate court finding that this Court’s ruling or the various rulings from other Courts were improper.
2. The Court begins its analysis by looking at Rule 1.380(a)(3) of the Florida Rules of Civil Procedure, which provides as follows:
For purposes of this subdivision an evasive or incomplete answer shall be treated as a failure to answer.
3. Rule 1.380(d) of the Florida Rules of Civil Procedure provides, in pertinent part, as follows:
If a party . . . fails . . . (3) to serve a written response to a request for inspection submitted under rule 1.350 after proper service of the request, the court in which the action is pending may take any action authorized under paragraphs (A), (B), and (C) of subdivision (b)(2) of this rule. . . .
4. Rule 1.380(b)(2) of the Florida Rules of Civil Procedure provides, in pertinent part, as follows:
If a party or an officer, director, or managing agent of a party or a person designated under rule 1.310(b)(6) or 1.320(a) to testify on behalf of a party fails to obey an order to provide or permit discovery, including an order made under subdivision (a) of this rule or rule 1.360, the court in which the action is pending may make any of the following orders:
(A) An order that the matters regarding which the questions were asked or any other designated facts shall be taken to be established for the purposes of the action in accordance with the claim of the party obtaining the order.
(B) An order refusing to allow the disobedient party to support or oppose designated claims or defenses, or prohibiting that party from introducing designated matters in evidence.
(C) An order striking out pleadings or parts of them or staying further proceedings until the order is obeyed, or dismissing the action or proceeding or any part of it, or rendering a judgment by default against the disobedient party.
5. The judiciary in Broward County has made it abundantly clear that GeoZip information is both relevant and discoverable. In fact, in a recent hearing involving State Farm this Court made very specific findings regarding GeoZip information:
Geozip is a compilation prepared by Mitchell Medical as it pertains to their client, partner, whatever term we would use. I have ordered Geozips since I first heard the term, I want to say at some point in 2013, because it’s the crux of the case, to some extent. It’s rebuttal, but it does give us kind of a map on the standard within the community.
I feel confident that I had ordered this between three to five-hundred times. I feel very confident that Judge DeLuca, ultra-conservative, has ordered it over one-hundred times (p. 5).
* * *
Judge Kanner and I had the discussion on Geozip, because I think it was the day after you all came in or maybe even that day and I said, you ordered Geozip. He said yeah, all the time. Judge Schiff orders Geozip. Judge — every judge I know orders Geozip. I can’t say for how long, but they order them.
I have had handed to me Geozips. I have had discussions with attorneys who represent State Farm, because there was a period of time where the defense was, Your Honor, this is a monumental undertaking3. Attorneys from State Farm kind of snickered and said, yeah, we could get it in an hour or two if you know the right person to call.
I have seen in my hand, I would guess ten to fifteen Geozips. I cannot say with confidence how many times my orders were complied with though. I think that’s important to know.
I have heard the proprietary trade secret argument raised — (p. 6).
* * *
State Farm gets a bill from the provider. They then send the bill to Mitchell Medical. Mitchell Medical then responds with an approved amount. This is what has been told to me by State Farm’s people as it pertains to each CPT code and question. And there is a serial number associated with each claim or a numeric number. And that’s the only thing the Geozip says.
So I just don’t even begin to get to — nobody is asking for the working of the program. Nobody is asking for the mechinism that the communication occurs. They are just asking for a report that I would bet a shareholder of any significance wanted to see they could get that’s been provided countless times that doesn’t contain any new information. And I think it’s important to note at our last hearing, I was hopeful that we could get State Farm to just, oh, I don’t know, to agree to all the other CPT reports they’ve given in the past so that we wouldn’t have to do this anymore (p. 7).
* * *
Bearing in mind I’ve denied this. Because again, I mean no disrespect to you [defense attorney], I think this is frivolous and meritless (p. 10).
6. Based on the record and the facts set forth above, the Defendant has engaged in a pattern designed to thwart discovery evincing a continuous pattern of willful, deliberate, and contumacious disregard of the Florida Rules of Civil Procedure and the Court’s clear position concerning State Farms’ obligation to produce this information.
7. Defendant’s willful failure to produce this information and to abide by this Court’s orders and the Rules of Civil Procedure has severally prejudiced the Plaintiff in its attempt to prosecute this matter and bring it to a conclusion. Defendant can offer no reasonable justification for continuously raising the same objections to discovery that this Court has ruled upon over and over again.
8. Moreover, pursuant to the Florida Rules of Judicial Administration, rule 2.250(b) this case should have been resolved within 12-18 months. This case has far exceeded the reasonable time frame for completion and said conduct creates a significant problem of judicial administration.
9. In this case, the Court utilizes Rule 1.380(a)(3), 1.380(d) and 1.380(b)(2)(A) and (b)(2)(B) and finds that the information that State Farm was obligated to produce is relevant and admissible and if produced would have supported Plaintiff’s position and negated Defendant’s position regarding the reasonableness of Plaintiff’s charge. Utilizing subsection (A) and (B), this Court deems that Plaintiff’s charge is reasonable.
10. The hearing on Plaintiff’s motion for summary judgment or summary disposition is rescheduled to occur on February 08, 2016 at 11:00 a.m.
__________________
1Case No.: CONO13-009952(70).
2This Order required the following information in the report: (1) the claim number, (2) the date of service, (3) the CPT code, (4) the name of the healthcare provider, (5) the address of the healthcare provider, (6) the amount of each healthcare providers’ charge for each CPT code, and (7) the amount of the recommended reimbursement for each CPT code.
3State Farm had previously defended production of the Geozips in these cases (as Judge Fry referenced), by claiming that it would take far too long, and cost far too much to gather. That argument was later exposed by plaintiff attorneys as fallacious. See, e.g., the testimony of PIP/litigation claims representative, Stephanie Salado, who testified that it takes less than a minute to procure the Geozip information on a computer (Deposition of Salado, p. 20-21).
