throbber
Filing # 181326578 E-Filed 09/07/2023 02:38:38 PM
`
`I N THE COUNTY COURT IN AND FOR
`ORANGE COUNTY, FLORIDA
`
`CASE NO.: 2023-CC-002344-0
`
`PATH MEDICAL ACQUISITION
`COMPANY, INC.
`a/a/o Lizsandra Latorre
`
`Plaintiff,
`
`vs.
`
`NATIONAL GENERAL INSURANCE
`COMPANY
`
`Defendant,
`
`/
`
`PLAINTIFF'S MOTION IN LIMINE
`
`COMES NOW, Plaintiff, by and through the undersigned counsel, and files this Motion
`
`in Limine.
`
`In support of its Motion, Plaintiff states as follows:
`
`1. Defendant must be precluded from referring to the accident
`
`in question as
`
`a
`
`"fender-bender"
`
`or by any other pejorative term. There is no
`constructionist or expert to testify to the nature, extent or severity of the accident
`
`accident
`
`re-
`
`and all comments regarding same
`
`should be precluded. In the case of Mathieu v.
`
`Schnitzer, 559 So.2d 1244 (Fla. 4th DCA 1990),
`the Appellate Court found that
`in relation to pedestrian's injuries and what that evidence
`
`damage found on
`
`a car
`
`understanding of an
`indicated to a trained investigator was not within the common
`average layman. To qualify as an expert in a given area, it must be shown that the
`
`witness has acquired special knowledge of the subject matter whether by study or
`
`though experience. Lake Hospital & Clinic, Inc. v. Silverman, 551 So. 2d 538 (Fla.
`4th DCA 1989) No individual, neither a
`from
`
`representative nor
`
`an attorney,
`
`[404-07909/43794631/1]
`
`

`

`Defendant has such expertise and there is no
`
`such person listed on Defendant's
`
`pretrial catalog. Therefore, no witness can give any testimony concerning impact or
`
`the need for emergency treatment
`
`at
`
`the scene. Accordingly, Plaintiff
`
`seeks a
`
`Motion in Limine precluding such reference in any manner
`infer some kind of fraud which is not pleaded. It
`
`2. Defendant may attempt to allege or
`
`whatsoever.
`
`is a well— established point of law that fraud must be plead with specificity. See Fla.
`Rules of Civil Procedure 1.120(b). See Bankers Mutual Cap. Corp. v. US Fidelity &
`
`Guaranty Co., 786 So.2d 485 (Fla. 4th 2001); Peninsular Florida Dist. Council v.
`
`Pan Am. Invest & Dev. Corp., 450 So. 2d 1231 (Fla. 4th DCA 1984). The elements
`of
`1) misrepresentation of
`
`fraud are:
`
`a material
`
`fact; 2) knowledge that
`
`misrepresentation is
`
`false; 3)
`
`intention that
`
`the other party rely on
`
`said
`
`misrepresentation; 4) justifiable reliance and; 5) resulting injury or damage. See
`
`Eastern Cement v. Halliburton Co., 600 So. 2d 469 (Fla. 4th DCA 1992); Arnold v.
`
`Week, 388 So. 2d 269 (Fla. 4th DCA 1980). Pleading fraud without particularity in
`an affirmative defense does not raise the issue of fraud for trail. Cady v. Chevy Case
`
`S. & L. Assoc., 528 So.2d 136 (1988). Moreover, elements not pled may not be
`inferred from context. Myers v. Myers, 652 So. 2d 1214 (Fla. 5th DCA 1995).
`
`Failure to allege fraud with particularity is grounds for dismissal of
`
`the claim.
`
`General Dynamics Corp. v. Hewitt, 225 So. 2d 561 (Fla. 3rd DCA 1979). Defendant
`fraud which is
`claiming any kind of
`must be precluded from inferring or
`
`inadmissible as a matter of law at trial and which has not been plead and is not
`factually supported in any manner whatsoever.
`[404-07909/43794631/1]
`
`

