21 Fla. L. Weekly Supp. 810a
Online Reference: FLWSUPP 2108RAMI
Depositions — At deposition of insurer’s corporate representative, medical
provider may inquire as to reimbursement levels in community as reflected by
amounts insurer has paid other similarly placed providers in community —
Insurer is required to bring to deposition complete PIP file and any documents
that identify person who decided allowable amount for claim
Vladimir), Plaintiff, v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY,
Defendant. County Court, 11th Judicial Circuit in and for Miami-Dade County.
Case No. 13-5045 SP 23. March 27, 2014. Myriam Lehr, Judge. Counsel: Jacklyne
Marti, Florida Advocates, for Plaintiff. Nancy J. Saint-Pierre, Ayenn C. Stark
& Associates, Miami, for Defendant.
AMENDED ORDER ON DEFENDANT’S
MOTION FOR PROTECTIVE ORDER AND TO
LIMIT THE SCOPE OF PLAINTIFF’S DEPOSITION
OF THE CORPORATE REPRESENTATIVE
and to Limit the Scope of Plaintiff’s Deposition of the Corporate Representative
“Reimbursement levels in the community where the service was
performed, as reflected by the amounts which Defendant has paid other similarly
placed providers in in the community where the service was performed for the
same CPT codes that are at issue in this case, during the period of time from
December 1, 2007 through December 31, 2007 and during the period of time from 10
days prior to the date of service in this case until 10 days after the date of
service in this case;” Shall be limited to a sampling of thirty
stipulated to coverage so Defendant does not need to bring said documents to the
structure as it is not in the new Notice of Deposition.
documentation regarding the drafting of Explanation of Benefits/Explanation of
Review,” Defendant must bring the complete PIP file.
documentation regarding whom, on Defendant’s behalf, authorized the method to
use to determine the allowable, approved, or authorized amount.” Defendant must
bring any document that identifies the person who decided the allowable amount.
Defendant retains any objections to work product, privilege, etc. . . .
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