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Filing # 71457667 E-Filed 05/01/2018 09:32:43 AM
IN THE CIRCUIT COURT OF THE
15™ JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO.: 2017 CA 012325 AN
JOSE AMARO
Plaintiff,
vs.
KIM J. DENBERG and MARK
H. DENBERG,
Defendants.
/
SUBPOENA FOR DEPOSITION DUCES TECUM
TO: Heather Ledbetter
C/O Compass Medical Centers
2365 S. Congress Avenue
West Palm Beach, FL 33406
‘YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on Monday, July 16, 2018, at 10:00am at the following location:
Lawyers Reporting
12230 W. Forest Hill Blvd.
Wellington, FL 33414
for the taking of your deposition in this action. If you fail to appear, you may be in
contempt of court.
You are subpoenaed to appear by the following attorneys and unless excused from this subpoena
by these attorneys or the Court, you shall respond to this subpoena as directed and to bring and
produce at that time the following:
1. Any and all records related to the billing to payment from, or on behalf of, Jose Amaro.
2. All documentation relating to the collection of any outstanding balance owed by José
Amaro.
Tha cala ar accianmant af anu antetanding halanea aured hy Incd Amarn
ane Saie Of Gosigmiueut Of Gy Gulsluluig, CulalTe UWE UY sow ZAunaL Us
we
CHEN. DAIAARCACU AAIINTY Cl CUADAND ANF FLED NEIN«INNAA NO-29-A2 ANA
HILL. PAL DLA VUUINE TT, PL, OHI. DUUN, ULLIAN, Yoru Zulu Ug.ue.t0 mvt10.
11.
12.
13.
Any and all information including all records and documents regarding whether José
Amaro was referred to the Compass Medical Centers, Inc. by any emplovee, attorney, or
any other representative of the law firms of Schwed, Adams, Sobel & McGinley, P.A. or
Kanner & Pintaluga, P.A.
Any and all documents regarding patients previously represented by Schwed, Adams,
Sobel & McGinley, P.A. or Kanner & Pintaluga, P.A. This request specifically includes
the number of all patients of Compass Medical Centers, Inc. who are/were represented by
the above-mentioned firms.
All documentation showing how billing on letters of protection or other similar
forbearance agreements are tracked and accounted for.
The amounts earned by Compass Medical Centers, Inc. by percentage on patients seen on
Letters of protection and/or similar agreements v. non— litigation patients from January
1, 2015 to the present.
The amount of patients (alternatively by percentage) seen on letters of protection and/or
similar agreements v. patients seen on non- litigation basis from January 1, 2015 2
present.
The existence of any sale, transfer, or assignment of Letters of protection and/or similar
agreements including medical receivables, and/or account receivable between Compass
Medical Centers, Inc. and any third party.
Efforts by Compass Medical Centers, Inc. to recover payments via formal collection
procedures from this litigation patients v. non— litigation patients from January 1, 2015
to the present date, and the identity of all agencies or entities used by Compass Medical
The amount Compass Med. Center, Inc. has agreed to accept, accept, and will continue to
accept as payment from Medicare, Medicaid, Worker's Compensation, health insurers,
HMOs, PPOs or any other sources for all similar procedures charged to José Amaro as
shown on the attached bill marked as Exhibit 1 and the full names and addresses of the
insurance companies and health insurance carriers.
The name and address of all insurance companies from whom Compass Medical Centers,
Inc. except payment for services rendered by Compass Medical Centers, Inc. from
January 1, 2015 to the present date and for each such insurance Company the identity and
specific plans except.
Billing rates and practices of Compass Medical Centers, Inc. for patients with no
insurance; patients with health insurance; Medicare/Medicaid Patients or patients with
Letters of protection and/or similar agreements; and the differences and billing practices14,
15.
with regard to litigation patients v. non— litigation patients from January 1, 2015 to the
1,
Whether Compass Medical Centers, Inc. has reduced any outstanding balances in the last
3 years on patients involved in personal injury pre-suit claims in personal injury
litigation.
All documentation regarding the owners of Compass Medical Centers, Inc. including
whether Dr Rahat Faderani ac anv financial interest in Comnacc Medical Centers Inc
yo cieetesees tn et EEE y SAH
IN ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT, PERSONS IN
NEED OF A SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING
SHALL, WITHIN A REASONABLE TIME PRIOR TO ANY PROCEEDING CONTACT THE
ADMINISTRATIVE OFFICE OF THE COURT, 73 W. FLAGLER STREET, MIAMI,
FLORIDA 33130, TELEPHONE (305) 275-1155, 1-800-955-8771 (TDD) OR 1-800-955-8770
(V), VIA FLORIDA RELAY SERVICE.
DATED: May 1, 2018.
For the Court
/s/Daniel C. Methe, Esquire
DANIEL C. METHE, ESQUIRE
FBN: 501220
METHE & ROTHELL, P.A.
