Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 1 of 157 PagelD UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ALLSTATE INSURANCE COMPANY, CASE NO.: Plaintiff, VS. FLORIDA INSTITUTE FOR NEUROLOGIC REHABILITATION, INC., and JOSEPH BRENNICK, Defendants. COMPLAINT AND JURY TRIAL DEMAND INJUNCTIVE RELIEF SOUGHT Plaintiff Allstate Insurance Company ("Allstate" and/or "Plaintiff'), by its attorneys, SMITH & BRINK, P.C. and CALLAHAN & MARTINEZ, L.L.C., allege as follows: I. INTRODUCTION I. scheme This lawsuit seeks perpetrated against Rehabilitation, damages Allstate by incurred a result of an insurance fraud defendants Florida Institute for ("FINR") and Joseph Inc, as Brennick Neurologic ("Brennick") (collectively, "defendants"). 2. FINR, a self-proclaimed leader in the treatment of traumatic brain injuries, neurorehabilitation, and neuropsychiatric disorders, and its co-conspirator Brennick, induced Allstate into paying in excess of $7, 600, 000, 00 in fraudulent claims for 1 Case 8:12-cv-01935-JDW-MAP unnecessary medical services Document 1 purportedly Filed 08/24/12 Page 2 of 157 PagelD rendered to Allstate customers insured under Michigan automobile insurance policies. The defendants conducted 3. Michigan that lured patients The 4. to FINR's defendants' elaborate an marketing campaign in the State of facilities in Wauchula, Florida. fraudulent scheme began with false promises of comprehensive neurologic treatment to patients injured in automobile accidents. Rather than 5. (as best as providing the promised rehabilitative clinically possible) patients than warehouse 6. to their pre-morbid lives, intended to restore FINR did nothing more patients with no meaningful treatment or clinical progress. The defendants' scheme deceived Allstate and other insurance claim documents invoices, bills, care by falsifying medical records, ("False Medical Documentation") that were submitted to Allstate for payment under Michigan's No-Fault Insurance Act. 7. Allstate reasonably No-Fault claims submitted 8. seven In reliance relied the False Medical Documentation in on by, or on behalf of, the defendants. on the defendants' million dollars to FINR for claims that money submissions, Allstate paid in were not All of the conduct alleged herein was undertaken intentionally. 10. By this pleading, Allstate brings claims damages for: (a) violations of the Federal mistake of fact; 11. 18 U.S.C. 1962(c); (b) excess of compensable under Michigan law. 9. Organizations Act, paying against the defendants seeking Racketeer Influenced and common Corrupt law fraud; (c) payment under (d) unjust enrichment; and (e) breach of contract. Allstate's claim for compensatory insurance payments made by damages includes: (a) Allstate to the defendants in reliance upon the 2 first party purported 2 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 provision of neurologic rehabilitative treatment, see 3 of 157 Page Exhibit I attached PagelD hereto; (b) treble damages; (c) statutory interest; (d) costs; and (e) attorney's fees, THE PARTIES II. Allstate Insurance 12. Corporation, an Company is a to exist under and entity organized of The Allstate wholly-owned subsidiary by virtue of the laws of the State of Delaware. 13. Allstate Insurance Company maintains its principal place of business in Northbrook, Illinois. 14. Allstate Insurance Company is authorized policies of automobile insurance in the 15, The Florida to conduct business and to issue State of Michigan. Institute for Neurologic Rehabilitation is a Delaware Corporation. principal place of business is in Wauchula, Florida. 16. FINR's 17. Brennick resides in and is 18. Brennick is the president of FINR. 19. Brennick is the sole 20. Brennick was the sole founder and a owner citizen of the State of Florida. and shareholder of FINR. incorporator of FINR. JURISDICTION AND VENUE III. 21. 1331. Jurisdiction over this action is conferred upon this Court Supplemental jurisdiction over by 28 U.S.C. the state law claims is proper under 28 U.S.C. 1367. 22. vast majority Venue is proper pursuant to 28 U.S.C. of the wrongful acts known to Allstate 3 1391(a)(2) and (c) whereas the alleged herein with particularity 3 Document 1 Case 8:12-cv-01935-JDW-MAP were Filed 08/24/12 Page 4 of 157 PagelD carried out within the Middle District of Florida. IV. MICHIGAN'S UNLIMITED NO-FAULT AUTO INSURANCE patient chose FINR, FINR obtained an assignment of benefits. 23. When a 24. FINR is, therefore, 25. As assignee an assignee of each patient's Allstate auto insurance policy. an Allstate insurance states, in part: property or FINR assumed all aspects of the limitation, the choice of law clause which third-party beneficiary, policy including, without "[Vs policy is issued in accordance with the laws of Michigan and covers risks and all claims or or principally disputes located in to the Michigan. Subject in any way related to this following paragraph, policy shall be governed by the any laws of Michigan... 26. Allstate underwrites automobile insurance in the State of Michigan. 27. Michigan's No-Fault and rehabilitative benefits on a Act provides for the payment of unlimited medical first-party payor basis for injured victims of motor vehicle accidents. 28. expenses Personal protection insurance benefits consisting of all reasonable charges incurred services and accommodations for arising an 29. "Under or if the Comp. product or a reasonable service itself is not Club Ins. Ass'n, 435 Mich. 33, 49 (1990). 4 payable for laillowable reasonably necessary products, care, recovery, Laws [the No-Fault] statutory scheme, medical expense to the extent it is not service, for injured person's out of a motor vehicle accident. Mich. are an or rehabilitation" 500.3107(1)(a). insurer is not liable for any charge for the particular product reasonably necessary." Nasser v. or Auto 4 Case 8:12-cv-01935-JDW-MAP Document 1 A claimant who seeks to hold 30. Filed 08/24/12 5 of 157 PagelD insurer liable for No-Fault benefits has an the burden of proving that the service claimed is Page reasonably necessary and that the charge for the service is reasonable. Nasser, 435 Mich. at 49. Claims for 31. only if the benefits out of' or are Mich. are caused Comp. protection insurance days 33. Laws The V. only if those or use available injuries "aris[e] of a motor vehicle limited benefits exceptions, an insurer must pay each claim for out of the motor vehicle accident within arising personal thirty (30) of the amount of loss sustained." 500.3142(2). Michigan No-Fault Act provides that an insurer "may award of as and are 500.3105(1). a reasonable insurer's attorney in defense excessive bodily injury" by "the ownership, operation, maintenance Mich. Comp. Laws an benefits under the No-Fault Act receiving "reasonable proof of the fact and after court "for accidental Subject to 32. personal injury sum against a against a claim that claimant was to have no reasonable foundation." Mich. in as an some Comp. be allowed by a attorney's fee for the respect fraudulent Laws or so 500.3148(2) BACKGROUND ON FINR A. BRENNICK'S OWNERSHIP, MANAGEMENT, AND CONTROL OF FINR 34. Since FINR' s incorporation, president and sole responsible for and under the tutelage Brennick has been its sole officer, director, and shareholder. 35. Accordingly, benefited from the services 36. of his at all relevant times, Brennick was provided at and by FINR. Brennick entered the neurologic rehabilitation industry father, Charles Breimick. 5 5 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page Charles Breimick owned New Medico Health Care 37. Medico"), Document 1 a chain of forty-two (42) brain injury rehabilitation 6 of 157 PagelD Systems ("New facilities spanning fifteen states. In 38. its 1992, the FBI raided New Medico's corporate headquarters investigation into allegations that emotionally insurance devastated ran out." New Medico See Peter Kerr, The FINR campus 40. In to Brennick and promised "near-impossible families, overcharged patients, and discharged patients Company Medico, N.Y. Times, October 28, 1992, 39. as was at part of cures as to their News: F.B.I. Seizes Records of New D3, attached hereto at Exhibit 2. the site of a former New Medico franchise. 1992, amidst New Medico's legal troubles, ownership incorporated in its present form was transferred FINR. as operates under the sole control of Brennick. 41. FINR 42. At all relevant financial matters, and the times, Brennick controlled all personnel decision-making, day-to-day operations of FINR. fraud. As discussed B. FINR'S LEGAL REQUIREMENTS PURSUANT TO FLORIDA HEALTH_ CARE herein, FINR was used by Breimick to perpetrate 43. a LAWS 44. FINR is a "transitional living facility" registered with the State of Florida Agency for Health Care Administration. 45. specialized As health a "transitional care services community reentry training, living facility, "including, but aids for FINR is not limited independent living, injured persons and head-injured persons." and FLA. STAT. ANN. 6 charged with providing to, rehabilitative services, counseling 400.805. to spinal-cord- 6 Document 1 Case 8:12-cv-01935-JDW-MAP FINR is also 46. As Brain and a such, FINR "shall provide... the individual's social goal-oriented treatment program designed as well as provide to least the at FLA. STAT. ANN, transitional days and A skills training, behavior and recreation." 381.75(6)(c). a Brain and Spinal Cord Injury Program Designated Facility, by the following statutory provision: living facility improve following therapies: physical, analysis for programs serving brain-injured individuals, health education, also bound to support and supervision. necessary occupational, speech, neuropsychology, independent living As PagelD Spinal Cord Injury Program Designated Facility. living facility shall offer 47. 7 of 157 Page physical, cognitive, communicative, behavioral, psychological, functioning, transitional a Filed 08/24/12 as a temporary living facility shall measure develop and not an "All residents shall as a permanent home of treatment and domicile. The living facility shall develop discharge plan for each resident after the resident's admission. Each as a soon as practical, but treatment plan and discharge plan must be reviewed and updated as necessary, but no less often than who has no later than 30 a or the transitional initial treatment plan for each resident within 3 after the resident's admission. The transitional comprehensive plan use FINR is The transitional quarterly.... an days appropriate discharge discharge plan or who is no living facility These basic discharge site and who has achieved the longer making progress toward the comprehensive treatment plan and the discharge plan." 48. shall comprehensive any individual goals of his goals or her established in the FLA. STAT. ANN. legal requirements outline the minimum care to 381.75(6)(d). be provided to each patient admitted to FINR. 49. FINR's patients should also be safe, shall have 7 a right to dignity, privacy, 7 Case 8:12-cv-01935-JDW-MAP Document 1 and humane care, and shall be free from abuse, v. Filed 08/24/12 neglect, Page 8 of 157 PagelD exploitation. Cf., Youngberg or Romeo, 457 U.S. 307 (1982) (treatment of individuals involuntarily civilly confined); FLA. STAT. ANN. VI. 393.13 (bill of rights of persons who are developmentally disabled). FINR'S MISREPRESENTATIONS TO ALLSTATE AND TO PATIENTS FINR 50. employed individuals, including to carry out its Michigan, aggressive marketing those exclusively assigned program, which designed was to to take advantage of Michigan's unlimited No-Fault payment limits. These 51. without limitation, online marketing efforts include, http://w.finr.net, printed brochures and literature, presentations at resources at conferences, and networking events. 52. FINR sponsors events in 53. FINR's thorough, materials make numerous promises of comprehensive, and professional rehabilitative treatment. 54. provision marketing Michigan that cater to those with brain injuries. F1NR' s mission statement, for example, provides that: "[t]hrough the of individualized assessment, restorative service and foundational retraining in behavior, psych-social, cognitive, physical functioning, communication, daily living, education and vocational areas, FINR seeks to assist its clients in maximum level of functioning and restrictive environment." quality as See Florida Institute for 56. FINR's home page on Neurologic Rehabilitation, Inc., at Exhibit 3. FINR' s mission statement also identifies including "re-entry to the community." one of the goals of its treatment See id. its website describes its services 8 their of life in their most normalized and least MISSION, PHILOSOPHY AND GOALS, annexed hereto 55. attaining as follows: 8 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 9 of 157 PagelD [FINR] has developed a comprehensive brain injury continuum of care offering specialized inpatient evaluation and treatment for both children and adults. Through a preadmission evaluation and medical records review, FINR develops individualized treatment programs. As a leader in traumatic brain injury (TBI), neurorehabilitation, and neuropsychiatric disorders, our continuum of care delivers clinically relevant and cost effective services with unparalleled continuity of care. The distinct programs in our continuum are designed for individuals with a wide of medical, neurorehabilitation, range complex and care needs.' neurobehavioral, neuropsychiatric 57. Most of Allstate's insureds acute rehabilitation program. rehabilitative treatment, were allegedly This program including: (l) enrolled in FINR's adult post- promised a five-tiered intensive rehabilitation; approach to (2) neurobehavioral rehabilitation; (3) forensic evaluation; (4) community integration; and (5) vocational rehabilitation. 