State Farm Mutual Automobile Insurance Company et al v. Lewin, D.C. et al
| State Farm Fire and Casualty Company and State Farm Mutual Automobile Insurance Company |
| 1-800-411-Pain Referral Service, LLC, Nelson Vazquez, M.D., Ronald Golden, D.C., Frank Lassiter, D.C., Adam Lewis, D.C., Chintan Desai, M.D., Sarah Vleko, D.C., Ralph Marino, M.D., Donald Thomas III, M.D., Tie Qian, M.D., William Kurzbuch, D.C., Lisa Nerbonne, D.C., Joseph Sefick, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC, Dheeraj Manocha, D.C., Michael Wilensky, M.D., Brittany Chong, D.C., Robert Lewin, D.C., Roger Ramos, M.D., David Cheesman, D.O. and Kieron Parchment, D.C. |
| Jay M. Cohen |
| 8:2020cv02428 |
| October 16, 2020 |
| US District Court for the Middle District of Florida |
| Virginia M Hernandez Covington |
| Thomas G Wilson |
| Racketeer/Corrupt Organization |
| 18 U.S.C. § 1962 Racketeering (RICO) Act |
| Plaintiff |
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Filing 121
ENDORSED ORDER: Pursuant to the Stipulation of Dismissal with Prejudice (Doc. #120), this case is dismissed with prejudice and without costs. The Clerk is directed to close the case. Signed by Judge Virginia M. Hernandez Covington on 7/6/2022. (JW)
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| Filing 120 STIPULATION of Dismissal With Prejudice by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) |
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Filing 119
ENDORSED ORDER granting #118 Joint Motion for Extension of Stay. This case will remain stayed and administratively closed until August 1, 2022. On August 2, 2022 the Court will direct the Clerk to lift the stay and return this case to active status. Signed by Judge Virginia M. Hernandez Covington on 7/1/2022. (JW)
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| Filing 118 Joint MOTION for Miscellaneous Relief, specifically for Extension of Stay by All Plaintiffs. (Detzel, Christopher) |
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Filing 117
ENDORSED ORDER granting #116 Motion to Stay. This case will remain stayed and administratively closed until July 1, 2022. On July 5, 2022, the Clerk is directed to lift the stay and return this case to active status. Signed by Judge Virginia M. Hernandez Covington on 4/16/2022. (Covington, Virginia)
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| Filing 116 Joint MOTION to Stay (For Extension of Stay) by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) |
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Filing 115
ENDORSED ORDER: Granting the Joint Motion for 90-Day Extension of Stay. (Doc. #114). This case is stayed and administratively closed until April 18, 2022, at which time the case will be automatically reopened and returned to active status. Signed by Judge Virginia M. Hernandez Covington on 1/18/2022. (CTL)
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| Filing 114 Joint MOTION to Stay re 111 Order on Motion to Stay; Joint Motion for 90-Day Extension by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Purvis, Nicholas) |
| Filing 113 STATUS report (Joint) by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Purvis, Nicholas) |
| Filing 112 STATUS report Joint by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) |
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Filing 111
ENDORSED ORDER granting the Joint Motion to Stay Proceedings (Doc. #110) until January 11, 2022. The parties are directed to file a status report by November 12, 2021 regarding the status of Path Medical LLC's bankruptcy case. The parties are directed to file a status report by January 3, 2022 about the status of the bankruptcy and the parties' positions about when and whether the stay should be lifted. Absent further order by the Court, on January 11, 2022, the stay will be lifted and the dates in the CMSO will be extended by 120 days. This case is Stayed and Administratively Closed pending further order of the Court. The Clerk is directed to administratively close this case and stay deadlines entered by the Court. Signed by Judge Virginia M. Hernandez Covington on 9/14/2021. (KMH)
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| Filing 110 Joint MOTION to Stay re 107 Order by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) |
| Filing 109 NOTICE to counsel of filing of OFFICIAL TRANSCRIPT. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days. Any party needing a copy of the transcript to review for redaction purposes may purchase a copy from the court reporter or view the document at the clerk's office public terminal. Court Reporter: David Collier. (DJC) |
| Filing 108 TRANSCRIPT of motion hearing held on August 20, 2021 before Magistrate Judge Thomas G. Wilson. Transcriber David J. Collier, Telephone number (813) 301-5575. Transcript may be viewed at the court public terminal or purchased through the Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER or purchased through the Transcriber. Redaction Request due 9/22/2021 Redacted Transcript Deadline set for 10/4/2021 Release of Transcript Restriction set for 11/30/2021. (DJC) |
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Filing 107
ENDORSED ORDER: : On August 30, 2021, Defendant Path Medical LLC, filed a Suggestion of Bankruptcy (Doc. #105), which states that it filed a voluntary petition for relief under Chapter 11 of the United States Bankruptcy Code. The Court stayed the case only as to Path Medical LLC pending completion of the bankruptcy proceedings. However, if any of the Defendants wish to stay all proceedings pending completion of Path Medical LLC's bankruptcy, the Defendants should consult with each other and notify the Court in one filing by September 14, 2021. If Plaintiff objects to staying proceedings as to all Defendants, it must file an objection by September 21, 2021. Signed by Judge Virginia M. Hernandez Covington on 8/31/2021. (KMH)
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Filing 106