Attorneys for Defendant
1555 Palm Beach Lakes Blvd., Suite 301
West Palm Beach, FL 33401
(561) 727-3600 telephone; (561) 727-3601 facsimile
PE: Lreppel@flacivillaw.com
SE: Dmethe@flacivillaw.com
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Filing # 71457667 E-Filed 05/01/2018 09:32:43 AM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2017 CA 012325 AN JOSE AMARO Plaintiff, vs. KIM J. DENBERG and MARK H. DENBERG, Defendants. / SUBPOENA FOR DEPOSITION DUCES TECUM TO: Heather Ledbetter C/O Compass Medical Centers 2365 S. Congress Avenue West Palm Beach, FL 33406 ‘YOU ARE COMMANDED to appear before a person authorized by law to take depositions on Monday, July 16, 2018, at 10:00am at the following location: Lawyers Reporting 12230 W. Forest Hill Blvd. Wellington, FL 33414 for the taking of your deposition in this action. If you fail to appear, you may be in contempt of court. You are subpoenaed to appear by the following attorneys and unless excused from this subpoena by these attorneys or the Court, you shall respond to this subpoena as directed and to bring and produce at that time the following: 1. Any and all records related to the billing to payment from, or on behalf of, Jose Amaro. 2. All documentation relating to the collection of any outstanding balance owed by José Amaro. Tha cala ar accianmant af anu antetanding halanea aured hy Incd Amarn ane Saie Of Gosigmiueut Of Gy Gulsluluig, CulalTe UWE UY sow ZAunaL Us we CHEN. DAIAARCACU AAIINTY Cl CUADAND ANF FLED NEIN«INNAA NO-29-A2 ANA HILL. PAL DLA VUUINE TT, PL, OHI. DUUN, ULLIAN, Yoru Zulu Ug.ue.t0 mvt10. 11. 12. 13. Any and all information including all records and documents regarding whether José Amaro was referred to the Compass Medical Centers, Inc. by any emplovee, attorney, or any other representative of the law firms of Schwed, Adams, Sobel & McGinley, P.A. or Kanner & Pintaluga, P.A. Any and all documents regarding patients previously represented by Schwed, Adams, Sobel & McGinley, P.A. or Kanner & Pintaluga, P.A. This request specifically includes the number of all patients of Compass Medical Centers, Inc. who are/were represented by the above-mentioned firms. All documentation showing how billing on letters of protection or other similar forbearance agreements are tracked and accounted for. The amounts earned by Compass Medical Centers, Inc. by percentage on patients seen on Letters of protection and/or similar agreements v. non— litigation patients from January 1, 2015 to the present. The amount of patients (alternatively by percentage) seen on letters of protection and/or similar agreements v. patients seen on non- litigation basis from January 1, 2015 2 present. The existence of any sale, transfer, or assignment of Letters of protection and/or similar agreements including medical receivables, and/or account receivable between Compass Medical Centers, Inc. and any third party. Efforts by Compass Medical Centers, Inc. to recover payments via formal collection procedures from this litigation patients v. non— litigation patients from January 1, 2015 to the present date, and the identity of all agencies or entities used by Compass Medical The amount Compass Med. Center, Inc. has agreed to accept, accept, and will continue to accept as payment from Medicare, Medicaid, Worker's Compensation, health insurers, HMOs, PPOs or any other sources for all similar procedures charged to José Amaro as shown on the attached bill marked as Exhibit 1 and the full names and addresses of the insurance companies and health insurance carriers. The name and address of all insurance companies from whom Compass Medical Centers, Inc. except payment for services rendered by Compass Medical Centers, Inc. from January 1, 2015 to the present date and for each such insurance Company the identity and specific plans except. Billing rates and practices of Compass Medical Centers, Inc. for patients with no insurance; patients with health insurance; Medicare/Medicaid Patients or patients with Letters of protection and/or similar agreements; and the differences and billing practices14, 15. with regard to litigation patients v. non— litigation patients from January 1, 2015 to the 1, Whether Compass Medical Centers, Inc. has reduced any outstanding balances in the last 3 years on patients involved in personal injury pre-suit claims in personal injury litigation. All documentation regarding the owners of Compass Medical Centers, Inc. including whether Dr Rahat Faderani ac anv financial interest in Comnacc Medical Centers Inc yo cieetesees tn et EEE y SAH IN ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT, PERSONS IN NEED OF A SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING SHALL, WITHIN A REASONABLE TIME PRIOR TO ANY PROCEEDING CONTACT THE ADMINISTRATIVE OFFICE OF THE COURT, 73 W. FLAGLER STREET, MIAMI, FLORIDA 33130, TELEPHONE (305) 275-1155, 1-800-955-8771 (TDD) OR 1-800-955-8770 (V), VIA FLORIDA RELAY SERVICE. DATED: May 1, 2018. For the Court /s/Daniel C. Methe, Esquire DANIEL C. METHE, ESQUIRE FBN: 501220 METHE & ROTHELL, P.A. Attorneys for Defendant 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, FL 33401 (561) 727-3600 telephone; (561) 727-3601 facsimile PE: Lreppel@flacivillaw.com SE: Dmethe@flacivillaw.com