58. FINR's "intensive rehabilitation, program promised the following testing and/or treatments: neuropsychological evaluation; occupational therapy; physical therapy; speech language pathology; rehabilitation nursing; medical management; pharmacologic assessment; and family education and training? 59. FINR also rehabilitation" program. promised additional programs See Florida Institute for See Florida Institute for Neurologic Rehabilitation, BRAIN INJURY accessed on August 22, 2012. as part of its "intensive Neurologic Rehabilitation, Inc., REHABILITATION, , 2 See Florida Institute for Neurologic Rehabilitation, ADULT POST-ACUTE REHABILITATION, , accessed on September 27, 2011. 9 9 Document 1 Case 8:12-cv-01935-JDW-MAP FINR's neurobehavioral program is "based 60. is a more Structure and chemical effective way to safety restraint, or on 10 of 157 through staff mechanical restraint." PagelD at Exhibit 4. the idea that change behavior than punishment and maintained are Page SHEET, annexed hereto INTENSIVE REHABILITATION PROGRAM FACT teaching Filed 08/24/12 positive restriction.... supervision rather than locked See Florida Institute for units, Neurologic Rehabilitation, Inc., NEUROBEHAVIORAL REHABILITATION FACT SHEET, annexed hereto at Exhibit 5. FINR also 61. integration. and to promises "This program is designed expected Neurologic Rehabilitation, Inc., annexed hereto at Exhibit 62. "The potential position Rehabilitation training Program to community community living natural, 'real worldenvironment where the demonstrate the skills." See Florida Institute for COMMUNITY INTEGRATION PROGRAM FACT SHEET, Rehabilitation Program provides individuals with the skills and abilities necessary to evaluate themselves for position. Participation includes rehabilitation for functional job skills... Our on-campus See Florida Institute for REHABILITATION PROGRAM FACT 63. aggressive approach to teach the skills necessary for and to sustain that for necessary positions. to an 6.3 Vocational neurologic impairment provide these skills in the continuously apply program trainees will be to Throughout the in the Vocational improvement employment well over 10 80 VOCATIONAL process, FINR promised All fact sheets discussed herein and annexed as exhibits contain information that is reproduced on its webpage. The quote cited herein from the Community Integration Program fact sheet is cut off midsentence. The full quote appears on FINR's website at http://www.fmr.net/aduh-post-acute- rehabilitation/programs/community-integrationh. as at Exhibit 7. pre-admission evaluative 3 as includes Neurologic Rehabilitation, Inc., SHEET, annexed hereto a 10 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 family members, coordination among "clients, referral sources Page 11 of 157 PagelD and payor sources." The goal for each patient's admission was to get "[a]ll concerned parties [to] work together to establish measurable delivered through an and goals objectives Client services for each admission. integrated Case Management system designed to keep are all concerned parties aware of clinical, medical, and behavioral progress."4 64. that it FINR warranted to its provides Allstate, Allstate's insureds, and with patients evaluation program aimed at a to the comprehensive and multi-faceted rehabilitating patients to general public treatment and pre-morbid normalcy and reintroducing patients into the community. 65. FINR also promotes its Program Designated Facility in its designation advertising and Brain and as a on Spinal Cord Injury its website. See Exhibit 8 attached hereto. 66. As such, FINR warrants that it adheres to the legal requirements of such a facility, as discussed sirpra. 67. Allstate, patients, and guardians relied representations, laws and and also on the fact that FINR governing regulations, when was in FINR's on compliance making the decision to enroll promises with all and applicable patients/insureds at FINR. 68. each Allstate and its insureds also relied specific patient in the proposed treatment on the plans promises that made with respect to were prepared by FINR personnel in advance of each patient's admission to FINR. 69. 4 See note Each such proposed treatment 3, sirpra. 11 plan that was submitted to Allstate 11 Document 1 Case 8:12-cv-01935-JDW-MAP promised and an updated "individualized as comprehensive Filed 08/24/12 treatment Page plan" that "will needed." See representative proposed treatment 12 of 157 PagelD be re-evaluated plan attached hereto at Exhibit 9. The 70. plans also conveyed that a full array of services would be patients, including medical, behavioral, vocational, occupational, speech recreational, and case management services, provision of comprehensive rehabilitative and language, among others. Allstate and its insureds relied 71. provided to care on in FINR's the representations regarding making the important decision to enroll at FINR. As 72, discussed herein, through its discovered that FINR did not services it did provide did provide recent investigation, many of the services it not constitute "comprehensive VII. promised goal of re-entry community. CULTURE OF ABUSE AND VIOLENCE AT FINR Despite 73, the idea that its representation positive teaching is punishment and restriction... supervision rather than locked Exhibit 5, FINR its to and those treatment" related to FINR's mission of individualized rehabilitative treatment and FINR's into the promised Allstate has a that its neurobehavioral program is "based more effective way to Structure and safety units, chemical restraint, employees frequently engaged are or on change behavior than maintained mechanical through staff restraint, see in violent and abusive behavior towards patients. 74. In fact, several former FINR employees have faced criminal charges relating to the abusive and violent tactics they used on FINR patients. 12 12 Case 8:12-cv-01935-JDW-MAP The Florida 75. Document 1 Department allegations of abuse and neglect complaints of abuse have been verified or by of Children and investigators and, along Page 13 of 157 PagelD Families, which investigates of children and vulnerable at FINR since 2005. neglect state Filed 08/24/12 adults, has received 514 Thirty-seven (37) of these claims with other complaints, were referred to law enforcement. In 76. 2008, University Legal Services, Ine., the protection and advocacy program for the District of FINR that violated Columbia, issued a report in which it detailed activities patients' human rights and several District prohibiting long-term seclusion and chemical restraint of Columbia ("ULS report"). at policies See ULS report attached hereto at Exhibit 10. Following the issuance 77. recalling its twenty-one (21) patients A recent report 78. of this report, the District of Columbia from FINR. published by Bloomberg and authored by David Armstrong ("Bloomberg report") details patients. See Bloomberg report 79. of certain The began the wide-spread abuse endured by FrNR attached hereto at Exhibit 11. Bloomberg report also references videos that capture the violent abuse FINR patients. These several videos are available at , accessed on August 22, 80. means to control 81. used The by FrNR Bloomberg report describes 2012. FINR's frequent use of "take downs" as patients that were often accompanied by beatings. The See Exhibit 11. Bloomberg report also describes the sometimes patients to escape a extreme measures facility deemed "prison"-like by professionals 13 a in the 13 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 14 of 157 PagelD field. See id Two of the Allstate insureds who 82. described FINR both stated that, in abuse and The neglect proceedings this whereas there is Bloomberg report, the received never an (Claim by Florida agencies against No. former FINR over 1897127260) FINR because there is end date for "treatment" at FINR. ULS report, the hundreds of culture of violence and abuse a Complaint also complaints of the last few years, and the criminal employees alleging abuse of FINR patients predominated at FINR. The existence of this culture of violence and abuse is corroborated and 85, was prison, instituted evidence that and RH. (Claim No. 217244850) fact, they would rather have been in jail than in certain end date in 84. of this subject prison. Patients A.A. 83. a as a the are directly experienced by the Allstate claimants/FINR patients who are the subject of Complaint. 86. Indeed, its insureds who are as part of its pre-suit investigation, Allstate interviewed several of former patients of FINR, most of whom stated that they experienced abuse at the hands of FINR employees. Patient A.A. 87. staff members held him across the room. including an No. 2172448520) down, beat him until he He had severe Patient B.H. 88. (Claim bruising, scars, was and a described a unconscious, time when three FINR and then rug burn from being dragged. (Claim No. 1897127260) also complained incident in which three FINR employees pushed him dragged him of physical abuse, against the wall and jumped him. 89. Patient K.A. (Claim No. 2909659216) described instances of physical 14 14 Document 1 Case 8:12-cv-01935-JDW-MAP assault Filed 08/24/12 15 of 157 Page PagelD by FINR employees and also abusive threats made by FINR employees, including that they would 90. drug him or throw him to the alligators. The mother of patient J.G. (Claim complaints about his "treatment" several at No. that her 40206901) stated son had F1NR, including that employees would "jump" him and that beatings occurred. 91. FINR's abusive tactics were particularly evident in the context of patient discharge. Indeed, FINR resorted to numerous abusive tactics to prevent patient attrition. 92. promised A.B. For with respect to that she would receive her to ride all the rides 93. example, if she own A.B. (Claim No. 2882309301), apartment and could go FINR to Busch Gardens stayed at F1NR. One of FINR's did not know what she patient was employees told A.B. when doing that her (A.B.'s) guardian and mother requesting that A.B. be discharged, leaving A.B. upset and in tears. 94. The same representative FINK also told A.B. that Allstate would stop paying her claims if she left FINR. 95. FINR told A.B.'s transition from FINR to and mother that it would not assist in A.B.'s Michigan. Indeed, upon A.B.'s discharge, prescription medication, medical guardian FINR withheld A.B.'s withheld medical records, refused to cooperate with A.B.'s providers in Michigan, and threatened to withhold funds earned by A.B. while at F1NR. 96. FINR also used abusive tactics to prevent patient T.S. (Claim No. 2881939595) from leaving FINR. 97. T.S.' s case manager stated that it took months to 15 remove T.S. from FINR. 15 Document 1 Case 8:12-cv-01935-JDW-MAP 98. FINR 99. It was that FINR finally only after agreed The 100. promised to buy T.S. to Allstate and were Page 16 of 157 PagelD house to try to convince him to stay. a case manager threatened FINR with legal action discharge T.S. abuse and violence that existed at FINR stands in stark pervasive contrast to the safe and T.S.'s Filed 08/24/12 rehabilitative treatment facility that patients, guardians, and promised by FINR and on which they relied in making the decision to place keep patients at FINR. 101. As such, Allstate is entitled to reimbursement of all payments it made to F1NR. VIII. FINR DID NOT PROVIDE REHABILITATIVE CARE 102. goal of rehabilitative The treatment is to integrate the patient back into functioning society to the best of the patient's ability. 103. specifically in the FINR in its promised generally proposed treatment plans prepared rehabilitative care, in fact FINR provide the Though provided public representations for each FINR little to no and patient that it would rehabilitative treatment to patients at issue in this Complaint. 