ORDER Pursuant to 11 U.S.C. 362(a), this case is STAYED as to Defendant Path Medical, LLC until the bankruptcy court lifts the stay or the stay is no longer in effect. The parties are directed to advise the Court when the bankruptcy proceedings have concluded. Signed by Judge Virginia M. Hernandez Covington on 8/31/2021. (KMH)
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| Filing 105 SUGGESTION of Bankruptcy by Path Medical, LLC. (Attachments: #1 Exhibit A)(Matthews, Michael) |
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Filing 104
ORDER denying without prejudice #102 plaintiffs' Motion for Michael J. Powers to Appear Pro Hac Vice. Signed by Magistrate Judge Thomas G. Wilson on 8/30/2021. (DMS)
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Filing 103
ORDER granting #101 1-800-411-PAIN Referral Service, LLC's Motion to Quash Non-Party Subpoena and Motion for Protective Order; quashing the subpoena duces tecum served upon Bank of America, N.A., dated July 30, 2021. Signed by Magistrate Judge Thomas G. Wilson on 8/30/2021. (DMS)
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| Filing 102 MOTION for Michael J. Powers to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-18636825 for $150 by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) Motions referred to Magistrate Judge Thomas G. Wilson. |
| Filing 101 MOTION to Quash Plaintiffs' Non-Party Subpoena and Motion for Protective Order by 1-800-411-Pain Referral Service, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Matthews, Michael) Motions referred to Magistrate Judge Thomas G. Wilson. |
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Filing 100
ORDER granting #96 Defendants' Motion for Protective Order Regarding Plaintiff's Non-Party Subpoena to Kevin Johnson; quashing subpoena. Signed by Magistrate Judge Thomas G. Wilson on 8/20/2021. (DMS)
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Filing 99
ORDER granting #86 Defendants' Motion for Protective Order; granting #87 Defendants' Joint Motion for Protective Order and to Join and Adopt; quashing subpoenas duces tecum served upon Path Medical Center Holdings, Inc., GreatBanc Trust Company, and Keefe, McCullough & Co., LLP. Signed by Magistrate Judge Thomas G. Wilson on 8/20/2021. (DMS)
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| Filing 98 Minute Entry. In-person proceedings held before Magistrate Judge Thomas G. Wilson: MOTION HEARING held on 8/20/2021 re #87 Defendants' Joint MOTION for Protective Order regarding Plaintiff's Non-Party Subpoenas, #86 Defendants' MOTION for Protective Order Regarding Non-Party Subpoenas. (DIGITAL) (DMS) |
| Filing 97 RESPONSE in Opposition re #96 MOTION for Protective Order Regarding Plaintiffs' Non-Party Subpoena to Kevin Johnson filed by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Attachments: #1 Exhibit 1 - AHCA - Licensing Application for Path Medical-Apex, #2 Exhibit 2 - May 5, 2021 Ramos Responses to First Interrogatories, #3 Exhibit 3 - Medical Director Contract, #4 Exhibit 4 - SFL Radiology Holdings, LLC Articles of Organization, #5 Exhibit 5 - South Florida Diagnostic Resources, LLC Articles of Organization, #6 Exhibit 6 - Path Investment Articles of Organization)(Spector, David) |
| Filing 96 MOTION for Protective Order Regarding Plaintiffs' Non-Party Subpoena to Kevin Johnson by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical, LLC. (Attachments: #1 Exhibit 1)(Lee, Heather) Motions referred to Magistrate Judge Thomas G. Wilson. |
| Filing 95 REPLY to Response to Motion re #80 MOTION to Dismiss Plaintiffs' First Amended Complaint (All Defendants) filed by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical, LLC. (Matthews, Michael) |
| Filing 94 NOTICE of HEARING: IN PERSON oral argument on the Motions for Protective Order Regarding Non-Party Subpoenas (Docs, 86, 87) is scheduled for 8/20/2021 at 2:30 PM in Tampa Courtroom 12A before Magistrate Judge Thomas G. Wilson. Belated submissions are disfavored. Any materials submitted after 4:00 p.m. on the day before the hearing will be disregarded.(MEM) |
| Filing 93 RESPONSE in Opposition re #86 MOTION for Protective Order Regarding Non-Party Subpoenas filed by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Attachments: #1 Exhibit 1 - 2015 Form 5500 for Path Medical Center Holdings, Inc., #2 Exhibit 2 - Defendant Ramos' Response to Interrogatories)(Spector, David) |
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Filing 92
ENDORSED ORDER: Defendants' Motion for Leave to File Combined Reply (Doc. #90) is granted in part. The Court notes Plaintiffs' opposition but finds allowing the reply appropriate. Accordingly, Defendants may file a combined reply, not to exceed a total of ten pages, in support of their motion to dismiss by August 2, 2021. Signed by Judge Virginia M. Hernandez Covington on 7/26/2021. (AR)
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| Filing 91 RESPONSE in Opposition re #90 Unopposed MOTION for Leave to File Other Document :Defendants' Motion for Leave to File Combined Reply in Support of their Motion to Dismiss (ALL DEFENDANTS) filed by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) |
| Filing 90 MOTION for Leave to File Other Document : Defendants' Motion for Leave to File Combined Reply in Support of their Motion to Dismiss (ALL DEFENDANTS) by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical, LLC. (Matthews, Michael) Modified on 7/22/2021 to edit text (CRH). |
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Filing 89
ENDORSED ORDER: Although the Court's Case Management and Scheduling Order (Doc. #42) provides for a fourteen-day deadline to respond to motions for summary judgment (Id. at 6), under the new Local Rules, parties have twenty-one days to respond to a "motion to dismiss, for judgment on the pleadings, for summary judgment, to exclude or limit expert testimony, to certify a class, for a new trial, or to alter or amend the judgment." Local Rule 3.01(c), M.D. Fla. Additionally, under the new Local Rules, parties have an automatic right to file a reply in support of a motion for summary judgment. Local Rule 3.01(d), M.D. Fla. Accordingly, the Court clarifies that a party is permitted to respond to any of the aforementioned motions within twenty-one days after service of the motion, and that a party is permitted to file a reply in support of its motion for summary judgment. Signed by Judge Virginia M. Hernandez Covington on 7/20/2021. (AR)