`

`3. Defendant should be precluded from any mention that the claimant went
`that an attorney referred him to the medical facility in question. It is not
`
`attorney or
`
`to see an
`
`relevant and its prejudicial value far outweighs its probative value. Any questions
`
`regarding the time period or circumstances under which the claimant hired an
`attorney is not relevant to this suit. Watson v. Builders Square,563 So.2d. 721 (4th
`
`DCA 1990). There is no allegation that the claimant
`is litigious and therefore no
`relevance to him seeking the assistance of an attorney or how it was
`
`that he came
`
`to
`
`seek medical treatment.
`
`4. Any mention, comment,
`
`reference, suggestion or question that
`
`the patient and
`
`plaintiff are dishonest or
`
`are committing insurance fraud or
`
`that their claims are
`
`suspect or
`
`referred to the Special Investigation Unit (SIU) or
`that any claims were
`the reasons why it was
`referred to SIU. Statements in a proof of loss must be willful
`
`and fraudulent before they will
`
`render the policy void for fraud and the insurer has
`
`the burden to establish the knowing and willful misrepresentations were material to
`its risk. See Rogers v. Auto-Owners Ins. Co., 379 So. 2d 700 (Fla. 2d DCA), cert
`
`denied., 388 So.2d 1109 (Fla.1980) (insurer burden to establish knowing and willful
`misrepresented facts material to company's risk); and E. G. Berkshire Mut. Ins. Co.
`
`v. Moppet, 378 F.2d 1007, 1012 ( 5th Cir. 1967) (overestimation of value of goods,
`
`and mistake for an
`
`the fixing of values will not render the
`in judgment on
`insurance contract void unless "the proof of the false swearing was
`such that no
`
`error
`
`other conclusion can
`
`be drawn than that
`
`a purposeful misrepresentation was
`
`intended").
`[404-07909/43794631/1]
`
`

`

`5. Any mention, comment, reference, suggestion or question to the patient's desire for
`treatment being motivated by the attorneys, claim building or establishment of the
`
`tort threshold in a personal injury case.
`
`6. Any mention, comment, reference, suggestion or question to the financial status of
`
`the patient should be precluded.
`
`7. Any mention, comment, reference, suggestion or question to any claims that the
`
`patient has ever made including unemployment, workers compensation, or
`
`jury
`
`claims whatsoever subsequent
`
`to the accident date in question and completion of
`
`treatment should be precluded.
`8. Any mention, comment, reference, suggestion or question if this suit or
`
`judgment in
`
`this suit would have any effect upon the insurance rates, premium or charges, either
`generally or as particularly applied to the Defendant as a result of this matter should
`
`also be precluded.
`
`9. Defendant should be prohibited from making any mention, comment
`an "insurance crisis." Davidoff v. Segret, 551 So.2d 1274 (Fla. 4th DCA 1989).
`
`or reference to
`
`10. Defendant should be prohibited from making any mention, comment, reference or
`asking any questions encouraging the jury to "send a messageby its verdict to act
`
`as
`
`the voice of the community or
`
`to use
`
`its verdict to punish the plaintiff and
`
`patient. Eagle- Picher Industries Inc. v. Cox., 481 So.2d 517 (Fla. 3n1 DCA 1985);
`Florida Crushed Stone Co.
`v. Johnson, 546 So.2d.1102 (Fla. 5th DCA 1989);
`
`Brumage v. Plummer, 502 So.2d.966 (Fla.3r1 DCA 1987); Davidoff v. Segret, 551
`
`[404-07909/43794631/1]
`
`

`

`So.2d 1274 (Fla. 4111 DCA 1989); and Sacred Heart Hospital ofPensacola v. Stone,
`650 So.2d 676(Fla. 1 sr DCA 1995).
`
`11. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument that the medical records are
`
`insufficiently detailed. See
`
`Florida Medical & Injury Ctr.,
`
`Inc. v. Progressive Express Ins. Co., 29 So.3d 329
`
`(Fla. 5th DCA 2010), and Cardinal Inv. Gp., Inc. v. Giles, 813 So. 2d 262, 263 (Fla.
`4th DCA 2001) (IC]ourts are not authorized to grant relief not requested in the
`
`pleadings."). Florida law is clear that a defense not raised is waived. See Fla. R.
`
`Civ. P. 1.140(h)(1).1 See Miami Electronics Center, Inc. v. Saporta, 597 So.2d 903,
`
`904-905 (Fla. 3rd DCA 1992); Jorge v. Rosen, 208 So.2d 644, 647 (Fla. 3rd DCA
`
`1968).
`12. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument that the Health Insurance Claim Forms are
`
`insufficient or
`
`non-compliant. Florida law is clear that a defense not raised is waived. See Fla. R.
`Civ. P. 1.140(h)(1). See Miami Electronics Center,
`
`Inc. v. Saporta, 597 So.2d 903,
`
`904-905 (Fla. 3rd DCA 1992); Jorge v. Rosen, 208 So.2d 644, 647 (Fla. 3rd DCA
`1968). It would also be confusing and prejudicial.
`
`13. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument that the charges or services are unlawful. Florida law is
`
`1 Furthermore, the Supreme Court of Florida defined waiver as "the voluntary and intentional
`relinquishment of a known right or conduct which implies the voluntary and intentional
`relinquishment of a known right." Raymond James Financial Services, Inc. v. Saldukas, 896
`So. 2d 707 (Fla. 2005) [30 Fla. L. Weekly S115a].
`[404-07909/43794631/1]
`
`