104. As part of its investigation, the medical files of several of the 105. As a programs patients at issue sought and retained expert in this review of Complaint. result of this expert review, Allstate discovered that the "treatment" allegedly provided by specific Allstate FINR was deficient in several ways, and individualized treatment, (2) rehabilitative treatment, (3) using medical unreasonableness of treatment, and (4) records including (1) lacking not to context constituting meaningful conceal the lack of and consisting primarily of warehousing patients, 16 not 16 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 17 of 157 PagelD rehabilitating them. As 106. such, the services billed necessary and oftentimes Allstate is 107. for "Nllowable necessary or consisting of all reasonable charges Comp. Laws actually provided were medically not to the an Michigan No-Fault incurred for injured person's Act reasonably care, recovery, 500.3107(1)(a) (emphasis added). As FINR's billed-for services 108. FINR to pay claims under the services and accommodations for rehabilitation." Mich. by rendered at all. only required expenses products, were never were not to Allstate patient, medically necessary, were not and as many Allstate is entitled to reimbursement of all payments that it has made. A. NOT PROVIDE CONTEXT SPECIFIC INDIVIDUALIZED TREATMENT TO PATIENTS 109, As found in the expert review of FINR Allstate's "here are DID FINR pre-suit investigation, the goals, and this 110. A context 111. Patients lasted between thirty 112. nor were FINR did not is how we are PROGRAMS patient files, performed provide context specific as OR part of programs (i.e., going to reach them") to patients. specific program is vital to a successful rehabilitative program. were admitted to FINR under (30) days to a After the evaluation an evaluation program that usually few months. period ended, however, patients were not reevaluated specific discharge plans created. patients did receive specific estimates concerning their length 113. FINR 114. Instead, patient stays extended into perpetuity. 115. There not stay. was rarely modification of patient goals/treatment plans. 17 of 17 Document 1 Case 8:12-cv-01935-JDW-MAP 116. Without these plans and Filed 08/24/12 there goals, was no 18 of 157 Page way to measure PagelD changes in a patient's behavior or the efficacy of FfNR's "treatment." 117. In the ordinary medical records should course that provide of treating a patient patients with catastrophic is expected brain injuries, to be treated for a certain amount of time. 118. the At the conclusion of that patient should be moved to a time, if the patient does different treatment facility not or improve the or patient's progress, treatment plan should be modified. 119. Language to this effect was absent from most of FINR' s resulting in patients remaining was in the longer than necessary and often longer than what patient's best interests. 120. Indeed, in insistence of the 121. once at FINR medical records, most only at the to visit a patient from FINR occurred instances, discharge patient's Michigan guardian. Pursuant to Michigan law, each quarter and will a typically rely guardian on is only required FINR's medical records to ascertain a patient's progress. 122. Based discussed below, on the false guardians representations were contained in FINR's medical records, deceived into believing ongoing treatment was necessary. 123. This resulted in prolonged and unnecessary treatment at a substantial cost to Allstate. B. FINR DID NOT PROVIDE MEANINGFUL REHABILITATIVE TREATMENT 124. The services actually rendered 18 by FINR (1) were far less than those 18 Document 1 Case 8:12-cv-01935-JDW-MAP promised to patients at the time of their Filed 08/24/12 admission, and (2) did FINR's services consisted primarily of (1) 19 of 157 not constitute rehabilitative treatment necessary to the patient's care, recovery, 125. Page or PagelD meaningful rehabilitation. supervision, and (2) "vocational training, FINR's "vocational 126. worked at the training" consisted of supervising patients while they woodworking shop (where patients only sanded wooden letters), (where patients washed the few hours each 127. "vocational of FINR or locations where required supervision while The FINR patients at certain off-site locations for FINR did not provide any other by Allstate all described their typical day AM; have breakfast; report (i.e., weeding, sanding, washing cars); have lunch; report again until approximately 2:00 PM; report to living quarters week, certain patients met in to their vocational to vocational program for remainder of the day. groups to discuss current events. 129. Twice 130. Once per 131. Occasionally, weekend trips to the mall or to the beach were planned. 132. FINR medical or a patients could work and supervising they worked, interviewed at FINR as follows: wake around 7:00 a week, certain patients patients did not receive were taken to Wal-Mart. regular treatment and evaluation hy licensed neuropsychological professionals. 133. saw detailing bay training" to patients. 128. program employees), at the car the day. Beyond providing who patients cars shift), in weeds for their entire greenhouse (where patients pulled medical Indeed, when interviewed by Allstate, several patients stated they only professionals a few times during 19 their respective stays at FINR, though 19 Document 1 Case 8:12-cv-01935-JDW-MAP several were Filed 08/24/12 Page 20 of 157 PagelD at FINR for years. 134. The supervision and "vocational FINR did not meaningful rehabilitative care. constitute rehabilitative care, let alone 135. training" provided by Moreover, the services actually provided by FfNR paled in comparison the services and treatment that FINIR promised to to provide, including neuropsychological treatment, medical management services, behavioral services guided by positive reinforcement, and occupational therapy. FINR's MEDICAL RECORDS CONCEALED C. THE LACK OF MEANINGFUL TREATMENT 136. investigation, As a result of Allstate's expert FINR's medical records of records including (1) lack demonstrating changes in were concerning goals or the review, undertaken as part of its pre-suit found to be deficient in several areas, efficacy of treatment, (2) lack of records treatments, and (3) the use of non-specific and repetitive language regarding patient care. 137. F1NR's medical records claims for services that services were not were disguised rehabilitative, were were as intended to deceive Allstate into neurologic rehabilitative treatment, unnecessary, and/or were not paying when such compensable under Michigan law. 138. FINR's medical records served two purposes: of rehabilitative treatment treatment was 139. provided by FINR, and (2) based effective, they recommended prolonged This resulted in increased (1) they concealed the lack on the misrepresentation that care. profits for FINR, and a decline in the patient's progress and chance of rehabilitation. 140. The deceptive nature of FINR's medical records is first 20 seen in the 20 Case 8:12-cv-01935-JDW-MAP proposed treatment promised to provide patient to his or services plans Document 1 created FTNR before the her rehabilitative FINR which Allstate relied in goals, were agreeing and on under comprehensive 21 of 157 Michigan's PagelD which to progress the designed which Allstate relied in compensable to Page patient's admission, wide array of rehabilitative services a promised by by Filed 08/24/12 deciding that the No-Fault Act and on per diem rate contracts (discussed below). 141. FINR's deceptive recordkeeping admission medical records FINR 142. After that discussed the 143. a patient is further exemplified by the post- generated. was admitted, FINR provided monthly reports to Allstate patient's progress and recommended treatment goals. These reports have little variation from month to month, including little change in goals or treatment plans. 144. Notably, several patients did not receive monthly evaluations. 145. Allstate relied on the medical records generated by FINR in approving and paying insurance claims. 146. Patients and their guardians also relied on FINR's medical records when deciding to prolong treatment at FINR. 147. These fraudulent medical reports were generated on behalf of all FINR patients insured by Allstate. 148. In each instance, Allstate relied fraudulent medical reports to pay claims that contained in the on the misrepresentations were not compensable under Michigan law. D. FINR PATIENTS WERE WAREHOUSED 149. Instead of receiving meaningful rehabilitative 21 care, FINR patients were 21 Case 8:12-cv-01935-JDW-MAP instead Document 1 Filed 08/24/12 Page 22 of 157 PagelD essentially warehoused. There may be certain discrete instances in which 150. is in warehousing a patient's best interest. 151. However, in these instances, the medical records 152. That simply did not happen with the must reflect this fact. Allstate insureds at issue in this Complaint. Instead, a proposed 153. Allstate with respect to each the goal treatment plan was prepared by FINR and submitted to subject patient that promised of rehabilitation and re-entry into the community individualized treatment with to the particular patient's best ability. As discussed 154. goals plans, and lack and treatment extended into above, the lack of reevaluation, the lack of individualized of discharge plans meant that patient stays at FINR perpetuity. 155. imprisonment, Two separate Allstate each finding the prospect insureds of jail likened their stay preferable because there at FINR is at least an to end date when imprisoned. 156. Allstate's interviews of several FINR for each FINR patient, detailed above, was patients revealed that the typical day almost identical and rarefy consisted of anything more than supervision. words, Allstate paid for patients to be warehoused at FfNR. 157. In other 158. Indeed, with the exception of the few hours each day that patients received "vocational training, FINR patients were largely confined to their living quarters with no meaningful therapy or rehabilitative treatment. 22 22 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Upon completion of their daily "vocational training" 159. 2:00 PM each 23 of 157 Page at approximately day, patients returned to their living quarters for the remainder of the day. The 160. significant hours patients were confined to their living quarters, coupled with the fact that FINR did not establish discharge plans or identify care, meant PagelD patients were end points of long at effectively warehoused indefinitely. 161. The State of Florida has also found that 162. In patients were kept too FINR. specifically August 2012, that FINR the Florida kept patients too Agency long in for Health Care Administration found violation of FINR' s Florida transitional living facility license. 163. FINR 164. The corroborate the too was ordered to findings by findings develop a new the Florida of Allstate's protocol for discharging patients. Agency for Health Care Administration pre-suit investigation: patients are wrongfiilly held long at FINR without any identified end point. This amounts to 165. which is not warehousing, which Allstate what FINR represented to E. EXEMPLAR CLAIMS 166. The treatment was agreed to pay for and provide to patients, purportedly provided by FINR to Allstate insureds follows a distinct pattern wherein Allstate unnecessary, never was not rehabilitative in billed for treatment that nature, or was was otherwise not not rendered, was compensable under Michigan law. 167. and managed This pattern of fraudulent conduct by Brennick, 23 was implemented, directed, overseen, 23 Case 8:12-cv-01935-JDW-MAP The 168. Document 1 following claims Filed 08/24/12 Page 24 of 157 illustrate the pattern of fraudulent conduct PagelD employed by FINR and are representative of all twelve (12) patients at issue in this Complaint. 1. (Claim No. 2170854885) Patient M.B. 169. when he M.B. was was injured in a motor vehicle accident thirteen years old, after falling from proposed treatment plan for 170. A 171. The a M.B. on June 9, 2002, moving vehicle. was presented to Allstate on June 28, 2002. plan called for M.B. to be admitted to FINR for a period of 30 to 60 days to undergo a "course of evaluation and treatment." The treatment 172. plan stated that M.B. would be evaluated and treated neurology, neuropsychology, physical, occupational, behavior service treatment plan" that Report" was were to be used "to to be "re-evaluated and After his first month at FINR, 174. was speech and language, and departments with the goal of "returning to optimal independence." The evaluations 173. and by the develop an individual comprehensive updated as needed." an "Initial Client Service Plan/Assessment created which confirmed that M.B.'s rehabilitative services were to include "Occupational Therapy, Speech/Cognitive Therapy, Physical Therapy (consultative), Behavioral Management Services, Health Education and Medication Management Services, Educational Services, Recreational Services, Dietary Services, and Case Management Services." 175. which he Despite these purportedly representations, M.B. did not receive many of the needed and for which Allstate "comprehensive per diem rate" charged by FINR. 24 was billed as therapies part of the 24 Case 8:12-cv-01935-JDW-MAP Indeed, 176. Document 1 M.B.'s "treatment" Filed 08/24/12 primarily consisted relatively small number of medications and supervision in Page 25 of 157 PagelD of the administration of a his job working at the Activity Center/YMCA. 177. M.B. did not receive 178. Nor did M.B. have 179. The physical, occupation, or speech therapies while at F1NR. regular contact with a psychologist or counselor at F1NR. "comprehensive outcome statement" contained in M.B.'s reports remained unchanged for most of the six years M.B. resided 180. Significantly, monthly at F1NR. M.B. lacked many of the indicators to justify placement at F1NR in the first place. 