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| Filing 88 RESPONSE in Opposition re #80 MOTION to Dismiss Plaintiffs' First Amended Complaint (ALL DEFENDANTS) filed by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Attachments: #1 Exhibit 1 - Declaration of John Lepore, #2 Exhibit 1A - Exhibit A to Declaration, #3 Exhibit 1B - Exhibit B to Declaration, #4 Exhibit 1C - Exhibit C to Declaration, #5 Exhibit 2 - Administrative Complaint against Absolute Care Imaging, #6 Exhibit 3 - Administrative Complaint against Florida Injury Longwood)(Spector, David) |
| Filing 87 Joint MOTION for Protective Order regarding Plaintiff's Non-Party Subpoenas, Joint MOTION for Joinder and Adoption of Defendants Robert Lewin, D.C.'S, 1-800-411-PAIN Referral Service, LLC's, and Path Medical, LLC's Motion for Protective Order Regarding Plaintiffs' Non-Party Subpoenas by David Cheesman, D.O., Brittany Chong, D.C., Chintan Desai, M.D., Ronald Golden, D.C., William Kurzbuch, D.C., Frank Lassiter, D.C., Adam Lewis, D.C., Dheeraj Manocha, D.C., Ralph Marino, M.D., Lisa Nerbonne, D.C., Kieron Parchment, D.C., Tie Qian, M.D., Roger Ramos, M.D., Joseph Sefick, D.C., Donald Thomas III, M.D., Nelson Vazquez, M.D., Sarah Vleko, D.C., Michael Wilensky, M.D. (Sisco, Dale) Motions referred to Magistrate Judge Thomas G. Wilson. |
| Filing 86 MOTION for Protective Order Regarding Non-Party Subpoenas by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)(Lee, Heather) Motions referred to Magistrate Judge Thomas G. Wilson. |
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Filing 85
ENDORSED ORDER: Plaintiffs' unopposed Motion for Extension of Time (Doc. #83) is granted in part. The Court acknowledges that Plaintiffs seek a nineteen day extension. However, the new Local Rules already provide for twenty-one days to respond to a motion to dismiss, as opposed to the previous fourteen days. Therefore, the Court finds an extension of ten days sufficient at this juncture. Plaintiffs' response to Defendants' motion to dismiss is now due by July 19, 2021. Signed by Judge Virginia M. Hernandez Covington on 6/25/2021. (AR)
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Filing 84
ORDER granting #82 defendants' Motion to Withdraw as Attorney. Attorney Emily Anna Beer terminated. Signed by Magistrate Judge Thomas G. Wilson on 6/23/2021. (DMS)
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| Filing 83 Unopposed MOTION for Extension of Time to File Response/Reply as to #80 MOTION to Dismiss Plaintiffs' First Amended Complaint (All Defendants) by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) |
| Filing 82 Unopposed MOTION for Emily A. Beer to Withdraw as Attorney by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical, LLC. (Beer, Emily) Motions referred to Magistrate Judge Thomas G. Wilson. |
| Filing 81 DECLARATION of Maureen M. Stewart re #80 MOTION to Dismiss Plaintiffs' First Amended Complaint (All Defendants) by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Matthews, Michael) |
| Filing 80 MOTION to Dismiss Plaintiffs' First Amended Complaint (All Defendants) by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical, LLC. (Matthews, Michael) |
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Filing 79
ENDORSED ORDER: Defendants' unopposed Motion for Extension of Time (Doc. #78) is granted. Defendants' responses to the amended complaint are now due by June 18, 2021. Signed by Judge Virginia M. Hernandez Covington on 5/24/2021. (AR)
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| Filing 78 Unopposed MOTION for Extension of Time to File Response/Reply as to #77 Amended Complaint by All Defendants. (Matthews, Michael) |
| Filing 77 AMENDED COMPLAINT against David Cheesman, D.O., Brittany Chong, D.C., Chintan Desai, M.D., Ronald Golden, D.C., William Kurzbuch, D.C., Frank Lassiter, D.C., Robert Lewin, D.C., Adam Lewis, D.C., Dheeraj Manocha, D.C., Ralph Marino, M.D., Lisa Nerbonne, D.C., Kieron Parchment, D.C., Path Medical, LLC, Tie Qian, M.D., Roger Ramos, M.D., Joseph Sefick, D.C., Donald Thomas III, M.D., Nelson Vazquez, M.D., Sarah Vleko, D.C., Michael Wilensky, M.D. with Jury Demand. filed by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Attachments: #1 Exhibit 1 - Treatment Appendix, #2 Exhibit 2 - Absolute Final Order and Settlement Agreement, #3 Exhibit 3 - Chinaris Letter, #4 Exhibit 4 - 411 Trademark Assignments, #5 Exhibit 5 - Letter to AHCA, #6 Exhibit 6 - 1-800-671-HURT, #7 Exhibit 7 - Hurt Burt, #8 Exhibit 8 - Call From Home, Hospital or Accident Scene, #9 Exhibit 9 - After 911, call 411, #10 Exhibit 10 - 411PAIN website - FAQ's, #11 Exhibit 11 - 411 Chiro Advertising Agreement, #12 Exhibit 12 - R. Sitner Deposition excerpts, #13 Exhibit 13 - 411 Vanity Numbers, #14 Exhibit 14 - Path411pain website, #15 Exhibit 15 - Miami New Times Article, #16 Exhibit 16 - 411 Florida Bar Hearing Transcript, #17 Exhibit 17 - Letters to Florida Bar, #18 Exhibit 18 - 411PAIN website - Auto Accident, #19 Exhibit 19 - M.A. EUO, #20 Exhibit 20 - A.C. EUO, #21 Exhibit 21 - N.J. EUO, #22 Exhibit 22 - Standard Disclosure and Acknowledgment Forms, #23 Exhibit 23 - Initial Exam Reports and Bills, #24 Exhibit 24 - Physician Initial Exam Reports and Bills, #25 Exhibit 25 - Representative Examples of EMC Notices, #26 Exhibit 26 - J.E.M. Initial Exam, #27 Exhibit 27 - K.M. Initial Exam, #28 Exhibit 28 - J.E.M. Bill dated June 9, 2017, #29 Exhibit 29 - J.E.M. Daily Note, #30 Exhibit 30 - M.A. Bill dated December 15, 2017, #31 Exhibit 31 - M.A. Daily Note, #32 Exhibit 32 - Representative Examples of Daily Notes and Bills, #33 Exhibit 33 - E.B.A. Sample Records, #34 Exhibit 34 - J.G.O. Sample Records, #35 Exhibit 35 - B.H.P. Sample Records, #36 Exhibit 36 - D.F. Sample Records, #37 Exhibit 37 - M.M.B. MRI Reports and Bills, #38 Exhibit 38 - P.C.A. MRI Reports and Bills, #39 Exhibit 39 - D.S. MRI Reports and Bills, #40 Exhibit 40 - Path MRI AHCA Application, #41 Exhibit 41 - Path MRI Reports and Bills, #42 Exhibit 42 - Re-Exam Reports and Bills, #43 Exhibit 43 - Final Exam Reports and Bills, #44 Exhibit 44 - R.A. Final Exam Report, #45 Exhibit 45 - G.E.L. Final Exam Report)(Spector, David) |
