Case 2:22-cv-02820-LMA-DMD Document 1 Filed 08/23/22 Page 1 of 15
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`UNITED STATES DISTRICT COURT
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`EASTERN DISTRICT OF LOUISIANA
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`CIVIL ACTION NO: __________________
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`TAYLOR B. THEUNISSEN, MD, LLC,
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`and SADEGHI CENTER FOR PLASTIC
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`SURGERY, LLC, Individually and as
`Assignees and Authorized Representatives *
`of N.T.
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`VERSUS
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`UNITED HEALTHCARE OF
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`LOUISIANA, INC.
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`COMPLAINT
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`NOW INTO COURT comes Sadeghi Center for Plastic Surgery, LLC and Taylor B.
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`Theunissen, MD, LLC, individually and as the assignees and authorized representatives of their
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`patient N.T., and for their Complaint (“Complaint”) aver as follows:
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`Introduction
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`1.
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`At all times relevant hereto, N.T. 1 was a “beneficiary,” as defined by 29 U.S.C. §
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`1002(8), in an “Employee Health Benefit Plan,” as defined by 29 U.S.C. § 1022(1), which was
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`sponsored by Bechtel Global Corporation and administered by United Healthcare of Louisiana,
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`Inc. (the “Plan.”).
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`Because of confidentiality concerns, Plaintiff Providers’ patient is identified solely by her initials.
`1
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`Case 2:22-cv-02820-LMA-DMD Document 1 Filed 08/23/22 Page 2 of 15
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`2.
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`This case is a claim for benefits due under the Plan, as hereinafter defined, based
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`upon adverse benefit determinations for services rendered to N.T. by Plaintiffs, Sadeghi Center
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`for Plastic Surgery, LLC and Taylor B. Theunissen, MD, LLC (collectively “Plaintiff
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`Providers”). The Plan delegated responsibility to make the benefit determinations at issue to
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`United Healthcare of Louisiana, Inc. (“United”) under the express terms of the Plan. As such,
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`United is a fiduciary under ERISA.
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`The Parties
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`Plaintiffs
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`3.
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`Plaintiff, Taylor B. Theunissen, MD, LLC, (“TBT”), is a Louisiana limited
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`liability company domiciled in the Parish of East Baton Rouge, State of Louisiana; and,
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`4.
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`Plaintiff, Sadeghi Center for Plastic Surgery, LLC (“Sadeghi”) is a Louisiana
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`limited liability company domiciled in the Parish of Jefferson, State of Louisiana. 2
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`Defendants
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`5.
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`Defendant United is a corporation organized and existing under the laws of the
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`State of Louisiana domiciled, authorized to do and doing business, and subject to personal
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`jurisdiction, within this judicial district.
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`Jurisdiction and Venue
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`6.
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`The Defendant’s actions in administering the Plan are governed by the Employee
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`Retirement Income Security Act of 1974, 29 U.S.C. §1001-1461 (“ERISA”). This Court
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`possesses subject matter jurisdiction over the claim for benefits brought under 29 U.S.C. §
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`1132(a)(1)(B) is action pursuant to 28 U.S.C. § 1331 and 29 U.S.C. § 1132(e).
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`2
`Alireza Sadeghi, M.D. provides patient services through Sadeghi. Taylor B. Theunissen, M.D. provides
`patient services through TBT.
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`2
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`Case 2:22-cv-02820-LMA-DMD Document 1 Filed 08/23/22 Page 3 of 15
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`7.
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`Venue is appropriate in this court pursuant to 28 U.S.C. §1391in that the events
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`giving rise to the claims occurred in the Eastern District of Louisiana, including but not limited
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`to the professional medical serviced provided by Plaintiff Providers to patient N.T., as well as the
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`events or omissions by united giving rise to the claims set forth herein.
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`Standing
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`8.
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`As a “beneficiary” of the Plan as that term is defined in 29 U.S.C. §1002(8), N.T.
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`has standing to bring this action under 29 U.S.C. §1132(a)(1)(B).
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`9.
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`By and through an assignment of benefits and claims, N.T. has assigned her right
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`to bring this action to Plaintiff Providers, who therefore have standing to bring this action under
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`29 U.S.C. §1132(a)(1)(B). Specifically, N.T. executed a document entitled Assignment of
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`Benefits/Designated Authorized Representative (“Assignment and Designation”) which assigned
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`“to the fullest extent permitted by law and all benefit and non-benefit rights (including the right
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`to any payments) under my healing insurance policy or benefit plan” to the Plaintiff Providers.