`

`clear that a defense not raised is waived. See Fla. R. Civ. P. 1.140(h)(1). See Miami
`Electronics Center, Inc. v. Saporta, 597 So.2d 903, 904-905 (Fla. 3rd DCA 1992);
`
`Jorge v. Rosen, 208 So.2d 644, 647 (Fla. 3rd DCA 1968).
`
`It would also be
`
`confusing and prejudicial.
`14. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument
`
`that contradicts Defendant's admissions in this case,
`
`including technical admissions, as Defendant is bound by same.
`
`15. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument that the charges or services are unbundled or upcoded.
`See Fla. R. Civ. P. 1.140(h)(1). See Miami Electronics Center, Inc. v. Saporta, 597
`
`So.2d 903, 904-905 (Fla. 3rd DCA 1992); Jorge v. Rosen, 208 So.2d 644, 647 (Fla.
`3rd DCA 1968). It would also be confusing and prejudicial.
`
`16. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument
`
`that
`
`the disclosure and acknowledgement
`non-compliant. See Florida Medical & Injury Ctr.,
`
`form is
`
`Inc.
`
`v.
`
`insufficient
`
`or
`
`Progressive Express Ins. Co., 29 So.3d 329 (Fla. 5th DCA 2010).
`17. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument regarding any statute, law or administrative code violated
`
`This
`
`includes, without
`
`by Plaintiff.
`627.736(4)(b), F.S.
`627.736(5)(d) and/or Fla. Admin. Code 64B217.0065. See Florida Medical &
`
`limitation,
`
`F.S.
`
`Injury Ctr., Inc. v. Progressive Express Ins. Co., 29 So.3d 329 (Fla. 5th DCA 2010).
`See Fla. R. Civ. P. 1.140(h)(1). See Miami Electronics Center, Inc. v. Saporta, 597
`[404-07909/43794631/1]
`
`

`

`So.2d 903, 904-905 (Fla. 3rd DCA 1992); Jorge v. Rosen, 208 So.2d 644, 647 (Fla.
`3rd DCA 1968). It would also be confusing and prejudicial.
`
`18. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument
`
`that any of
`
`the CPT/HCPCS coding is incorrect,
`insufficient. See Fla. R. Civ. P. 1.140(h)(1). See Miami Electronics
`
`incomplete or
`
`Inc.
`
`Center,
`
`v. Saporta, 597 So.2d 903, 904-905 (Fla. 3rd DCA 1992); Jorge v.
`Rosen, 208 So.2d 644, 647 (Fla. 3rd DCA 1968). It would also be confusing and
`
`prejudicial.
`
`19. Defendant should be prohibited from making any mention, comment, reference to
`information to
`
`any evidence or argument that Defendant or any expert needs more
`
`determine if treatment was
`
`reasonable, related and medically necessary. See Florida
`Medical & Injury Ctr., Inc. v. Progressive Express Ins. Co., 29 So.3d 329 (Fla. 5th
`
`DCA 2010). Furthermore, the defense,
`
`if valid, was not raised in the pleadings by
`
`Defendant and therefore is waived. Furthermore, the evidence or argument would
`
`be unduly prejudicial and confusing in relation to any probative value. Finally,
`
`Defendant has shown no due diligence in obtaining the information necessary for
`
`the Defendant or
`
`its expert to render an opinion. See also State Farm Mut. Auto. Ins.
`
`Co. v. Florida Wellness and Rehab a/a/o Luis Alonso, 23 Fla. L. Weekly Supp. 88a
`
`(Fla. 17th Cir. Ct. App. 2015).
`20. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument that "medical necessity" means
`something more
`Stat. 627.732(2). The Florida Legislature has already defined medical necessity in
`[404-07909/43794631/1]
`
`than Fla.
`
`