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Filing 76
ORDER denying #34 Defendant's Motion to Disqualify Holland & Knight. Signed by Magistrate Judge Thomas G. Wilson on 4/30/2021. (DMS)
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Filing 75
ENDORSED ORDER: Plaintiffs' unopposed Motion for Extension of Time (Doc. #74) is granted. Plaintiffs' amended complaint is now due by May 18, 2021. Signed by Judge Virginia M. Hernandez Covington on 4/29/2021. (AR)
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| Filing 74 Unopposed MOTION for Extension of Time to Amend Complaint by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Purvis, Nicholas) |
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Filing 73
ORDER: Defendants' Motion to Dismiss (Doc. #32) and Motion to Dismiss and to Join and Adopt Motion to Dismiss (Doc. #33) are granted in part and denied in part. The complaint is dismissed without prejudice as to Path Medical Center Holdings, Inc. Counts I and V are dismissed without prejudice as to all other Defendants. Plaintiffs may file an amended complaint by May 4, 2021. Signed by Judge Virginia M. Hernandez Covington on 4/20/2021. (AR)
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Filing 72
ORDER denying as moot #70 defendant Chintan Desai, M.D.'s Motion to Seal Under Stipulated Protective Order. Signed by Magistrate Judge Thomas G. Wilson on 4/19/2021. (DMS)
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| Filing 71 RESPONSE in Opposition re #70 MOTION to Seal Under Stipulated Protective Order filed by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Attachments: #1 Exhibit A - Conflict Report)(Purvis, Nicholas) |
| Filing 70 MOTION to Seal Under Stipulated Protective Order by Chintan Desai, M.D. (Sisco, Dale) |
| Filing 69 Minute Entry. In-person proceedings held before Magistrate Judge Thomas G. Wilson: MOTION HEARING held on 4/12/2021 re #34 MOTION to Disqualify Counsel filed by Chintan Desai, M.D. (DIGITAL) (DMS) |
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Filing 68
Stipulated Protective Order. Signed by Magistrate Judge Thomas G. Wilson on 4/9/2021. (DMS)
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Filing 67
ORDER granting #63 Joint Consent Motion for the Entry of a Protective Order. The Clerk is directed to docket the confidentiality agreement attached at Doc. 63-1. Signed by Magistrate Judge Thomas G. Wilson on 4/9/2021. (DMS)
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Filing 66
ORDER denying #65 Defendant Chintan Desai, M.D.'s Second Motion to Continue Hearing on Defendant's Motion to Disqualify Holland & Knight. Signed by Magistrate Judge Thomas G. Wilson on 4/9/2021. (DMS)
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| Filing 65 Second MOTION to Continue Hearing on Defendant's Motion to Disqualify by Chintan Desai, M.D. (Isgro, Dominic) |
| Filing 64 STIPULATION re #63 Joint MOTION for Protective Order and Incorporated Memorandum of Law Proposed ESI Agreement by 1-800-411-Pain Referral Service, LLC, David Cheesman, D.O., Brittany Chong, D.C., Jay M. Cohen, Chintan Desai, M.D., Ronald Golden, D.C., William Kurzbuch, D.C., Frank Lassiter, D.C., Robert Lewin, D.C., Adam Lewis, D.C., Dheeraj Manocha, D.C., Ralph Marino, M.D., Lisa Nerbonne, D.C., Kieron Parchment, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC, Tie Qian, M.D., Roger Ramos, M.D., Joseph Sefick, D.C., Donald Thomas III, M.D., Nelson Vazquez, M.D., Sarah Vleko, D.C., Michael Wilensky, M.D. (Matthews, Michael) |
| Filing 63 Joint MOTION for Protective Order and Incorporated Memorandum of Law by 1-800-411-Pain Referral Service, LLC, David Cheesman, D.O., Brittany Chong, D.C., Jay M. Cohen, Chintan Desai, M.D., Ronald Golden, D.C., William Kurzbuch, D.C., Frank Lassiter, D.C., Robert Lewin, D.C., Adam Lewis, D.C., Dheeraj Manocha, D.C., Ralph Marino, M.D., Lisa Nerbonne, D.C., Kieron Parchment, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC, Tie Qian, M.D., Roger Ramos, M.D., Joseph Sefick, D.C., Donald Thomas III, M.D., Nelson Vazquez, M.D., Sarah Vleko, D.C., Michael Wilensky, M.D. (Attachments: #1 Exhibit Proposed Protective Order)(Matthews, Michael) Motions referred to Magistrate Judge Thomas G. Wilson. |
| Filing 62 NOTICE of Appearance by Maureen Mathis Stewart on behalf of 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC. (Stewart, Maureen) |
| Filing 61 NOTICE OF RESCHEDULING HEARING: The motion hearing previously scheduled for 4/6/2021 at 2:30 p.m. is rescheduled. New scheduling date and time: Motion Hearing on #34 Defendant Desai's Motion to Disqualify Holland & Knight set for 4/12/2021 at 02:30 PM in Tampa Courtroom 12A before Magistrate Judge Thomas G. Wilson. (DMS) |
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Filing 60
ORDER granting #59 Defendant Desai's Unopposed Motion to Continue Hearing on Defendant's Motion to Disqualify Holland & Knight. Signed by Magistrate Judge Thomas G. Wilson on 3/29/2021. (DMS)
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| Filing 59 Unopposed MOTION to Continue Hearing on Motion to Disqualify by Chintan Desai, M.D. (Sisco, Dale) |
| Filing 58 NOTICE of HEARING: Oral argument on the Motion to Disqualify Counsel (Doc. 34) is SCHEDULED for 4/6/2021 at 2:30 PM in Tampa Courtroom 12 A before Magistrate Judge Thomas G. Wilson. Belated submissions are disfavored. Any materials submitted after 4:00 p.m. on the day before the hearing will be disregarded.(MEM) |