181. M.B. was examined by a neuropsychologist retained by Allstate in 2011 as part of its pre-suit investigation. That 182. contracted neuropsychologist found that by F1NR, the FINR staff, did not account for several neuropsychological development those persons or early risk factors for abnormal which showed that M.B. already had a history of serious mental illness and behavior problems before his 2002 accident, 183. The failed to address or acknowledge significant findings been related to M.13.'s traumatic brain 184. at its facility The also stated that, in its initial neuropsychologist that could not have justification treatment needs with the 2002 injury possibly have injury. neuropsychologist concluded that FINR had without any FINR evaluation, or recommended placement clinically-based evidence that related and that there 25 was likely never a M.B.'s clinically-based 25 Document 1 Case 8:12-cv-01935-JDW-MAP justification for placing M.B. an initial evaluative 185. placement at FINR and Filed 08/24/12 Page 26 of 157 PagelD certainly not justification that extended beyond period. To the contrary, the neuropsychologist opined that M.B.'s continued at FINR was actually harmful to the patient because it entrenched a pattern of social isolation. 186. As F1NR both misrepresented the initial need for M.B.'s placement at promised, FINR was not entitled to payment from Allstate for its purported "treatment" of M.B. and Allstate is entitled to FINR and failed to provide M.B. with the treatment it reimbursement in the amount of $1, 830,595.94, representing the amount it paid to FINR relative to M.B. 2. 187. Patient A.B. at the age of five 188. A.B. was involved in a motor vehicle accident on August 16, 1996, (5). The November 20, 2009, submitted to Allstate course (Claim No. 2882309301) by proposed treatment plan for A.B. that FINR recommended that she be admitted for a "60 to 90 was day of evaluation and treatment." 189. As with other patients, rehabilitative services to A.B„ analysis, and vocational 190. an array of including occupational therapy, physical therapy, behavior However, A.B. did For provide therapy. receive were not reasonably 191. FINR warranted that it would example, not receive most of these treatments and those she did charged to Allstate at the rate A.B. received of $800.00 per diem. occupational therapy solely of bi-weekly budget meetings. 26 at FINR that consisted 26 Document 1 Case 8:12-cv-01935-JDW-MAP 192, The "vocational Filed 08/24/12 Page 27 of 157 A.B. received consisted of therapy" PagelD working at a greenhouse and at a car detailing service. 193. There is developed, however, as no indication that any new vocational skills 194. A.B.'s medical records reflect lack of attention to her needs. 195. For A.B. being employed prior to her admission to FINR. A.B. had been example, were recommended for was eye, and dental, gynecological examinations at the time of her admission to FINR in December 2009. 196. None of these examinations had been 197. A.B.'s remained largely unchanged tluoughout the including lack of meaningful change in goals of her stay at FINR, 198. monthly reports performed several months later. A.B. also examined was by a course and treatment. at Allstate's neuropsychologist request as part of Allstate's pre-suit investigation. 199. recovery neuropsychologist following her head injury 200. brain The The noted A.B.'s apparent in 1996. neuropsychologist found that A.B. needs mental health treatment, not injury rehabilitation, which could be accomplished A.B. worked and/or attended school within her home 201. The defined treatment neuropsychologist goals good neuropsychological on an outpatient basis while community (i.e., Michigan). further found that FINR did not have any for A.B. and that it was not clear how an indefinite FINK would increase A.B.'s chances of success upon re-entry to her home 202. Based admission to FINK on placement at community. the lack of progress and treatment from the time of A.B.'s throughout conclusion that FINR clearly was her time there, and based inappropriate for treatment 27 on the neuropsychologist's of A.B.'s needs, Allstate is entitled 27 Document 1 Case 8:12-cv-01935-JDW-MAP to reimbursement of the 3. 203. occurred on 204. 2002, Filed 08/24/12 Page 28 of 157 PagelD $456, 517.25 it paid to FINR relative to A.B. D.A. (Claim No. 2907688985) Patient D.A. was injured in pedestrian/motor vehicle accident that a October 15, 1989, In the Treatment Plan submitted to Allstate Proposed FINR recommended that D.A. treatment" at FINR, promising that undergo "6 to 12 month a D.A. would be treated course by a on November 23, of evaluation and neuropsychiatrist and neurologist. 205. FINR further promised "to develop an individual comprehensive treatment plan" that would be "updated as needed." 206. FINR stated that D.A.'s rehabilitative services would "Occupational Therapy, Speech Therapy, Physical Therapy (consultative), Services, Health Education Behavioral Services and Medical Management Services, Service Plan/Assessment and Case Educational Recreational Management, include Services, Management Services" in its Initial Client Report. 207, D.A.'s 208. D.A.'s records also fail to document monthly reports were largely unchanged exactly from month to month. what treatment she was receiving. 209. D.A.'s treatment 210. For example, plans and long-term goals rarely changed. D.A.'s "vocational therapy" consisted of working at a local thrift store. 211. Despite doing "outstanding" work at the thrift store, including ratings and goals, remained the same 28 for her vocational D.A.'s treatment plan, therapy from quarter to 28 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 29 of 157 PagelD quarter. Much of the "treatment" recommended for D.A., and for which Allstate 212. was billed, was questionable and/or not actually rendered. For 213. example, for several which consisted of birth control years, D.A. administered her own medication, pills. D.A. did not otherwise have any medical conditions that 214. required supervision or treatment by FINK 215. Yet, FINR billed Allstate for medical management services. 216. An independent expert review of D.A., performed part of its pre-suit investigation, noted activities classified were questionable and not clearly related For 217. to D.A.'s as at Allstate's request occupational therapy as that long-term goals. example, the occupational therapy that D.A. received at times consisted of board games. The expert also took issue with the lack of baseline data in FINR's 218. medical records to substantiate problematic behaviors for which D.A. was recommended for treatment/intervention. The expert further noted 219. a pervasive lack of specificity in D.A.'s medical records. For 220. there is almost 221. intellectual example, "violations" never a "behavior" or are mentioned in records, but description of the nature of the violation or behavior. The expert concluded that D.A.'s test results indicate that she has minimal deficiencies, not traumatic brain injury, her progress at FINR. 29 and that D.A. plateaued early on in 29 Case 8:12-cv-01935-JDW-MAP 222. not D.A. did not Document 1 require Filed 08/24/12 treatment at FINR in the first Page 30 of 157 PagelD place and certainly did require F1NR' s services for nearly the amount of years she received them. 223. Allstate is entitled to reimbursement in the amount of Accordingly, $1, 523,229.96, the amount it has paid to FINR relative to D.A. 4. 224. A.A. Patient A.A. 2006, and was admitted 225. (Claim No. 2172448520) was to FINR involved in on motor vehicle accident vocational on February 19, April 10, 2009. In its Initial Client Service Plan/Assessment A.A. and to Allstate that it would including a provide an Report, FINR promised array of rehabilitative services to services, recreational services, case to A.A., management services, and behavioral services, among others. 226. The "vocational services" A.A. received consisted of working in a greenhouse and a woodshop. 227. duties in the 228. The daily records of A.A.'s vocational treatment state only "perform woodshop." The notes for A.A.'s recreational treatment state only "recreational activities" and the number of units. 229. There is no discussion of exactly how it related to A.A.'s individual treatment 230. behavioral A.A. was placed at FINR what the recreational activity was nor plan. primarily due to substance abuse issues and problems. 231. The demonstrate any daily records of A.A.'s behavioral treatment, however, fail to change in A.A.'s objectives with respect to behavioral therapy. 30 30 Document 1 Case 8:12-cv-01935-JDW-MAP In 232. general, A.A.'s records reflect Filed 08/24/12 a Page 31 of 157 lack of change in progress, PagelD goals, and treatment. Nor is there 233. though the intelligence the clear end a point for treatment identified in the records, FINK found that A.A.'s neuropsychological examination performed by is in the average range, his "mental superior range, and his "overall be above average when compared flexibility and categorization problem solving skills and skill are in visuoperception appear to which support that A.A. should be to peers his age, expected to and should actually achieve certain treatment goals. 234. That the records do not reflect this necessary to A.A.'s treatment and care simply and/or that F1NR did not continued to A.A.'s clinical needs at the 235. means provide the that F1NR's treatment properly measure the was not efficacy of its service without any relation to same given time during his stay at FINK. Under either scenario, the Michigan No-Fault Allstate to pay for FINR's services relative to A.A. As Act does not obligate such, Allstate is entitled to reimbursement in the amount of $416, 225.19. K.A. 5. 236. K.A. 237. In the was (Claim No. 2909659216) injured when he was struck by a motor vehicle on November 20, 2000. K.A. was during Proposed recommended for which occupational, time and a Treatment Plan submitted to Allstate "60 to 90 he would speech and be day course evaluated June 11, 2009, of evaluation and treatment" at FINR by the language departments "to neuropsychology, physical, develop comprehensive treatment plan" that would be updated as needed. 31 on an individualized 31 Case 8:12-cv-01935-JDW-MAP K.A.'s medical records 238. "individualized While F1NR panoply speech and 241. largely are Page 32 of 157 PagelD redundant and do not reflect that any comprehensive treatment plan" was ever followed or updated. documented basis for a 240. full Filed 08/24/12 K.k's medical records also fail to 239. K.A. with Document 1 clearly relate the services provided to providing the particular service. consistently states in summary reports that it is providing of services to K.A., in fact K.A. did not receive physical, occupational, a or language services. K.A. did receive vocational therapy, which consisted of weeding in the greenhouse and sanding wood in the woodshop. 242. K.A. has long a and documented post-traumatic history quality woodworks, especially birdhouses, which calls into question of producing the benefit of sanding wood as a primary component of his vocational therapy. 243. As FINR has not provided the services it necessity of those services it did provide are promised 244. G.H. G.H. was a provide, questionable, Allstate is reimbursement in the amount of $573, 241.42, the amount it 6. to and as the entitled to paid to F1NR relative to K.A. (Claim No. 2901672985) seven-year-old pedestrian struck by a motor vehicle on March 17, 1994. 245. F1NR noted in its proposed treatment plan prepared in 2003 admission to FINR that his skills "remained on grade advance of G.H.'s level" and he "demonstrated strong abilities in algebra, vocabulary and spelling." 246. In the same report, G.H. was cognitive fimctioning." 32 found to have "achieved relatively stable 32 Case 8:12-cv-01935-JDW-MAP FINR 247. limits" and that his Document 1 found that G.H.'s specifically "Misual motor functions were to 12 month course Page "Blanguage 33 of 157 was PagelD within normal within normal limits." F1NR recommended that G.H. be admitted for Despite these findings, 248. Filed 08/24/12 of evaluation and treatment" that would include treatment a "6 by ItThe physical, occupational and speech and language departments." Yet G.H. did not receive services 249. beyond schooling and behavioral therapy during his time at F1NR. As in every 250. updateH as needed" with the ultimate 251. FINR promised to proposed treatment plan, However, G.H.'s goal of having G.H. treatment goals did not "re-evaluatell and return home. change throughout the course of his stay at FINR. 252. For example, said to have "shown great 253. not in the monthly report dated November 10, 2001, G.H. was improvement in his behavior." Yet, G.H.'s behavioral treatment goals (both long-term and short-term) did change from what they were in June 2001. 254. treatment G.H's medical records are thus indicative of the lack of individualized goals and plans pervasive in FINR's records. 