`

`the PIP context. Neither Defendant, nor
`
`its expert, should be permitted to advance a
`
`definition in contravention of Florida's Motor Vehicle No-Fault Law and the
`
`Standard Jury Instructions.
`
`21. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument that Defendant should be refunded any monies or
`
`that
`
`Defendant overpaid the claim or
`insured. See Cardinal Inv. Gp.,
`
`that Defendant
`
`is acting to the benefit of the
`
`Inc. v. Giles, 813 So. 2d 262, 263 (Fla. 4th DCA
`
`2001) CIC]ourts are
`
`not authorized to grant
`
`relief not
`
`requested in the
`
`pleadings."). Neither has Defendant pled set-off nor
`
`recoupment, which is therefore
`
`waived.
`
`22. Defendant should be prohibited from making any mention, comment, reference to
`any evidence or argument that Plaintiff
`s charges are unreasonable in price based on
`
`an actuarial report or actuary's statement.
`
`23. Defendant should be prohibited from making any mention, comment, reference to
`any argument that Plaintiff
`
`s charges are not usual and customary. Defendant has no
`
`evidence of this suggestion, which would mislead the trier of fact.
`24. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument as
`
`implying that this case
`
`is a Medicare claim. This is
`
`NOT a Medicare claim and no government dollars at issue. Defendant cannot
`
`treat
`
`this claim as Medicare and PIP is not
`
`See e.g, AFO Imaging v.
`
`Nationwide, 71 So.3d 134 (Fla. 2d 2011); and, SOCC, PL v. State Farm, 95 So.3d
`
`903 (Fla. 5th DCA 2012)("This language clearly prohibits an
`[404-07909/43794631/1]
`
`insurance company
`
`

`

`from treating PIP claims as
`they were Medicare claims."). Defendant must be
`precluded from referring or eliciting in anyway any reference to HMOs and PPOs.
`
`if
`
`Differential pricing is irrelevant
`
`in a PIP claim and confuses the issues.
`
`In
`
`Hillsborough Co. Hosp. Auth.
`
`the Court ruled that
`
`v. Fernandez, 664 So.2d 1071 (Fla. 2d DCA 1995),
`though it
`
`not unreasonable even
`
`the hospital charge was
`
`accepted less in reimbursement from
`patients and patients with group plans.
`
`patients, Worker's Compensation
`the trial court
`
`found the
`
`In Fernandez,
`
`hospital charge was unreasonable.
`
`Id. The trial court premised its decision on
`
`the
`
`fact that the hospital accepted less for the same
`service from (i) health maintenance
`organizations ("HMO's"), and (ii) preferred provider organizations ("PPO") as well
`
`as (iii) "the evidence also pertained to discounts received by Medicare, Medicaid
`and workerscompensation." Id. The Second District Court of Appeals reversed the
`
`trial court, and held that the mere
`
`fact that the hospital accepted less from PPO's,
`
`HMO's,
`
`and Workers Compensation patients was
`evidence to find that the hospital charge was unreasonable. Id. The Fernandez court
`
`not competent
`
`also held that differential pricing is relevant as well, but
`is insufficient
`uncertain terms, differential pricing, standing alone,
`
`the court
`
`ruled, in no
`
`to prove the
`
`medical charge unreasonable. Based on this binding case, the Seventh Circuit sitting
`
`in its appellate capacity held that,
`charges to other vendors for the same
`
`in the PIP context, "[w]hile evidence of NSPs
`
`evidence in determining whether
`information alone, even
`
`unreasonable,
`
`that
`
`if uncontested,
`
`is not enough to the
`
`services may be relevant along with other
`
`the specific
`
`charges
`
`in question were
`
`[404-07909/43794631/1]
`
`

`

`charges in question were
`
`unreasonable." State Farm Mutual Automobile Insurance
`
`Company v. New Smyrna Imaging, LLC et al, 22 Fla L. Weekly Supp. 508a (7th
`
`Jud. Cir. App. Ct. Sept. 11, 2014), reh 'g denied and cert. denied (Fla. 5th DCA
`
`Sept. 2, 2015).
`25. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument as to the AMA definition of "medical necessity." The
`Florida Legislature has already defined medical necessity in the PIP context.
`
`Neither Defendant, nor
`
`its expert, should be permitted to advance a definition in
`
`contravention of Florida's Motor Vehicle No-Fault Law and the Standard Jury
`
`Instructions.
`
`26. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument as to the AMA CPT Coding Manuals. The evidence is
`
`confusing, prejudicial and irrelevant
`
`to the pleadings and pre-trial stipulation.
`
`Coding is not an issue for the jury trial.
`27. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument as to the 1997 Documentation Guidelines for Evaluation
`
`and Management Services. The evidence is confusing, prejudicial and irrelevant to
`
`the pleadings and pre-trial stipulation. Again, coding is not an
`
`issue for the jury
`
`trial.
`
`28. Defendant should be prohibited from making any mention, comment, reference to
`
`any evidence or argument that the insured is indemnified in event
`found not be not reasonable and/or provider sued insured. See United Auto.
`[404-07909/43794631/1]
`
`that treatment
`
`was
`
`