| Filing 57 REPLY to Response to Motion re #32 MOTION to Dismiss Complaint and Memorandum of Law, #33 Joint MOTION to Dismiss Plaintiffs' Complaint, Joint MOTION for Joinder to and Adoption of "Defendants Robert Lewin, D.C.'S, 1-800-411-PAIN Referral Service, LLC'S, Path Medical, LLC'S, and Path Medical Center Holdings, Inc.'s Motion to Dismiss Complaint and Memorandum of Law" (ALL DEFENDANTS) filed by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC. (Matthews, Michael) |
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Filing 56
ENDORSED ORDER: Defendants' unopposed Motion for Leave to File 10-Page Combined Reply (Doc. #55) is granted. The Defendants may file a reply, not to exceed ten pages, by February 24, 2021. Signed by Judge Virginia M. Hernandez Covington on 2/10/2021. (AR)
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| Filing 55 Unopposed MOTION for Leave to File Other Document :Defendants' Motion for Leave to File 10-Page Combined Reply in Support of Their Motions to Dismiss (All Defendants) by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC. (Matthews, Michael) |
| Filing 54 RESPONSE in Opposition re #32 MOTION to Dismiss Complaint and Memorandum of Law, #33 Joint MOTION to Dismiss Plaintiffs' Complaint Joint MOTION for Joinder to and Adoption of "Defendants Robert Lewin, D.C.'S, 1-800-411-PAIN Referral Service, LLC'S, Path Medical, LLC'S, and Path Medical Center Holdings, Inc.'s Motion to Dismiss Complaint and Memorandum o filed by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Detzel, Christopher) |
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Filing 53
ORDER appointing Jay M. Cohen, Esq. as mediator in this action. The mediation conference is scheduled for March 22, 2022, at 10:00 AM. The Court directs that all counsel, parties, corporate representatives, and any other required claims professionals shall be present at the mediation conference with full authority to negotiate a settlement. The Court does not allow mediation by telephone or video conference. Personal attendance is required. Signed by Judge Virginia M. Hernandez Covington on 2/5/2021. (AR)
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| Filing 52 RESPONSE in Opposition re #34 MOTION to Disqualify Counsel filed by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Attachments: #1 Exhibit 1 - Affidavit of Jason Baruch, #2 Exhibit 1A - 8/6/2017 Hyde Park Engagement, #3 Exhibit 1B - 11/1/2019 Engagement Letter to Chintan Desai, #4 Exhibit 1C - 11/12/2019 Desai Signed Engagement, #5 Exhibit 1D - 10/19/2020 email re: Radiology Imaging Specialists, #6 Exhibit 2 - Affidavit of David Lisko, #7 Exhibit 2A - 11/1/2019 Engagement Letter to Chintan Desai, #8 Exhibit 2B - 11/12/2019 Desai Signed Engagement, #9 Exhibit 2C - 10/19/2020 email re: Radiology Imaging Specialists, #10 Exhibit 3 - 11/12/2019 email from Dasai re Radiology Imaging Specialists)(Purvis, Nicholas) |
| Filing 51 NOTICE of mediation conference/hearing to be held on March 22, 2022 at 10:00 a.m. before Jay M. Cohen, Esq. (Spector, David) |
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Filing 50
STANDING ORDER regarding discovery motions. Signed by Magistrate Judge Thomas G. Wilson on 2/1/2021. (DMS)
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| Filing 49 NOTICE of Appearance by Emily Anna Beer on behalf of 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC. (Beer, Emily) |
| Filing 48 Minute Entry. In-person proceedings held before Magistrate Judge Thomas G. Wilson: Discovery Hearing held on 1/26/2021. (DIGITAL) (DMS) |
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Filing 47
ORDER granting #46 Plaintiffs' Unopposed Motion for Extension of Time to Respond to #34 Defendant Chintan Desai, M.D.'s MOTION to Disqualify Counsel. Response due by 2/4/2021. Signed by Magistrate Judge Thomas G. Wilson on 1/19/2021. (DMS)
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| Filing 46 Unopposed MOTION for Extension of Time to File Response/Reply as to #34 MOTION to Disqualify Counsel by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) |
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Filing 45
ENDORSED ORDER: Plaintiffs State Farm Mutual Automobile Insurance Company and State Farm Fire and Casualty Company's unopposed Motion for Leave to Exceed Page Limitation and for Extension of Time (Doc. #44) is granted. Plaintiffs' response to Defendants' Motions to Dismiss (Doc. # #32; #33) is now due February 5, 2021. The page limit for the response is enlarged to thirty pages. Signed by Judge Virginia M. Hernandez Covington on 1/14/2021. (AR)
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| Filing 44 Unopposed MOTION for Extension of Time to File Response to Defendants' Motions to Dismiss Complaint , Unopposed MOTION to File Excess Pages by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) |
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Filing 43
ORDER regarding motions for summary judgment. See Order for details. Signed by Judge Virginia M. Hernandez Covington on 1/13/2021. (TWL)
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Filing 42
CASE MANAGEMENT AND SCHEDULING ORDER: Final Pretrial Conference set for 8/11/2022 at 9:00 AM in Tampa Courtroom 14 B before Judge Virginia M. Hernandez Covington, Jury trial set for the September 2022 trial term in Tampa Courtroom 14 B before Judge Virginia M. Hernandez Covington, Conduct mediation hearing by 3/22/2022. Lead counsel to coordinate dates. Signed by Judge Virginia M. Hernandez Covington on 1/13/2021. (TWL)
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| Filing 41 Minute Entry. Virtual Proceedings held before Judge Virginia M. Hernandez Covington: SCHEDULING CONFERENCE held on 1/13/2021. Court Reporter: Rebekah Lockwood (TWL) |
| Filing 40 NOTICE OF RESCHEDULING HEARING (TIME ONLY): The discovery conference hearing previously scheduled for 01/26/21 at 02:00 PM is rescheduled for 02:30 PM in Tampa Courtroom 12 A before Magistrate Judge Thomas G. Wilson. (KLS) |