255. As such, Allstate is entitled to reimbursement in the amount of $206, 490.42 for payments made relative to G.H. IX. FINR'S FRAUDULENT BILLING PRACTICES 256. Prior to 257. With respect to each admitting a new patient, FINR confirmed each patient's funding source. patient insured by Allstate, 33 FINR obtained an 33 Case 8:12-cv-01935-JDW-MAP Document 1 assignment from the patient/Allstate Filed 08/24/12 34 of 157 Page PagelD insured wherein it assumed the benefits and obligations of the auto insurance policy. admission, FINR contacted Allstate directly Prior to 258. negotiate to enrollment and payment terms for each patient. For each 259. patient, FINR obtained an authorization from Allstate, verifying that Allstate would approve claims for necessary rehabilitative treatment. FINR also demanded contracts 260. per diem rate for the comprehensive to which Allstate would pay pursuant promised neurologic a rehabilitation evaluation and treatment. FINR utilized the per diem contracts to avoid 261. charges, which would have revealed that F1NR not was having to submit itemized providing the rehabilitative services it promised. As detailed above, FINR failed to 262. evaluation and treatment to were not 264. "[a]llowable necessary or Under the expenses Michigan No-Fault Act, consisting were and accommodations for rehabilitative not medically necessary only required to pay for for reasonably charges incurred an injured person's care, recovery, 500.3107(1)(a). Each time FINR submitted invoice contained Allstate is of all reasonable rehabilitation." Mich. Comp. Laws 266. promised actually provided. products, services 265. the patients. Thus, it billed Allstate for services that 263. and/or provide an invoice to Allstate, it represented that the only reasonable charges incurred for reasonably necessary services. These representations were false. 34 34 Document 1 Case 8:12-cv-01935-JDW-MAP The 267. "comprehensive Filed 08/24/12 per diem rate" was supposed (1) required by Florida range of rehabilitative treannent Page 35 of 157 PagelD to encompass the full law for transitional living facilities, (2) promised during admission, and (3) recommended in monthly reports, but such treatment rarely provided. Allstate relied 268. claims that was were not unreasonable F1NR's representations to its detriment when paying compensable under Michigan law. FfNR's 269. on billing practices were also fraudulent because contained they charges. Michigan's 270. and customary No-Fault Act charges and requires an expenses rendered to an insurer to reimburse all reasonable insured injured in a motor vehicle accident. As 271. a pre-suit investigation, beginning result of its began demanding itemized bills July 2011, Allstate from FfNIt. These itemized bills reflect 272. in charges that are far in excess of what is reasonable and customary. For 273. example, Allstate was charged room and board (a shared two-bedroom apartment in Wauchula, Florida) for D.A. (Claim No. 2907688985) in the $375.00 a day, 274. each time or Allstate a nurse 275. $136, 875.00 per year. As was also See invoice attached hereto at Exhibit 12. charged $40.50, disguised dispensed medication to D.A. F1NR misrepresented reasonableness of its charges for services in fraudulent billing practices when it amount of the as "medical management, See I. medical necessity of, fact of, and purportedly rendered to patients, F1NR engaged sought payment from Allstate 35 under the Michigan 35 Case 8:12-cv-01935-JDW-MAP No-Fault Act to which it SPECIFIC X. was Document 1 Filed 08/24/12 Page 36 of 157 PagelD not entitled. ALLEGATIONS OF MAIL FRAUD RACKETEERING ACTIVITY The defendants created, 276. prepared, and submitted, prepared, and submitted, False Medical Documentation by devising and intending money and property causing to be placed, a caused to be created, in violation of United States law scheme to defraud for the purpose of obtaining through false and fraudulent representations, and by placing in a to be sent and delivered 1341 to devise or or post office and/or authorized depository for mail matter, things by the United States Postal Service, in violation of 18 U.S.C. (mail fraud). 277. Unless otherwise insurance claim pled to the contrary, all documents, notes, reports, health forms, medical records, referrals, letters, and requests for payment in connection with the insurance claims referenced through the U.S. 278. throughout this pleading Mail. Every automobile insurance claim detailed within involved at least one use of the U.S. Mail, including the mailing of, among other things, the notice of claim, initial insurance payments, claims settlement checks and the return of the cancelled policies, settlement drafts to the financial institutions from which the drafts return of settlement draft 279. scheme traveled acted with drawn, as well as duplicates to the insurance carrier's home office for filing. The defendants either by causing were personally used the mails to further their fraudulent medical bills and records from FrNR to be mailed to Allstate, and/or knowledge that the use of the mails would follow in the business. 36 ordinary course of 36 Document 1 Case 8:12-cv-01935-JDW-MAP 280. The defendants Filed 08/24/12 fraudulently represented providing comprehensive neurologic in these Page 37 of 157 mailings that they PagelD were rehabilitation evaluation and treatment to Allstate's insured. 281. The defendants fraudulently represented insureds would benefit from continued in these mailings that neurologic rehabilitation evaluation Allstate's and treatment at FINR. 282. The defendants purportedly provided by FINR that the medical treatment fraudulently represented was reasonable, medically necessary, and compensable under the Michigan No-Fault Act. 283. carrier, a The defendants knew that their offices, patient's attorney, other medical provider, connection with each of the fraudulent claims, or a patient, the a claimant, an insurance plaintiff would use the mails in including issuing payments based upon the defendants' fraudulent documentation. 284. patient stays Given the volume of medical records at selected FINR and the length of FINR, Allstate estimates that the defendants' fraudulent medical billing generated hundreds scheme generated by of mailings. See Exhibit 13 attached hereto examples fraudulent mailings arising from the defendants' (highlighting patient/business files). XL ALLSTATE'S JUSTIFIABLE RELIANCE 285. and Through represented the submission of False Medical to Allstate that FINR Documentation, FTNR certified provided compensable medical treatment in compliance with the Michigan No-Fault Act. 286. As a licensed transitional living facility and CARF-accredited facility, 37 37 Document 1 Case 8:12-cv-01935-JDW-MAP FINR was Filed 08/24/12 Page 38 of 157 PagelD legally obligated to act with honesty, integrity, and in accordance with the law. 287, In instances where invoices were provider employed and/or contracted by FINR, obligated, legally and ethically, to act with their respective professional oaths and 288. At all relevant signed or verified by a licensed medical both the medical provider and FINR were honesty, integrity, and in accordance with pledges. times, FINR actively concealed from Allstate facts regarding the compensability of claims submitted to Allstate for payment. 289. and At all relevant times, FINR misrepresented therapies each patient received during the course the nature of the treatments of the patient's evaluation and treatment program. 290. it was In its False Medical Documentation, FINR actually performing compensable medical services collect No-Fault benefits under 291. uniformly misrepresented that and eligible to demand and/or Michigan law. At the time FINR submitted False Medical Documentation, Allstate reasonably believed that FINR's actions conformed to all applicable laws. 292. To induce Allstate to False Medical Documentation that promptly pay fraudulent represented that claims, treatment FINR submitted was legitimate and compensable. 293. Allstate was required, under statutory and contractual obligations, to promptly and fairly process claims within 30 days. 294. charges at The facially valid documents submitted to Allstate in support of the issue, combined with the material misrepresentations described above, were designed to, and did in fact, induce Allstate to rely on the accuracy of these documents. 38 38 Case 8:12-cv-01935-JDW-MAP 295. In reliance on Document 1 the Filed 08/24/12 representations detriment, monies that Allstate otherwise would Page paid PagelD paid money to its if FINR had provided true of FINR, Allstate not have 39 of 157 and accurate information. 296. Based upon FINR's affirmative acts of concealment Allstate did not discover, and could not were have discovered, that its damages shortly before it filed this Complaint. attributable to FINR's fraud until XII. reasonably (discussed below), FINR'S FRAUDULENT CONCEALMENT 297. FINR's fraudulent scheme false medical reports and false invoices 298. Based was its very nature, i.e., appearing legitimate on their face. FINR's efforts to on self-concealing by conceal its harmful conduct, FINR's fraudulent scheme went undetected until Allstate had sustained substantial financial injury. 299. Despite of FINR's medical 300. due diligence, Allstate did not discover the true nature and scope billing fraud scheme until 2011. FfNR successful creating a provide to Allstate was successfully conceal able to marketing campaign describing treatments to itemize its treatment was 301. position activity by: (1) FINR knew it would not insureds; (2) generating interim medical reports making unfounded recommendations for continued treatment; having its fraudulent (3) demanding per diem contracts to avoid bills; and (4) representing through False Medical Documents that compensable under Michigan law. FINR's ability of trust medical insurance claims, to conceal the fraudulent scheme providers are was enhanced by the typically accorded in the transaction of medical particularly in the area of complex traumatic brain injuries. 39 39 Document 1 Case 8:12-cv-01935-JDW-MAP 302. Allstate relied to its detriment upon the the medical documentation submitted 303. Moreover, Allstate Nothing on presumption required by Michigan PagelD of honesty accorded law to the face of FINR's medical records would have led medical treatment was not unnecessary, 40 of 157 promptly reimburse thirty days. with each discrete insurance claim was Page by FINR. was FINR for its submitted claims within 304. Filed 08/24/12 a prudent provided as submitted in connection person to believe that the agreed, or was otherwise not compensable under Michigan law. 305. Had Allstate not been misled by FINR' s fraudulent conduct and intentionally false statements, payments would not have been made 306. It is the review of only upon Allstate's patients and defendants' scheme to defraud 307. Allstate's patient was on these claims. pre-suit investigation, including most importantly medical records by retained experts, that the revealed. investigation is ongoing and new facts concerning FINWs scheme continue to be revealed. XIII. ALLSTATE'S DAMAGES 308. The defendants' pattern of fraudulent conduct caused 309. Allstate's injury includes, injury to Allstate. but is not limited to, compensatory payments in connection with No-Fault claims of $7, 600,321.39, the damages for exact amount to be determined at trial. 310. forth in its The chart annexed hereto at Exhibit entirety, and incorporated herein as if set identifies Allstate's payments to FINR in connection with the No- Fault claims determined to be fraudulent as of the 40 filing of this Complaint. 40 Document 1 Case 8:12-cv-01935-JDW-MAP XIV. Page 41 of 157 PagelD 41 damages continue to accrue. Allstate's 311. Filed 08/24/12 CAUSES OF ACTION COUNT I VIOLATIONS OF 18 U.S.C. 1962(c) RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT (Against Joseph Brennick) Allstate 312. set forth above as re-alleges, re-pleads, and incorporates by intentionally caused to be herein, Brennick Brennick and mailed False Medical Documentation in prepared connection with Allstate insurance 314. paragraphs if fully set forth herein. In connection with each of the claims identified 313. more reference all claims, employed (or in furtherance of a scheme to defraud. caused to be occasions to demand and/or receive payment employed) on the U.S. Mail on two or including, but certain dates, not limited to, those dates identified in the chart at Exhibit 13. Among other things, 315. insurance, and premium checks FINR were invoices, medical reports, routinely delivered to Allstate applications through for the U.S. Mail. delivered to insureds 316. Policies of insurance 317. FINR's medical reports and invoices were were through the U.S. Mail. delivered to Allstate through the U.S. Mail. FINR issued by Allstate traveled through the U.S. Mail. 318. Payments to 319. At all relevant times, Brennick caused to be submitted) repeatedly and intentionally submitted (or FINR invoices and other medical documentation to Allstate for medical expenses and/or services that were 41 purportedly performed at FINR to collect Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 42 of 157 PagelD payment from Allstate under the first-party benefits portion of Allstate policies and the Michigan No-Fault Act. 320. As documents and result of, and in reasonable reliance upon these a misrepresentations, Allstate, by its agents and employees, misleading issued drafts to FINR, for the benefit of Brennick, that would not otherwise have been paid. 321. fraudulent The defendants' pattern of claims, each appearing legitimate discovering the fraudulent continue without 322. U.S.C. 1341 323. scheme for their face, also to be submitted, prevented Allstate from long period of time, thus enabling this scheme to (mail fraud). to be By mailing (or causing in mailed) numerous fraudulent claims in The activities pattern of racketeering activity within the a alleged herein had the direct effect of Complaint, have a causing funds to be FINR, for the benefit of Brennick. Allstate is in the business of writing insurance and Michigan. an 1962(c). transferred from Allstate to State of causing The acts set forth above constitute indictable offenses pursuant to 18 meaning of 18 U.S.C. 325. a on or being detected. ongoing scheme, Brennick engaged 324. submitting, Insurance fraud schemes, such deleterious impact on as paying the scheme Allstate's overall financial claims in the alleged in this well-being and adversely affect insurance rates. 