`

`Ins. Co.
`
`v. Chiro-Care Centre of Broward,
`Weekly Supp. 436a (Fla. 17th Cir. Ct. App. 2012).
`
`Inc. a/a/o Josie Thomas, 19 Fla. L.
`
`29. Defendant should be prohibited from making any mention, comment, reference to
`
`any reference to co-pays or co-payment or
`
`the patient's responsibility, which is
`irreverent to this breach of contract claim. Furthermore, this policy does not contain
`
`a 20% co-pay for all services.
`30. Defendant is limited to its viable affirmative defenses and cannot raise any issue not
`
`specifically plead. Plaintiff does not agree to litigate any affirmative defenses not
`
`or
`
`plead and viable and seeks a motion in limine from any mention, in any way, shape,
`form, of any of these grounds for denying the claim. See Book v. City of Winter
`Park, 718 So.2d.945 (Fla. 5th DCA 1998). Therefore, Plaintiff seeks an instruction
`precluding Defendant from blurting out reasons
`for non-payment that have not been
`
`properly plead.
`
`31. The Third District Court of Appeals has repeatedly expressed its displeasure when a
`party is permitted to ambush its opponent at trial with issues not
`
`raised by the
`
`intended to be litigated at trial. In the case of Sobel v. Jefferson
`pleadings and not
`Stores, Inc., 459 So.2d 433 (Fla. 3d DCA 1984), Chief Judge Alan Schwartz noted
`
`the Court's astonishment at the granting of a directed verdict by the trail court
`
`that
`
`the plaintiffs had failed to affirmatively show the defendant was
`negligent operation of one of its stores where the accident occurred, after a hung
`
`liable for the
`
`jury failed to return a verdict on a slip and fall case. Chief Judge Schwartz stated the
`
`following:
`[404-07909/43794631/1]
`
`

`

`contained a
`Although Jefferson Stores, Inc.'s answer
`the allegations of
`general denial of all of
`the
`complaint, including the routine one that
`it operated
`the Jefferson store in question, its defense of the case,
`which it conducted throughout discovery and at trial
`to the end of the plaintiff s
`from opening statement
`reference to any claim that it was
`case totally without
`the responsible entity- including producing as its
`not
`corporate representative for deposition and trial
`the
`employee who was on the scene in the store when Mrs.
`fell-
`from
`clearly waived and stopped it
`Sobel
`asserting any such contention when it
`leaped from
`ambush with the claim of a failure of proof only after
`plaintiffs had rested. Argenbright v. J.M. Fields Co.,
`196 so2d 190 (Fla.3d DCA 1967), cert. denied, 201
`In
`So.2d 895(Fla.1967); Holvoke mutual
`Ins. Co.
`Salem v. Concrete Equipment,
`Inc., 394 So.2d 193
`(Fla. 3d DCA 1981)m pet. for rev. denied, 402 So.2d
`609 ( Fla.1981); Salcedo v. Asociacion Cubana,Inc.,
`368 So.2d 1337 (Fla.3d DCA 1979), cert.denied, 378
`So.2d 342 (Fla.1979).
`
`32. Defendant is precluded from making any reference to a police report or comments
`
`made to or by the investigating officer or
`
`comments made at
`
`the scene
`
`of
`
`the
`
`accident by any person, witness or party to the accident pursuant to F.S. 316.066(4).
`33. Defendant should be prohibited from challenging Plaintiff
`
`s counsel to explain to
`
`the jury why it did not call certain witnesses, or why deposed witnesses were
`trial, or making other references to matters outside the record. Riggins v. Mariner
`
`not at
`
`Boat Works, 545 so.2d 430 (Fla. 2d DCA 1989); Sacred Heart Hospital of
`
`Pensacola v. Stone. supra.
`
`34. Plaintiff has made or will make a good faith effort to avoid a hearing on this matter.
`
`This motion will not prejudice the parties.
`
`[404-07909/43794631/1]
`
`

`

`WHEREFORE, Plaintiff, seeks this relief for a fair trial, and all other relief just and
`
`proper.
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing was
`Mail on September 7, 2023 to: William J. McFarlane, III, Esq., McFarlane, Dolan & Prince,
`
`sent via E-
`
`pleadingservice@mcfarlanedolanlaw.com.
`
`LANDAU & ASSOCIATES, P.A.
`1619 NW 136th Avenue
`Suite 2C
`Sunrise, FL 33323
`Telephone (954) 744-8383
`Facsimile (954) 391-7805
`Email: efilings@pip-lawyers.com
`/s/ Dylan B Stearns
`Dylan B Stearns ESQ.
`Florida Bar No. 1035213
`
`By:
`
`[404-07909/43794631/1]
`
`

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