| Filing 39 NOTICE of hearing: Discovery conference set for 1/26/2021 at 02:00 PM in Tampa Courtroom 12 A before Magistrate Judge Thomas G. Wilson. (KLS) |
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Filing 38
ENDORSED ORDER: For the reasons stated at the January 13, 2021, case management hearing, the Court has determined that it would be helpful for the parties to participate in a discovery conference with United States Magistrate Judge Thomas G. Wilson. Accordingly, the Court requests that Judge Wilson set this case for a discovery conference at his convenience. Signed by Judge Virginia M. Hernandez Covington on 1/13/2021. (AR)
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Filing 37
ENDORSED ORDER: For the reasons stated at the January 13, 2021, case management hearing, the Motion to Stay Discovery (Doc. #28) is denied. Signed by Judge Virginia M. Hernandez Covington on 1/13/2021. (AR)
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Filing 36
AMENDED ENDORSED ORDER: Defendant Chintan Desai, M.D.'s Motion to Disqualify Counsel (Doc. #34) is hereby referred to the Honorable Thomas G. Wilson, United States Magistrate Judge, for disposition, including any hearings, motions, and deadlines related thereto. Signed by Judge Virginia M. Hernandez Covington on 1/12/2021. (AR) Motions referred to Magistrate Judge Thomas G. Wilson.
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Filing 35
ENDORSED ORDER: Defendant Chintan Desai, M.D.'s Motion to Disqualify Counsel (Doc. #34) is hereby referred to the Honorable Thomas G. Wilson, United States Magistrate Judge, for the issuance of a report and recommendation, including any hearings, motions, and deadlines related thereto. Signed by Judge Virginia M. Hernandez Covington on 1/11/2021. (AR) Motions referred to Magistrate Judge Thomas G. Wilson.
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| Filing 34 MOTION to Disqualify Counsel by Chintan Desai, M.D.. (Attachments: #1 Exhibit A)(Sisco, Dale) |
| Filing 33 Joint MOTION to Dismiss Plaintiffs' Complaint , Joint MOTION for Joinder to and Adoption of "Defendants Robert Lewin, D.C.'S, 1-800-411-PAIN Referral Service, LLC'S, Path Medical, LLC'S, and Path Medical Center Holdings, Inc.'s Motion to Dismiss Complaint and Memorandum of Law" by David Cheesman, D.O., Brittany Chong, D.C., Chintan Desai, M.D., Ronald Golden, D.C., William Kurzbuch, D.C., Frank Lassiter, D.C., Adam Lewis, D.C., Dheeraj Manocha, D.C., Ralph Marino, M.D., Lisa Nerbonne, D.C., Kieron Parchment, D.C., Tie Qian, M.D., Roger Ramos, M.D., Joseph Sefick, D.C., Donald Thomas III, M.D., Nelson Vazquez, M.D., Sarah Vleko, D.C., Michael Wilensky, M.D.. (Sisco, Dale) |
| Filing 32 MOTION to Dismiss Complaint and Memorandum of Law by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC. (Matthews, Michael) |
| Filing 31 RETURN of service executed on November 5, 2020 by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company as to 1-800-411-Pain Referral Service, LLC. (Spector, David) |
| Filing 30 NOTICE of hearing: Case Management Hearing set for 1/13/2021 at 11:00 AM. This hearing will be conducted via Zoom video conference before Judge Virginia M. Hernandez Covington. The Clerk will be sending an invitation to the meeting via email. If you have any questions please contact courtroom deputy, Tamecika Lee, at Tamecika_Lee@flmd.uscourts.gov. Although the hearing is taking place by video, all parties should dress appropriately for this Court proceeding. Furthermore, the parties are hereby reminded that under Local Rule 4.11(b) the taking of photographs, the operation of recording or transmission devices, and the broadcasting or televising of proceedings in any courtroom or hearing room of this Court, or the environs thereof, either while the Court is in session or at recesses between sessions when Court officials, lawyers, jurors, witnesses or other persons connected with judicial proceedings of any kind are present, are prohibited.(TWL) |
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Filing 29
ENDORSED ORDER: Plaintiffs filed this case on October 16, 2020. (Doc. #1). Based on the Court's review of the docket, Plaintiffs have not yet filed proof of service with regard to Defendant 1-800-411-Pain Referral Services, LLC. Accordingly, Plaintiffs are directed to file a status report by January 11, 2021, regarding their efforts to effect service of process upon 1-800-411-Pain. If 1-800-411-Pain has already been served, Plaintiffs are reminded of the Court's October 22, 2020, Order directing Plaintiffs to file proof of service as soon as it has been effected. (Doc. #6). Signed by Judge Virginia M. Hernandez Covington on 1/6/2021. (AR)
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| Filing 28 MOTION to Stay Discovery pending decision on motion to dismiss by All Defendants. (Lee, Heather) |
| Filing 27 CASE MANAGEMENT REPORT. (Spector, David) |
| Filing 26 NOTICE of Appearance by Lisa M. Noller on behalf of 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC. (Noller, Lisa) |
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Filing 25
ORDER granting #24 Motion for Lisa M. Noller to Appear Pro Hac Vice on behalf of defendants Robert Lewin D.C., 1-800-411-Pain Referral Service, LLC, Path Medical, LLC, and Path Medical Center Holdings, Inc. Signed by Magistrate Judge Thomas G. Wilson on 12/9/2020. (DMS)
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| Filing 24 MOTION for Lisa M. Noller to appear pro hac vice, Special Admission fee paid, Receipt No. 113A-17633142 for $150 by 1-800-411-Pain Referral Service, LLC, Robert Lewin, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC. (Matthews, Michael) Motions referred to Magistrate Judge Thomas G. Wilson. |
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Filing 23
ENDORSED ORDER: Defendants' unopposed Motion for Extension of Time (Doc. #22) is granted. Defendants' response to the Complaint is now due January 8, 2021. Signed by Judge Virginia M. Hernandez Covington on 11/12/2020. (AR) Modified on 11/12/2020 (AR).