326. affect, F1NR constitutes interstate an enterprise engaged in, and the activities commerce. 42 of which 42 Case 8:12-cv-01935-JDW-MAP At all relevant 327. Document 1 times, FINR Filed 08/24/12 engaged was Page 43 of 157 in the business of PagelD evaluating, treating, and rehabilitating traumatic brain injury and neuropsychiatric disorders. Brennick managed and directed the 328. participated, both directly and indirectly, operations of the FINR in the conduct of the FINR pattern of racketeering activities, including mailing, or causing enterprise, and enterprise through to be a mailed, False Medical Documentation to Allstate. At all relevant 329. times, for the affairs of FINR, responsible Brennick operated, managed, and including the management business affairs, the management of FINR's financial was of FINR's ultimately day-to-day affairs, and management of FINR's employees. Allstate is 330. business property by or a "person" reason as defined by of Brennick's conduct. Brennick's conduct in violation of 18 U.S.C. 331. 1961(3), injured in its 18 U.S.C. 1962(c) was the direct and proximate cause of Allstate's injury. 332. By entitled to recover submitted by FINR virtue of Brettnick' s violations of 18 U.S.C. from him three times the FINR as a damages sustained by direct result of Brennick's enterprise, together with the costs 1962(c), of suit, operation reason Allstate is of the claims and management of the including reasonable attorney's fees. COUNT II COMMON LAW FRAUD (Against Ali Defendants) 333. through 311 334. Allstate re-alleges, re-pleads, set forth above as and incorporates by reference paragraphs 1 if fully set forth herein. The defendants' scheme to defraud Allstate 43 was dependent upon a 43 Case 8:12-cv-01935-JDW-MAP succession of material Document 1 Filed 08/24/12 of fact misrepresentations Page concerning 44 of 157 FINR's claims for neurologic rehabilitative treatment that were not compensable under Michigan 335. The limited to, statements made in between FINR and Allstate, invoices/bills of fact misrepresentations that neurologic rehabilitation evaluation and 336. The defendants' plans, monthly treatment falsely represented law. by the defendants include, but marketing and advertising materials, proposed that FINR would PagelD are not per diem contracts updates, and treatment provide comprehensive treatment. representations were false, or required disclosure of additional facts to render the information furnished not misleading. 337. These misrepresentations were furtherance of their scheme to defraud Allstate were not made intentionally by the defendants by submitting claims in for services that compensable under Michigan law. 338. These misrepresentations These misrepresentations were made in bad faith, with no intention of performance. 339. fraud were nothing than more a device to perpetrate a against Allstate. 340. detriment in Allstate paying meritorious bills 341. reasonably relied numerous upon such material misrepresentations unreasonable, unnecessary, inappropriate, and purporting to be for compensable No-Fault insurance Allstate's damages include, but are not 44 non- claims. limited to monies connection with fraudulent claims, reasonable costs and fees. to its paid in 44 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 COUNT III PAYMENT UNDER MISTAKE OF FACT (Against Florida Institute for Neurologic Rehabilitation, Allstate 342. through 311 Allstate misapprehension, PagelD Inc.) re-alleges, re-pleads, and incorporates by reference paragraphs set forth above 343. 45 of 157 Page as if fully set forth herein. paid the error, fault, scheme to defraud Allstate 1 or amounts described herein under a of material ignorance by misrepresenting the misunderstanding, facts, namely, the defendants' necessity of medical services purportedly provided. Allstate sustained 344. submitted by, or on behalf damages by paying of, F1NR, and/or fact of the medical treatment FINR would be 345. to it which under a misrepresented mistake of fact the claims the reasonable, necessity, allegedly rendered. unjustly enriched if permitted to retain the payments made by Allstate under a mistake of fact. Allstate is entitled to restitution from F1NR for all monies 346. received by paid to and/or it from Allstate. COUNT IV UNJUST ENRICHMENT (Against All Defendants) Allstate 347. through 311 set forth above as When Allstate 348. obligated re-alleges, re-pleads, to make such and incorporates by reference paragraphs 1 if fully set forth herein. paid FINR, it reasonably payments based believed that it the was legally defendants' fraudulent benefit that the defendants aggressively upon misrepresentations and/or omissions. 349. Allstate's payments constituted 45 a 45 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 46 of 157 PagelD sought and voluntarily accepted. The defendants 350. fraudulent wrongfully obtained payments from Allstate through their billing scheme as described more fully above. Retention of these benefits would violate fundamental 351. of principles justice, equity and good conscience. (Against Allstate 352. through 311 COUNT V BREACH OF CONTRACT Florida Institute for Neurologic Rehabilitation, re-alleges, re-pleads, set forth above as With respect to 353. to enter into contractual and Inc.) incorporates by reference paragraphs 1 if fully set forth herein. patients insured by Allstate, Allstate was induced by F1NR agreements for the provision of comprehensive neurologic rehabilitative treatment. In 354. Allstate agreed a the fixed provision of neurologic rehabilitative treatment, daily (i.e., per diem) cost for treatment. were entered into based provide neurologic rehabilitative evaluation requirements, was to pay FINR These agreements 355. would exchange for was was and treatment that met legal F1NR breached these contracts compensable under Michigan law. by failing of neurologic rehabilitative evaluation and treatment, reasonably FINR consistent with services advertised and/or discussed upon admission, recommended in monthly reports, and 356. the representation that on necessary, and to provide the promised course by providing services that were not by submitted unreasonable charges for those services it did provide. 357. As a direct result of FINR's breach, Allstate is entitled to reimbursement 46 46 Case 8:12-cv-01935-JDW-MAP of all monies XV. Document 1 Filed 08/24/12 Page 47 of 157 PagelD paid under the terms of the per diem contracts between FINR and Allstate. DEMAND FOR RELIEF WHEREFORE, plaintiff Allstate Insurance Company respectfully prays that judgment enter in its favor as follows: COUNT I VIOLATIONS OF 18 U.S.C. §1962(c) RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT (a) AWARD Allstate's actual and (b) AWARD Allstate treble and (c) damages pursuant to 18 U.S.C. established at trial; §1964, interests, costs attorney's fees; GRANT conduct (d) consequential damages to be injunctive relief enjoining the defendants alleged in the Complaint; from engaging in the wrongful and GRANT all other relief this Court deems just. COUNT II COMMON LAW FRAUD (a) AWARD Allstate its actual (b) AWARD Allstate its reasonable costs and (c) GRANT any other relief this Court deems just. damages in an amount to be determined fees; at trial; and COUNT III PAYMENT UNDER MISTAKE OF FACT (a) AWARD Allstate its actual (b) GRANT all other relief this Court deems just. damages in an amount to be determined at trial; and COUNT IV UNJUST ENRICHMENT (a) AWARD Allstate its actual (b) AWARD Allstate its reasonable costs and fees; and damages in an amount to be determined at trial; 47 47 Case 8:12-cv-01935-JDW-MAP (c) Document 1 Filed 08/24/12 Page 48 of 157 GRANT any other relief this Court deems just. COUNT V BREACH OF CONTRACT (a) AWARD Allstate its actual (b) AWARD Allstate its reasonable costs and (e) GRANT any other relief this Court deems just. XV. JURY TRIAL DEMAND The damages in an amount to be determined fees; and plaintiff demands a trial by jury on all claims. [SIGNATURE PAGE FOLLOWS] 48 at trial; PagelD 48 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 49 of 157 PagelD Respectfully Submitted, /0_7 Daniel A. Mai Florida Bar ID No.: g 009016 Attorney for Allstate Insurance Company CALLAHAN & MARTINEZ, L.L.C. 2935 1st Avenue North, 2nd Floor St. Petersburg, FL 33713 Telephone: (727) 894-3535 Fax: (727) 502-9621 E-mail: dan@callahanmartinez.com and Richard D. King, Jr. (pro hac vice pending) Nathan A. Tilden (pro hac vice pending) Michael W. Whitcher (pro hoc vice pending) Jacquelyn A. McEttrick (pro hoc vice pending) Attorneys for Allstate Insurance Company SMITH & BRINK, P.C. 350 Granite Street, Suite 2303 Braintree, MA 02184 Telephone: (617) 770-2214 Fax: (617) 774-1714 E-mail: rking@smithbrink.com E-mail: ntilden(iNmithbrink.com E-mail; E-mail: Dated: August 24, 2012 49 mwhitcher@smithbrink.com imcettrick@smithbrink.com 49 Case 8:12-cv-01935-JDW-MAP Document 1. Filed 08/24/12 _Page 50 of 157 Pagel!), So Respectfully Submitted, Daniel A. Martinez Florida Bar ID No.: 00009016 Attorney for Allstate Insurance Company CALLAHAN & MARTINEZ, L.L.C. nd 2935 rt Avenue North, 2 Floor St. Petersburg, FL 33713 Telephone: (727) 894-3535 Fax: (727) 502-9621 E-mail: dan@callahamriartinez.com and Richard D. Kitt, Jr. (pro hac vice pending) Nathan A. Tilden (pro hac vice pending) Michael W. Whitcher (pro hac vice pending) Jacquelyn A. MeEttrick (pro hac vice pending) Attorneys for Allstate Insurance Company SMITH & BRINK, P.C. 350 Granite Street, Suite 2303 Braintree, MA 02184 Telephone: (617) 770-2214 Fax: (617) 774-1714 E-mail: E-mail: E-mail: Dated: August 24, 2012 49 rking@smithbrink.corn ntilden@srnithbrink.com mwhitcher@smithbrink.com jmeettrick@smithbrink.com Case Document 1 Filed 08/24/12 Page 51 of 157 PagelD 51 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit Filed 08/24/12 52 of 157 PagelD 52 Damages Chart Payment Payment Date Page Payee Payor Amount Check No. Claim No. 40206901 0411/0041393181 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $18, 700.00 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $48.27 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500, 00 40206901 0425/0041393859 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0428/0041394102 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0510/0041398755 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 90206901 0516/0041399138 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0531/0041399841 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 40206901 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0623/0041408854 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0627/0041408973 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $17, 000.00 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0809/0041457650 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 650.00 40206901 0815/0041457930 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500, 00 40206901 0830/0041458634 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 40206901 0908/0041466644 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0919/0041467286 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500, 00 40206901 0928/0041467971 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 650.00 40206901 1016/0041468921 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 650.00 40206901 1017/0041469007 40206901 0425/0041393858 0425/0041393860 0606/0041400241 0718/0041456509 40206901 0726/0041456924 EXHIBIT 1 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages 53 of 157 PagelD 53 Chart Payment Payment Date Page Payee Payor Amount Claim No. Check No. 