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`10.
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`Through that same Assignment and Designation, N.T. designated Plaintiff
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`Providers as her “authorized representatives,” as defined in 29 C.F.R.§ 2560.503-1 and Plaintiff
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`Providers may, therefore, bring this action on behalf of N.T. under 29 U.S.C. § 1132(a). The
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`instrument N.T. executed in favor of Plaintiff Providers incorporates, inter alia, the following
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`language;
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`I hereby appoint as Designated Authorized Representative each of my Providers
`and each of their respective assistant surgeons, physician assistants, teaching
`assistants, billing staff, lawyers or any other person or business that provides
`healthcare activity services as a “business associate” (including Howard Healthcare
`Group) under the Health Insurance Portability and Accountability Act of 1995, as
`amended (“HIPAA”) and their respective designees (collectively referred to herein
`as an “Authorized Representative”). This authorization is intended to comply with
`all requirements of the Employment Retirement Income Security Act of 1974, as
`amended (“ERISA”) and any applicable State law. Each authorized representative
`is granted the same rights which I have as a member or beneficiary under my
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`3
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`Case 2:22-cv-02820-LMA-DMD Document 1 Filed 08/23/22 Page 4 of 15
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`insurance policy or benefit plan, including without limitation: (1) the right of my
`Authorized Representative to file claims for benefits on my behalf and directly
`receipt payment for benefits and non-benefits from any third party payor under my
`insurance policy or benefit plan, including the right to penalties, interest and
`attorneys’ fees; (2) the right of my Authorized representative to communicate with
`Insurers, plan fiduciaries, employers and plan and claim administrators relative to
`all my benefit information and private health information (“PHI”) as further defined
`under HIPAA and to share and exchange such information with a “covered person”
`or “business association” as those terms are defied under HIPAA; (3) the right of
`my Authorized Representative to send and receive follow-up information and
`obtain all documentation that ERISA or any State law required to be provided to
`me, including, without limitation, plan documents, explanation of benefits, adverse
`benefit determinations, all relevant documents involving my claim, identity of all
`persons involved in determining my claim and all documents relied upon in making
`any determination as to the payment of any amount under the applicable plan; (4)
`The right of my Authorized Representative to file any internal or external member
`appeal for payment of benefits under any applicable insurance policy or benefit
`plan; [and] (5) The right of my Authorized representative to pursue any rights,
`claim or cause of action through litigation or otherwise under any Federal or State
`law with respect to payment for services provided by a Provider to me, including
`penalties, interest and attorneys’ fees.
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`Factual Background
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`11.
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`N.T. was diagnosed with left breast cancer and underwent a bilateral mastectomy
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`and breast reconstruction but the reconstruction required subsequent revision.
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`12.
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`On March 23, 2018, the Plaintiff Providers performed a bilateral revision breast
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`reconstruction with deep inferior epigastric perforator (DIEP) flaps (“First Surgery”) on N.T.
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`13.
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`A DIEP Flap is a cutting-edge breast reconstruction procedure that uses a flap of
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`complete tissue, blood vessels, skin and fat from the woman’s lower abdomen as donor tissue.
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`The flap is then transplanted to the chest where those removed blood vessels are reconnected to
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`the vessels in the chest. The flap is then shaped into a new breast and the abdomen is surgically
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`closed. The procedure requires two micro-surgeons and at times, both a first and second assist,
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`working together in unison for approximately 8-12 hours. There are few surgeons with proper
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`training and skill to perform this complex procedure.
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`14.
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`Breast reconstruction procedures such as the DIEP Flap are specifically covered
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`by the Plan, which states in relevant part:
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`Benefits for Reconstructive Procedures include breast reconstruction following a
`mastectomy and reconstruction of the non-affected breast to achieve symmetry.
`Replacement of an existing breast implant is covered by the Plain if the initial breast
`impact followed a mastectomy. Other services required by the Women’s Health and
`Cancer Rights Act of 1998; including breast prostheses and treatment of complications,
`are provided in the same manner and at the same level as those for any other Covered
`Health Service. …
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`15.
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`Dr. Alireza Sadeghi of Sadeghi (“Dr. Sadeghi”) is a double board certified plastic
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`surgeon and reconstructive microsurgeon who specializes in reconstructive breast surgery for
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`women who have dealt with breast cancer in the past. He graduated from the Karol
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`Marcinkowski University of Medical Sciences, where he received his Ph.D. He completed his
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`internship and residency in general surgery at SUNY Downstate Medical Center, where he also
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`served as Chief Resident. He then completed an additional residency at LSU Health Sciences
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`Center in plastic and reconstructive surgery, and again served as Chief Resident.