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| Filing 22 Unopposed MOTION for Extension of Time to File Response/Reply as to #1 Complaint by Path Medical Center Holdings, Inc., Path Medical, LLC. (Matthews, Michael) |
| Filing 21 CORPORATE Disclosure Statement by Path Medical Center Holdings, Inc., Path Medical, LLC. (Matthews, Michael) |
| Filing 20 NOTICE of Appearance by Heather Anne Lee on behalf of Path Medical Center Holdings, Inc., Path Medical, LLC. (Lee, Heather) |
| Filing 19 NOTICE of Appearance by Michael P. Matthews on behalf of Path Medical Center Holdings, Inc., Path Medical, LLC. (Matthews, Michael) |
| Filing 18 NOTICE of pendency of related cases re #5 Related case order and track 2 notice per Local Rule 1.04(d) by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. Related case(s): No (Spector, David) |
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Filing 17
ENDORSED ORDER: Counsel are directed to meet and confer, in person or by telephone, and by January 4, 2021, file a completed Case Management Report. This document can be found on Judge Covington's page of the Court's website at www.flmd.uscourts.gov. Please be advised that the Court's Case Management Report form is different from those used by other judges. Local Rule 3.05(c)(2)(E), M.D. Fla., explains that most track two cases, like the present case, "will be tried within one year after the filing of the complaint." To accomplish this goal, the Court believes that six to eight months is a sufficient period of time to conduct discovery. If the parties believe that more time than eight months will be needed to complete discovery, the parties should provide the Court with a detailed explanation as to why additional time is needed and a timeline for the discovery that is planned. The Court will then determine whether a Case Management Hearing is necessary before entry of a Case Management and Scheduling Order. Signed by Judge Virginia M. Hernandez Covington on 11/4/2020. (AR)
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| Filing 16 WAIVER of service returned executed on November 3, 2020 by Roger Ramos, M.D., Lisa Nerbonne, D.C., David Cheesman, D.O., William Kurzbuch, D.C., Kieron Parchment, D.C., Frank Lassiter, D.C., Nelson Vazquez, M.D., Joseph Sefick, D.C., Ronald Golden, D.C., Ralph Marino, M.D., Donald Thomas III, M.D., Michael Wilensky, M.D., Brittany Chong, D.C., Dheeraj Manocha, D.C., Chintan Desai, M.D., Sarah Vleko, D.C., Adam Lewis, D.C., Tie Qian, M.D. as to Roger Ramos, M.D., Lisa Nerbonne, D.C., David Cheesman, D.O., William Kurzbuch, D.C., Kieron Parchment, D.C., Frank Lassiter, D.C., Nelson Vazquez, M.D., Joseph Sefick, D.C., Ronald Golden, D.C., Ralph Marino, M.D., Donald Thomas III, M.D., Michael Wilensky, M.D., Brittany Chong, D.C., Dheeraj Manocha, D.C., Chintan Desai, M.D., Sarah Vleko, D.C., Adam Lewis, D.C., Tie Qian, M.D.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18)(Sisco, Dale) |
| Filing 15 NOTICE of Appearance by Dale R. Sisco on behalf of David Cheesman, D.O., Brittany Chong, D.C., Chintan Desai, M.D., Ronald Golden, D.C., William Kurzbuch, D.C., Frank Lassiter, D.C., Adam Lewis, D.C., Dheeraj Manocha, D.C., Ralph Marino, M.D., Lisa Nerbonne, D.C., Kieron Parchment, D.C., Tie Qian, M.D., Roger Ramos, M.D., Joseph Sefick, D.C., Donald Thomas III, M.D., Nelson Vazquez, M.D., Sarah Vleko, D.C., Michael Wilensky, M.D. (Sisco, Dale) |
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Filing 14
ORDER granting #8 Plaintiffs' Motion for Ross O. Silverman to Appear Pro Hac Vice; granting #9 Plaintiffs' Motion for John W. Reale to Appear Pro Hac Vice; granting #10 Plaintiffs' Motion for Eric T. Gortner to Appear Pro Hac Vice; granting #11 Plaintiffs' Motion for John T. Lepore to Appear Pro Hac Vice. Signed by Magistrate Judge Thomas G. Wilson on 11/2/2020. (DMS)
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| Filing 13 RETURN of service executed on October 22, 2020 by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company as to Path Medical Center Holdings, Inc.. (Spector, David) |
| Filing 12 RETURN of service executed on October 22, 2020 by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company as to Path Medical, LLC. (Spector, David) |
| Filing 11 MOTION for John T. Lepore to appear pro hac vice, Special Admission fee paid, Receipt No. 113A-17495367 for $150 by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) Motions referred to Magistrate Judge Thomas G. Wilson. |
| Filing 10 MOTION for Eric T. Gortner to appear pro hac vice, Special Admission fee paid, Receipt No. 113A-17495345 for $150 by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) Motions referred to Magistrate Judge Thomas G. Wilson. |