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 103010041469707 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 40206901 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 1122/0041472319 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 1129/0041472570 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 90206901 1219/0041473789 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $17, 850.00 40206901 0115/0041476959 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0117/0041477194 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 90206901 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 40206901 0207/0041478505 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500, 00 40206901 0219/0041479188 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 800.00 40206901 0306/0041479981 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0319/0041482217 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $59.00 40206901 0403/0041483097 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 40206901 0409/0041483308 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $34.43 40206901 0503/0041484601 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 800.00 40206901 0503/0041484604 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0509/0041484944 2 1108/0041470219 1206/0091472980 0131/0041478005 0306/0041479980 0403/0041483096 0416/0041483710 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 54 of 157 PagelD 54 Exhibit 1: Damages Chart Payment Date Payment Payee Payor Amount $8, 500.001 Claim No. Check No. 40206901 0516/0041485417 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $17, 850.00 40206901 0606/0041486590 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0619/0041487454 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $15.27 40206901 0702/0041488411 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0709/0041488770 2007!LORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0717/0041489330. 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 800.00 40206901 0731/0041490292 2007 FLORIDA INSTITITTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 40206901 0807/0041490797 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 40206901 0822/0041491811 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $110.11 40206901 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $125.38 40206901 0917/0041498340 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $30.54 40206901 0917/0041498341 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $25.15 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9.29 1897127260 0928/7382866246 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $19.56 1897127260 0928/9382866255 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $12.10 1897127260 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $45.60 1897127260 1110/8383048199 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 0628/8382509153 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 0630/0382517802 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00_ 1897127260 3 1897127260 0626/0041487938. 0822/0041491812 0829/5382730904 1110/6383048181 0728/4382603851 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 55 of 157 PagelD 55 Exhibit 1: Damages Chart Payment Payment. Date Payee. Payor Amount Claim No. Check No. 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 0807/3382635459 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 0809/6382646304 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 374.00 1897127260 0828/5382723596 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 0829/4382730904 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 0901/6382751127 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 1897127260 0908/1382772907 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 1897127260 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $2, 568.76 1897127260 0928/6382866246 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 0928/8382866255 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 1110/0383048136 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 1110/1383048145 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 1897127260 1110/4383048172 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 415.46 1897127260 1110/5383048181 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $2, 568, 76 1897127260 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $2, 610.86, 1897127260 1110/8383048118 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 000.00 1897127260 1110/9383048127 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $46.85 1897127260 010211383256063 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $22.19 1897127260 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 4 0928/0382866264 1023/4382959684 1110/2383048154 1110/7383048199 0102/3383256072 1897127260 0102/0383256063 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 56 of 157 PagelD 56 Exhibit 1: Damages Chart Payment Payment Date Payee Payor Amount Claim No. Check No. 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0102/2383256072 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $2, 894.72 1897127260 0102/6383256027 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500, 00 1897127260 0102/7383256036 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0102/9383256054 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 0111/6383306868 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0208/0383432238 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 0209/0383437395 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0221/1383484537 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 380.39 1897127260 0227/2383508279 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0301/6383520402 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 1897127260 0307/5383546799 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 683.67 1897127260 0322/9383617269 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0409/2383687028 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 500.00 1897127260 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 735.66 1897127260 0521/9383866848 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $748.93 1897127260 0731/6384127857 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00_ 1897127260 0803/0600301624 5 1897127260 0102/8383256045 0207/2383426892 0322/8383617251 0410/9383698539 0721/0600296053 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 57 of 157 PagelD 57 Damages Chart Payment Date Page Payment Payee Payor Amount Claim No. Check No. 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0803/1600301625 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0803/2600301626 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0803/4600301628 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 0803/5600301629 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE $6, 000.00 1897127260 0803/6600301630 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0914/0600317667 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 0914/1600317668 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 0922/4600320844 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 1012/7600328841 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 1020/9600332144 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 1023/2600333288 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 1111/0600340192 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 1111/9600340191 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 1202/4600347340 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 1202/5600347341 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $590.99 1897127260 1210/5600350374 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 1210/6600350375_ 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $470.03 6 COMPANY_ 0803/3600301627 0819/2600307731 0914/9600317666 1897127260 1229/0600357828 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages Page 58 of 157 PagelD 58 Chart Payment Payment Payee Date Payor Amount Claim No. Check No. ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 1229/9600357827 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0105/2600361153 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0108/9600363362 ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 0201/1600372881 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0212/5600378341 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0215/3600379003 ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 0222/6600382285 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0305/8600388654 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0305/9600388655 ALLSTATE INSURANCE COMPANY $6, 000.00 1897127260 0329/3600398958 ALLSTATE INSURANCE COMPANY $7, 500, 00 1897127260 0329/4600398959 ALLSTATE INSURANCE COMPANY $7, 500,00 1897127260 0412/5600905380 ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 0412/6600405381 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0505/2600416514 ALLSTATE INSURANCE COMPANY $7, 500, 00 1897127260 0505/3600416515 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0525/0600424390 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0525/9600424389 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0615/3600431926 ALLSTATE INSURANCE COMPANY $8, 250.00 1897127260 0615/9600431927 ALLSTATE INSURANCE COMPANY $7, 500.00 1897127260 0701/2600439823 ALLSTATE INSURANCE COMPANY $2, 250.00 1897127260 0702/3600440355 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $1, 700.00 2170164269 0502/5377425206 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0520/2377508843 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0530/5377551116 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $989.87 2170164269 0602/2377559018 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0602/3377559027 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0603/4377566353 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170164269 0617/9377633088 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0625/7377671644 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $228.35 2170164269 0707/9377711919 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2009 FLORIDA INSTITUTE FOR NEUROLOGIC 119 I'S 1 2010 1 0' IP, 1 I II' Ili' IP. 1 II II' 11•6 I I' 15 1'0 IF 2010 2010 ismil), IF 2010 REHAB 1 r s• 1I 2010 O. 111, 1 I 111' 11"11 2010 5. 1 5•• 2010 REHAB S. r a• 10, 2010 REHAB us s. 2010 ip.JI9UJ 'S 111' I117L1h.IIuut1I 2010 II" 1'5 0' I V' I'S IF 11 I 111. 55 F 1 I I•S 41' S• 2010 REIIAB it 2010 O 5, 1 2010 REHAB i• II. 2010 REHAB e. e• It, vs 2010 10111, 1 1 1'0 r 111' I'S IF 5' •'5 F. 1 lb' I 5 2010 5•5, 2010 REHAB 5, 1 2010 REHAB FLORIDA INSIllUlt I-OR NEUROLU611. 2010 REFIAB FLURIUA INS IllUlh I UR NEURULLMAC 2010 REHAB 7 2170164269 0708/7377720127 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 59 of 157 PagelD 59 Exhibit 1: Damages Chart Payment Payment. Date Payee Amount Payor Claim No. Check No. $8, 500.00 2170164269 0719/4377746083 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $231.05 2170164269 0730/9377820927 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0731/2377820918 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0804/1377839071 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350, 00 2170164269 0819/5377897643 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0903/5377969382 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170164269 0923/2378068382 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $421.04 2170164269 0923/3378068391 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0924/5378074979 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0929/7378091089 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 1008/6378137439 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $231.05 2170164269 1015/0378169002 2003 FLORIDA INSTITUTE FOR NEURO REFfAB INC ALLSTATE INSURANCE COMPANY $7, 650.00 2170164269 1020/9378184896 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 1103/7378245493 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 1111/5378282501 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $631.30 2170164269 1112/9378288819 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170164269 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 1208/0378392211 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $255.86 2170164269 1208/1378392229 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 1217/9378434646 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $0.28 2170164269 0420/3378969894 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $6.71 2170164269 0428/9379010682 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0106/0378502191 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0108/6378516825 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 950.00 2170164269 0127/2378596727 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $473.34 2170164269 0203/3378628407 2009 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0203/4378628416 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $309.89 2170164269 0211/8378672012 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 650, 00 2170164269 0212/1378679923 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $6, 800.00 2170164269 0224/0378738117 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170164269 0226/0378752895 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $16, 150,00 2170164269 0301/4378764766 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE 8 COMPANY, 1201/5378360477 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 60 of 157 PagelD 60 Damages Chart Payment Payment Date Page Payor Payee Amount Claim No. Check No. 