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`16.
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`Dr. Taylor Theunissen of TBT (“Dr. Theunissen”) is a board certified plastic
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`surgeon with extensive breast reconstruction experience. He graduated from the LSU Health
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`Sciences Center Medical School and completed his residency in orthopedic surgery. He then
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`completed an additional residency at the University of Nebraska Medical Center in plastic and
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`reconstructive surgery. Dr. Theunissen completed fellowship training in craniofacial plastic
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`surgery at Stanford University. He is Associate Professor at LSU and Tulane University medical
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`schools.
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`17.
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`On or about March 5, 2018, several weeks prior to the First Surgery, TBT
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`submitted to United a preauthorization request for the First Surgery citing to multiple CPT codes,
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`including the following: S2068, 19380, 19364, 21600, 15002, 15777, 64910, and 64488. The
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`preauthorization request further explicitly stated that two surgeons, Dr. Theunissen and Dr.
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`Sadeghi, would be performing the First Surgery.
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`18.
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`In response to the preauthorization request, United authorized the First Surgery,
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`reference number A040864938.
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`19.
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`Through correspondence to N.T., copied to TBT, dated March 9, 2018 (“Approval
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`Letter”), United stated that “we have determined that the treatment is medically necessary” and
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`then referenced the following specific CPT codes pertaining to the First Surgery: 19364, 19380,
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`S2068, 21600, 15002, 15777, 64910 and 64488.
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`20.
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`Plaintiff Providers received the Approval Letter and relied upon the Approval
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`Letter, and United’s authorization stated therein, in proceeding with the First Surgery.
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`21.
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`In relevant part, the Plan states as follows pertaining to the definition of Eligible
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`Expenses:
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`For Non-Network Benefits, Eligible Expenses are based on either of the following:
`When Covered Health Services are receive from a non-Network provider, Eligible
`Expenses are determined, based on:
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`-
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`- Negotiated rates agreed to by the non-Network provider and either United
`Healthcare or one of United Healthcare’s vendors, affiliates or subcontractors,
`at United Healthcare’s discretion;
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`If rates have not been negotiated, then one of the following amounts:
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`o For Covered Health Services other than Pharmaceutical Products,
`Eligible Expenses are determined based on available data resources of
`competitive fees in that geographic area.
`…
`o When a rate is not published by CMS for the service, United
`Healthcare uses a gap methodology established by OptumInsight
`and/or a third party vendor that uses a relative value scale. The relative
`value scale is usually based on the difficulty, time, work, risk and
`resources of the service. If the relative value sale currently in use
`becomes no longer available, United Healthcare will use a comparable
`scale(s). United Healthcare and OptumInsight are related companies
`through common ownership by UnitedHealth Group. Refer to United
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`Healthcare’s website at www.myuh.com for information regarding the
`vendor that provides the applicable gap fill relative value scale
`information.
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`One of the “vendors, affiliates or subcontractors” listed on United’s website as a
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`22.
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`vendor providing “gap fill relative value scale information” utilized by United is FAIR Health
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`Inc.
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`23.
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`Pursuant to the terms of the Plan, United had applied the FAIR Health value scale
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`at the 90th percentile level as the reasonable and customary competitive fee for similar
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`procedures in the geographic area at issue.
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`24.
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`Through the Approval Letter, United explicitly stated that the First Surgery was
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`eligible for in patient coverage and was medically necessary.
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`25.
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`Based on the Approval Letter, the Plaintiff Providers believed that a binding
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`contractual agreement had been reached between them and United, whereby Plaintiff Providers
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`would perform the First Surgery and United would pay them the reasonable and customary
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`charges incurred for the First Surgery.
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`26.
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`On March 23, 2018, Dr. Sadeghi and Dr. Theunissen undertook and completed
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`the First Surgery in accordance with the authorization of United.
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`27.
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`Following the First Surgery, Sadeghi submitted a claim to United in the amount of
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`$130,000 in accordance with the agreement evidenced by the Approval Letter and in accordance
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`with the prior authorization.
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`28.
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`The Plaintiff Providers are “out of network” with United, meaning neither of the
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`Plaintiff Providers have agreed to reduce their fees when treating United insureds. N.T. was
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`forced to seek treatment from an out of network physician because United did not have qualified
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`surgeons available for the required procedure on an in-network basis in the relevant area.