| Filing 9 MOTION for John W. Reale to appear pro hac vice, Special Admission fee paid, Receipt No. 113A-17495301 for $150 by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) Motions referred to Magistrate Judge Thomas G. Wilson. |
| Filing 8 MOTION for Ross O. Silverman to appear pro hac vice, Special Admission fee paid, Receipt No. 113A-17495224 for $150 by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) Motions referred to Magistrate Judge Thomas G. Wilson. |
| Filing 7 CORPORATE Disclosure Statement by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Spector, David) |
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Filing 6
ORDER: Plaintiff is directed to effect service of process as required by Rule 4, Fed. R. Civ. P., and file proof thereof with the Court as soon as service has been effected. See Order for details. Signed by Judge Virginia M. Hernandez Covington on 10/22/2020. (TWL)
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Filing 5
RELATED CASE ORDER AND NOTICE of designation under Local Rule 3.05 - track 2. Signed by Judge Virginia M. Hernandez Covington on 10/22/2020. (TWL)
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| Filing 4 SUMMONS issued as to State Farm Fire and Casualty Company and State Farm Mutual Automobile Insurance Company. (JLD) |
| Filing 3 NOTICE to counsel Ross O. Silverman, Eric T. Gortner, John W. Reale, and John T. Lepore of Local Rule 2.02, Special Admission to Practice - Pay the $150.00 Special Admission Fee; Complete the E-Filer Registration Form to obtain a login and password for CM/ECF; Local counsel must electronically file a Motion to appear Pro Hac Vice on behalf of the non-resident attorney. (Signed by Deputy Clerk) (JLD) |
| Filing 2 NEW CASE ASSIGNED to Judge Virginia M. Hernandez Covington and Magistrate Judge Thomas G. Wilson. New case number: 8:20-cv-2428-T-33TGW. (SJB) |
| Filing 1 COMPLAINT against 1-800-411-Pain Referral Service, LLC, David Cheesman, D.O., Brittany Chong, D.C., Chintan Desai, M.D., Ronald Golden, D.C., William Kurzbuch, D.C., Frank Lassiter, D.C., Robert Lewin, D.C., Adam Lewis, D.C., Dheeraj Manocha, D.C., Ralph Marino, M.D., Lisa Nerbonne, D.C., Kieron Parchment, D.C., Path Medical Center Holdings, Inc., Path Medical, LLC, Tie Qian, M.D., Roger Ramos, M.D., Joseph Sefick, D.C., Donald Thomas III, M.D., Nelson Vazquez, M.D., Sarah Vleko, D.C., Michael Wilensky, M.D. with Jury Demand (Filing fee $ 400 receipt number 113A-17437630) filed by State Farm Fire and Casualty Company, State Farm Mutual Automobile Insurance Company. (Attachments: #1 Exhibit 1 - Treatment Appendix, #2 Exhibit 2 - Absolute Final Order, #3 Exhibit 3 - Chinaris Letter, #4 Exhibit 4 - PATH411-PAIN Hompage, #5 Exhibit 5 - 411 Trademark Assignments, #6 Exhibit 6 - 1-800-671-HURT, #7 Exhibit 7 - Hurt Burt, #8 Exhibit 8 - Call from Home, Hospital or Accident Scene, #9 Exhibit 9 - After 911, call 411, #10 Exhibit 10 - 411 PAIN website - FAQs, #11 Exhibit 11 - 411 Chiro Advertising Agreement, #12 Exhibit 12 - R. Sitner Deposition excerpts, #13 Exhibit 13 - 411 Vanity Numbers, #14 Exhibit 14 - April 2018 411 Pain Annual Report, #15 Exhibit 15 - June 2020 PATH Annual Report, #16 Exhibit 16 - 411PAIN website - Auto Accident, #17 Exhibit 17 - M.A. EUO, #18 Exhibit 18 - A.C. EUO, #19 Exhibit 19 - N.J. EUO, #20 Exhibit 20 - Standard Disclosure and Acknowledgment Forms, #21 Exhibit 21 - Initial Exam Reports and Bills, #22 Exhibit 22 - Physician Initial Exam Reports and Bills, #23 Exhibit 23 - Examples of EMC Notices, #24 Exhibit 24 - J.E.M. Initial Exam, #25 Exhibit 25 - K.M. Initial Exam, #26 Exhibit 26 - J.E.M. bill dated June 9, 2017, #27 Exhibit 27 - J.E.M. Daily Note dated June 9, 2017, #28 Exhibit 28 - M.A. Bill dated December 15, 2017, #29 Exhibit 29 - M.A. Daily Note dated December 15, 2017, #30 Exhibit 30 - Examples of Daily Notes and Bills, #31 Exhibit 31 - E.B.A. Sample Records, #32 Exhibit 32 - J.G.O. Sample Records, #33 Exhibit 33 - B.H.P. Sample Records, #34 Exhibit 34 - D.F. Sample Records, #35 Exhibit 35 - M.M.B. MRI Reports and Bills, #36 Exhibit 36 - P.C.A. MRI Reports and Bills, #37 Exhibit 37 - D.S. MRI Reports and Bills, #38 Exhibit 38 - Path MRI AHCA Application, #39 Exhibit 39 - Path MRI Reports and Bills, #40 Exhibit 40 - Re-Exam Reports and Bills, #41 Exhibit 41 - Final Exam Reports and Bills, #42 Exhibit 42 - R.A. Final Exam Report, #43 Exhibit 43 - G.E.L. Final Exam Report, #44 Civil Cover Sheet, #45 Proposed Summons)(Spector, David) |
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