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`PLAINTIFF’S REQUEST FOR ADMI
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`RE: DEFENDANT’S “DEMAND LETTER”
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`ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/16/2023 05:36:22 PM
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`
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`’s receipt of the i
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`’s receipt of
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`That Defendant’s explanation of benefits did not state the name of the person specified by
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`That Defendant responded to Plaintiff’s Demand Letter.
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`That Defendant’s Demand Letter Response failed to allege non
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`issue to a condition precedent, prior to the Plaintiff’s Complaint.
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`
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`’s
`17. Defendant would not have paid East Coast Neuro, LLC’s bill even if it had received a
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`perfect demandletter addressed to the specified recipient.
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`18. That pursuant to 627.736(10)(f) it is an unfair trade practice for a carrier to make a
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`general businesspractice of not paying valid claims until a demandletter is received.
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`19, That Defendant has engaged in an unfairtrade practice of not paying valid claimsprior to
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`receipt of a demandletter.
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`20. That Defendant denied this claim in its entirety prior to the date East Coast Neuro, LLC
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`sent its demandletter.
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`21. That a demandletter is not required where a claim is denied in its entirety.
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFYthat a true and correct copy of the foregoing has been furnished
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`to all parties or their counsel of record by e-mail on February 16, 2023.
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`SHUSTER & SABEN, LLC
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`_/4s/MelissaR.Winer__
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`ADAMSABEN,ESQ.
`Fla. Bar No.: 0958697
`Email: Adam@piplaw.com
`MELISSAR. WINER, ESQ.
`Fla. Bar No.: 084594
`Email: Melissa@piplaw.com
`JULIA E. GAZECKA,ESQ.
`Fla. Bar No.: 1011317
`Email: JuliaG@piplaw.com
`10245 Centurion Parkway,Suite 305
`Jacksonville, Florida 32256
`Pleading E-mail: JaxPleadings@piplaw.com
`Telephone: 904-999-4000
`Fax Number: 904-374-9644
`Attorney for Plaintiff
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