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`29.
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`Consistent with the Approval Letter, Sadeghi submitted to United a claim for his
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`bill under two CPT codes, S2068-RT-62 and S2068-LT-62, both of which were included in the
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`Approval Letter.
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`30.
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`United rejected the claim based, at least in part, on the rejection of the CPT Code
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`S2068.
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`31.
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`United’s refusal to honor its prior approval of the billing S2068 is contrary to both
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`the Plan and the industry practice; S2068 was a valid code which had been recognized and
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`utilized by United repeatedly.
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`32.
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`Thereafter, despite the fact that the Approval Letter explicitly authorized the First
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`Surgery, United rejected the initial claim.
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`33.
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`United refused to abide by its agreement stated in the Approval Letter and paid
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`Sadeghi nothing. Plaintiff Providers’ claims to United on behalf of N.T. form the basis of this
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`lawsuit as United, on behalf of the Plan, failed to pay said claims based on the clear terms of the
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`Plan.
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`34.
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`Also following the First Surgery, Theunissen submitted a claim to United in the
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`amount of $125,000.
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`35.
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`In response to the claim submitted by Theunissen, United discounted the claim
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`from $125,000 to $5,000 (a 96% reduction), paid $1,000.00, and indicated that N.T. owed the
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`remaining $4,000.
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`36.
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`37.
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`This adjudication left N.T. responsible for the $120,000 discounted claim amount.
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`Following the First Surgery, a second revision of the breast reconstruction was
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`required. Said second surgery was scheduled for August 6, 2018 (“Second Surgery”).
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`38. With respect to the Second Surgery, United stated in correspondence as follows:
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`During adjudication of out-of-network claims, our system refers to the FH
`Benchmark databased and automatically applies the amount reported at the plan’s
`selected percentile for your geographic area (called the “geozip”) for eligible
`claims. Your plan has chosen to use the 95%Th percentile.
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`39.
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`Again, despite the preauthorization, United refused to pay the claim submitted for
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`this Second Surgery. Plaintiff Providers’ claims to United on behalf of N.T. form the basis of this
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`lawsuit as United, on behalf of the Plan, failed to pay the amount of said claims based on the
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`clear terms of the Plan.
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`40.
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`Thereafter, United made a partial, but still insufficient, payment of the claim
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`submitted by Theunissen for the Second Surgery.
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`41.
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`Following the surgeries in 2018, N.T. required continuing care for her breast
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`reconstruction.
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`42.
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`In early 2020, it was determined that N.T. required a third surgery (“Third
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`Surgery”) to address complications from the prior breast reconstruction procedures which was
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`scheduled for February 17, 2020.
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`43.
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`Through correspondence dated January 24, 2020, Dr. Theunissen requested
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`authorization from United to undertaken the Third Surgery.
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`44.
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`Through correspondence dated February 10, 2020, United authorized the Third
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`Surgery, reference number A090407509. This authorization was further confirmed via a
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`telephone call from Dr. Theunissen’s office to United, Reference Number 8889.
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`45.
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`Consistent with United’s prior authorization, Theunissen undertook the Third
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`Surgery and submitted a claim to United for the Third Surgery in the amount of $60,000.
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`46.
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`However, and again despite the preauthorizations, United rejected the claim
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`submitted by Theunissen and refused to perform pursuant to its agreement as evidenced by the
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`Approval Letter pertaining to the Third Surgery. Plaintiff Providers’ claims to United on behalf
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`of N.T. form the basis of this lawsuit as United, on behalf of the Plan, failed to pay said claims
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`based on the clear terms of the Plan.
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`47.
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`In response to the denial of the claim arising from the Third Surgery, a referral
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`was made of this matter to Medical Audit & Review Solutions (“MARS”). After review, MARS
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`proposed a reduced amount to be paid to Theunissen in the amount of Three Thousand Nine-
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`Hundred Dollars. This offer / proposal was rejected.
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`48.
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`Additionally, United contracted with Multiplan, a third-party company which
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`provides services related to health insurance claims and insurance including review of disputed
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`claims, to facilitate the resolution of the claims.
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`49. Multiplan and MARS also communicated to Theunissen pertaining to the First
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`Procedure, presenting a written offer to pay $62,500.00 of the $125,000 billed and stating
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`“PLEASE RETURN IMMEDIATELY FOR PROMPT PAYMENT” (“MARS Negotiated
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`Resolution”).
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`50.
