IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

SARAH FOSTER - Plaintiff

v

JAMES HUESSER- Defendant,

* * * * *
         CASE NO. 05-C-05-095553
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

NOTICE OF PARTIES’ ORAL DEPOSITIONS
AND DEPOSITIONS DUCES TECUM


      Sarah Foster, Plaintiff, by her attorneys and pursuant to the Maryland Rules of Procedure, will take the depositions upon oral examinations of the following persons on the dates and at the times indicated, in the Office of Miller & Zois, LLC, 7310 Ritchie Highway, Empire Towers, Suite 615, Glen Burnie, Maryland, 21061.

                                                     DEPONENT: Steve Sellinger

                                                     TIME: 2:00 p.m.

                                                     DATE: December 5, 2010

      State Farm Insurance adjuster Steve Sellinger is to produce the following documents at the above-listed time and place:

    1. The entire  claims’ file pertaining to the claim made by Plaintiffs for monetary benefits from injuries arising out of an automobile collision that occurred on ___________, under claim number  and any other claim number, under   insurance policy _________ include all documents relative to the claim for Medical Benefits.
    2.  Copies of all letters State Farm sent to the Plaintiffs, their attorneys, and any medical provider, that are entitled “Explanation Of Reimbursement” pertaining any medical bills received by State Farm, and processed with a date of loss of loss of ________. These document shall include any and all documents that indicate  that  State Farm approved full payment or partial payment  of any of the Plaintiffs’ medical bills for medical treatment and services claimed by the Plaintiffs arising out of an automobile accident that occurred on_______.

    3. A copy of the list of codes with the corresponding explanation that State Farm in denying any medical payments for medical treatment and services claimed by the Plaintiffs arising out of an automobile accident that occurred on ______.

    4. A copy of any Medical Payment Log Sheet , PIP Log Sheet and any and all similar log sheets that lists and reflects any and all requests for payment/ reimbursement for bills / and the payment of medical bills from medical treatment that any medical provider provided to the Plaintiffs for injuries they sustained in an automobile collision that occurred on _______ which is the subject of the lawsuit at bar.

    5.  All letters sent to any person by State Farm or any person entity that State Farm contracted with,  to State Farm or any of its  contracted entities wherein any person or entity determined that the medical treatment rendered by any medical provider to the Plaintiffs were not causally related to the injuries the Plainiff sustained in an automobile collision that occurred on __________, or that the costs for the medical treatment was/were unreasonable.

    6. A copy of State Farm’s policies, procedures, instructions, and training manuals, that it provided to any of its employee/adjuster/contracted agents that delineates the procedures and considerations that State Farm employees/agents are to follow when conducting a determination whether a medical bill is causally related to an accident wherein an State Farm  insured is requesting monetary benefits under an automobile insurance policy issued by State Farm, and in particular, under the policy of insurance that is the subject matter of the litigation at bar, to include the whole insurance policy especially pertaining to “first party” medical  benefits.   
    7. A copy of any recorded statement that State Farm has obtained from any of the Plaintiffs. 

    8. A copy of the entire State Farm insurance policy that potentially covers the loss in the car accident that is the subject of this lawsuit.

    9. Copies of any letters that State Farm sent to any person that spelled out the requirements that the Plaintiffs had to meet in order for State Farm to accept and pay medical bills for treatment the Plaintiff received for injuries arising out of an automobile collision that occurred on _______, which is car accident that is the subject of this lawsuit.
    10. Copies of any photos of any of the vehicles involved in the car accident that is the subject of the litigation at bar.

    11. Copies of all documents requested in the Plaintiffs’ Request For Production Of Documents that have not already been provided by State Farm.
    12. Copies of any and all contracts with any medical audit concern and entity that processed any payments for any of the medical bills submitted for payment by the Plaintiffs or any of the Plaintiffs’ medical providers to include________.   

    13. Copies of any and all letters and correspondence to and from any medical doctor, M.D., D.O., Chiropractor  nurse or other medical personnel who reached any conclusion that any part of the Plaintiffs medical treatment and corresponding medical bills were not causally related to the automobile, OR WERE CASUALLY RELATED TO THE car crash at issue in this lawsuit were in any way shape unnecessary or unreasonable.

    14. Copies of all correspondence to any person or entity which reflects that State Farmchanged its position on any determination that it made regarding the approval of payment of medical bills submitted by the Plaintiffs or any of the Plaintiffs medical providers for treatment for injuries the Plaintiff sustained in the automobile collision at bar. 

    15. If a computer software program, TEACH or any other program, and/or any other computer analysis is utilized by State Farm or any of its medical auditors, in making a determination if any part of a medical bill submitted by the Plaintiffs or any of the Plaintiffs’ medical providers  is related/unrelated to the accident bar or is reasonable/unreasonable than please identify the name of the software program, the creator of the software program, who inputs data into the program for analysis, and any and all parameters that State Farm and any of its auditors set for the program to run.

    16. If State Farm made any decision to approve for payment or not to approve for payment any medical bill submitted by the Plaintiffs or any of the Plaintiffs’ medical providers relative to the auto accident in this case.

    17. All 1099 forms that State Farm sent to any medical doctor/expert witness/ located in the State of Maryland in the last three years.  


                                                                           Respectfully submitted,

                                                                           MILLER & ZOIS, LLC


                                                                           Ronald V. Miller, Jr.
                                                                           Empire Towers, Suite 1001
                                                                           7310 Ritchie Highway
                                                                           Glen Burnie, Maryland 21061
                                                                           (410)553-6000
                                                                           (410)760-8922 (Fax)
                                                                           Attorney for the Plaintiff

More Information