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`Theunissen accepted the MARS Negotiated Resolution in writing on or about
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`April 18, 2019, one day after it was sent.
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`51.
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`Despite the clear terms of the MARS Negotiated Resolution, United refused to
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`comply with those terms and refused payment.
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`52. Multiplan communicated to Theunissen pertaining to the outstanding claim for
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`services provided by Theunissen arising from the Third Surgery in which Multiplan proposed a
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`reduced payment, allegedly with the consent of United, in the amount of Twenty-Two Thousand
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`Five-Hundred Dollars. Multiplan demanded a response by April 27, 20221.
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`53.
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`Theunissen rejected the Multiplan proposal as wholly insufficient and failing to
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`comply with the terms of the Plan.
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`54.
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`As a result, despite the repeated authorizations, United denied the vast majority of
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`the claims related to the First Surgery, the Second Surgery and the Third Surgery (collectively
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`“Reconstruction Procedures”), and the minimal payments that were made are clearly insufficient
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`and contrary to the Plan. Plaintiff Providers’ claims to United on behalf of N.T. form the basis of
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`this lawsuit as United, on behalf of the Plan, failed to pay said claims based on the clear terms of
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`the Plan.
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`55.
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`In response to United’s refusal to pay the amount of the claims submitted for the
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`Reconstruction Procedures, which were directly contrary to clear terms of the Plan and the
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`representations and agreement from the Approval Letter, the Plaintiff Providers, submitted both
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`first and second level member appeals to United (“Member Appeals”).
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`56.
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`Through these member appeals, the Plaintiff Providers demanded that United
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`abide by the terms of the Plan as well as the statements, agreements and/or representations
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`contained in the Approval Letter and pay the reasonable and customary bills for the
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`Reconstruction Procedures.
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`57.
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`Through the member appeals, Plaintiff Providers demanded that United comply
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`with the terms of the Plan by, inter alia, applying the FAIR Health data as the reasonable and
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`customary competitive fee for services provided such as the Reconstruction Procedures in the
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`applicable geographic area.
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`58.
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`In response to these appeals, United continued to deny its liability for the amount
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`of the Reconstruction Procedures and refused to perform in compliance with its prior agreement
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`to pay the reasonable and customary costs of the Reconstruction Procedures as per the terms of
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`the Approval Letter, including but not limited to a refusal to apply the applicable FAIR Health
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`competitive fee data for procedures similar to the Reconstruction Procedures.
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`59.
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`As such, United’s refusals to make sufficient payment for N.T.’s claims under the
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`term of the Plan are “adverse benefit determinations” under ERISA
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`60.
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`Further, as stated above, any administrative remedies that may be required to be
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`pursued under ERISA have, therefore, been exhausted, should be deemed exhausted under
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`applicable regulations, or would be futile under the circumstances, and are therefore excused and
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`Plaintiff Providers are permitted to now pursue remedies available under 29 U.S. C. A. 1132 on
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`behalf of N.T.
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`Count One – Claim for Plan Benefits Under 29 U.S.C. § 1132(a)(1)(B)
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`61.
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`Plaintiff Providers incorporate by reference all the allegations stated in Paragraphs
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`1-60 above.
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`62.
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`By failing to adequately pay benefits to Plaintiff Providers for serviced provided
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`to N.T., United violated obligations set forth in the Plan, and such refusal and/or lack of payment
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`was arbitrary, capricious and manifestly mistaken.
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`63.
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`Because N.T. is a beneficiary under the Plan, and because Plaintiff Providers are
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`N.T.’s assignee, authorized representative, and/or attorney-in-fact with respect to the benefit
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`claims herein at issue, Plaintiff Providers have standing to bring this cause of action on behalf of
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`N.T. under 29 U.S.C. § 1132(a)(1)(B) to enforce rights created by the Plan and to seek benefits
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`relating to services provided to N.T.
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`Count Two – Breach of Contract
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`64.
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`Plaintiff Providers incorporate by reference all the allegations stated in Paragraphs
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`1-63 above.
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`65.
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`As evidenced by the Approval Letter, prior to the Reconstruction Procedures,
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`United agreed that the Reconstruction Procedures were authorized and medically necessary.
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`66.
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`Through the preauthorization process, United and the Plaintiff Providers agreed
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`that the Reconstruction Procedures was both eligible and medically necessary.
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`67.
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`As evidenced by the Approval Letters, United authorized the Plaintiff Providers to
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`undertake the Reconstruction Procedure for N.T. with the agreement that United would provide
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`to the Plaintiff Providers the customary and reasonable compensation for such procedure.
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`68.
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`Consequently, in reliance on the agreement stated in the Approval Letters, a
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`meeting of the minds was reached between the Plaintiff Providers and United whereby United
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`agreed that the Plaintiff Providers would perform the Reconstruction Procedures for N.T. and
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`United would pay to the Plaintiff Providers the reasonable and customary fee for such
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`procedures.
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`69.
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`However, despite the fact that the Plaintiff Providers performed the
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`Reconstruction Procedures, United breached that agreement and refused to pay the reasonable
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`and customary fee for such procedures.
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`70.
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`Further, despite making the MARS Negotiated Resolution and the acceptance of
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`the terms thereof, United refused to comply and, thus, is in breach of the MARS Negotiated
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`Resolution.
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`71.
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`As a result of these breaches, the Plaintiff Providers incurred damages in an
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`amount to be shown at the trial of this matter. Specifically, the Plaintiff Providers were damaged
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`by the refusal of United to comply with its agreements, including but not limited to the MARS
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`Negotiated Resolution and/or to pay the reasonable and customary fee for the Reconstruction
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`Procedures.
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`72.
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`As a result of the breach of contract, United is liable to the Plaintiff Providers for
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`all damages in an amount to be shown at the trial of this matter.
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`Case 2:22-cv-02820-LMA-DMD Document 1 Filed 08/23/22 Page 14 of 15
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`Count Three – Detrimental Reliance
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`73.
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`Plaintiff Providers incorporate by reference all the allegations stated in Paragraphs
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`1-67 above.
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`74.
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`Through its conduct and/or word, including but not limited to the representations
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`stated in the Approval Letters, United represented to the Plaintiff Providers that the
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`Reconstruction Procedures were both eligible and medically necessary, that the Plaintiff
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`Providers were authorized to undertake the Reconstruction Procedures and that United would
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`pay the reasonable and customary fees for the Reconstruction Procedures.
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`75.
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`76.
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`The Plaintiff Providers justifiably relied on those representations by United,
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`The Plaintiff Providers changed their position to their detriment based on said
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`representations by, inter alia, undertaking the Reconstruction Procedures for N.T.
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`77.
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`As a result of the Plaintiff Providers’ justifiable reliance on said representations,
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`and their change in position based on said reliance, Plaintiff Providers have incurred damages in
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`the amount to be proven at the trial of this matter.
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`78.
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`United is liable to Plaintiff Providers for all damages incurred as a result of their
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`reliance on the representations of United outlined above, in an amount to be proven at the trial of
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`this matter.
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`Jury Demand
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`79.
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`Plaintiff Providers demand trial by jury as to all counts for which trial by jury is
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`available.
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`WHEREFORE, the Plaintiff Providers request that this Petition for Damages be deemed
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`good and sufficient and that United HealthCare Louisiana, Inc., be duly cited and served with
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`this Petition for Damages, and that after due proceedings are had there be judgment rendered
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`Case 2:22-cv-02820-LMA-DMD Document 1 Filed 08/23/22 Page 15 of 15
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`herein in favor of Plaintiff Providers and against United HealthCare Louisiana, Inc., on Plaintiff
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`Providers’ demands as follows:
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`A. Declaring that United violated its duties and obligations under the Plan by failing to
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`adequately pay benefits relating to the services provided by Plaintiff Providers to
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`N.T.;
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`B. Directing United to adequately pay benefits relating to the services provided by
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`Plaintiff Providers to N.T.;
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`C. Awarding Plaintiff Providers all damages to which they may be entitled, including
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`prejudgment interest under Louisiana law, attorneys’ fees pursuant to 29 U.S.C. §
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`1132(g)(1); costs pursuant to 29 U.S.C. § 1132(g)(1); ; and
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`D. Granting such other general and equitable relief as the nature of this case may permit.
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`Respectfully submitted,
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`____/s/ Thomas M. Beh_______________
`THOMAS M. BEH (# 24018)
`STEPHEN B. MURRAY,, Jr. (#27694)
`THE MURRAY LAW FIRM
`701 Poydras Street, Suite 4250
`New Orleans, LA 7019
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`Attorneys for Plaintiffs
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`PLEASE SERVE:
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`UNITED HEALTHCARE OF LOUISIANA, INC.
`Through its registered agent for service of process
`CT Corporation
`2867 Plaza Tower Drive
`Baton Rouge, LA 70816
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