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500, 00 2170164269 0304/0378786861 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $445.85 2170164269 0318/9378853011 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 650.00 2170164269 0330/0378909369 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 650.00 2170164269 0419/7378963765 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $431.31 2170164269 0420/2378969894 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170164269 0426/2378995868 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $6, 800.00 2170164269 0428/8379010682 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $433.52 2170164269 0429/0379019034 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0504/1379039311 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $2, 550.00 2170164269 0518/5379098882 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 550, 00 2170164269 0608/4379180719 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 150,00 2170164269 0615/5379210311 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $1, 300.00 2170164269 0706/6379294497 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $927.65 2170164269 0712/8379318833 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $850, 00 2170164269 0506/8380695545 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0520/8380757735 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0602/4380807226 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0616/9380868543 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0620/4380880072 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $414.58 2170164269 0623/4380898783 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $305.35 2170164269 0627/9380910744 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0705/7380948409 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0705/8380948418 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0721/0381018636 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $366.17 2170164269 0725/3381032568 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0727/2381046536 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0810/0381106719 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170164269 0819/1381150756 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500, 00 2170164269 0823/8381164058 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0823/9381164067 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $384.38 2170164269 0831/2361204855 INSURANCE COMPANY $9, 350.00 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC, ALLSTATE 9 2170164269 0916/9381267207 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 61 of 157 PagelD 61 Damages Chart Payment Payment Date Page Payee Payor Amount Claim No. Check No. 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $305.35 2170164269 0922/7381292236 2005 FLORIDA INSTITUTE FOR NEURO REI LAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170164269 0922/8381292245 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 250.00 2170164269 1010/1381378303 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $305.35 2170164269 1101/9381469626 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $22.36 2170854885 1205/9376694244 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $36.89 2170854885 1219/4376765218 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0912/0376275965 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0912/1376275474 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $1, 700.00 2170854885 0912/4376275902 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0912/5376275411 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0912/6376275429 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0912/7376275438 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0912/8376275497 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $58.40 2170854885 0912/9376275456 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1001/2376378713 2002 FLORIDA INSTITUTE FOR NEURO REI lAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1010/5376429293 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1021/1376482411 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1030/9376534836 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1205/8376694244 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1212/3376730136 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1212/4376730145 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170859885 1219/3376765218 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1227/8376791093 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0107/2376839423 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170859885 0115/3376883874 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0131/2376966287 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0214/3377034624 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $806.83 2170854885 0220/8377060184 2003 FLORIDA INSTITUTE FOR NEURO REtIAB INC ALLSTATE INSURANCE COMPANY $7, 693.17 2170854885 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0313/3377167131 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0319/0377197047 10 0312/0377160192. 0314/2377174286 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages 62 of 157 PagelD 62 Chart Payment Payment Date Page Payee Payor Amount Claim No. Check No. 2003 FLORIDA INSTITUTE FOR NEURO REFIAB INC ALLSTATE INSURANCE COMPANY $6, 800.00 2170854885 0327/8377245125 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0401/3377262756 INC, ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0402/4377277894 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0424/8377382789 2003 FLORIDA INSTITUTE FOR NEURO REHAB 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $946.49, 2170854885 0502/0377425233 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0513/8377473644 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $52.00 2170854885 0515/8377487387 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 553.51 2170854885 0519/4377500491 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0519/5377500509 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0603/8377566362 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0610/5377599464 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0612/2377611056 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0625/4377671698 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0708/4377720181 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0730/0377820981 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885, 0811/9377869518 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $30.20 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0819/2377903241 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0826/4377936244 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0908/7377991279 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0929/7378091179 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1031/4378221364 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $49.45 2170854885 1103/3378245637 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1104/6378252198 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $17, 000.00 2170854885 1111/4378282699 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1117/6378307746 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 650.00 2170854885 1208/1378392481 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $1.75 2170854885 0204/1378635382 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $0.78 2170854885 0204/3378634446 11 2170854885 0731/2377827317 0818/9377897679 0924/2378068472 1031/3378221355 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 63 of 157 PagelD 63 Exhibit 1: Damages Chart Payment Date Payment Payee Payor Amount Claim No. Check No. 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0128/8378601857 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $53.72 2170854885 0204/0378635382 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $53.72 2170854885 0204/2378634946 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $6, 800.00 2170854885 0204/9378635373 2004 FLORIDA INSTITUTE FOR NEURO RH IAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0211/4378672714 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170859885 0211/5378672723 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0219/7378717984 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $35, 700.00 2170854885 0223/1378730368 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0225/9378745641 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0303/0378780534 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $107.44 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0324/3378882153 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 650.00 2170854885 0331/5378917991 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $53.72 2170854885 0416/4378960183 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0423/6378989928 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350, 00 2170854885 0423/7378989937 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0428/4379012554 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $55.94 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0503/6379033668 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170859885 0503/7379033677 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0527/7379137483 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $55.94 2170854885 0610/6379192653 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0617/6379223253 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0622/0379241028 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0629/0379268442 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $55.94 2170854885 0729/3379398447 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500, 00 2170854885 0825/3379519965 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $6, 800,00 2170854885 0825/4379519979 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0825/5379519983 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0901/4379552671 2004 FLORIDA INSTITUTE FOR NEURO REHAB $8, 500.00 2170854885, 0910/4379591911 INC, ALLSTATE INSURANCE COMPANY 12 2170854885 2170854885 0308/4378800595 0430/6379027593 0524/8379120356 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 64 of 157 PagelD 64 Damages Chart Payment Date Page Payment Payee Payor Amount Claim No. Check No. 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0922/5379642014 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0924/7379658214 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1005/9379705572 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 650.00 2170854885 1025/1379787004 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $111.88 2170854885 1026/7379792251 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1111/4379869489 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0104/7380084571 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0110/9380113056 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 650.00 2170854885 0113/5380133018 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $55.94 2170854885 0117/7380145879 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0120/0380165886 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0126/6380195622 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500,00 2170854885 0126/7380195631 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $55.94 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0202/9380232936 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0210/8380283732 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0228/0380366073 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $62.18 2170854885 0302/2380379132 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0307/5380400633 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $6, 800.00 2170854885 0311/8380428893 2005 FLORIDA INSTITUTE FOR NEURO REIIAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0324/0380490714, 2005 FLORIDA INSTITUTE FOR NEURO REFIAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0412/6380572875 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $55.94 2170854885 0412/7380572884 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0524/4380772828 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0524/5380772837 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0524/6380772846 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0525/5380778948 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $55.94 2170854885 0526/1380785473 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $58.11 2170854885 0607/3380825433 13 0110/0380113065 0131/7380218041 2170854885 0131/8380218059 0524/7380772855 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 65 of 157 PagelD 65 Damages Chart Payment Payment Date Page Payee Payor Amount Claim No. Check No. ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 060914380835945 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0614/1380854854 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $58.11 2170854885 0627/9380911068 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170859885 0630/3380935557 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0705/2380948805 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885, 0715/4380993643 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $58.11 2170854885 0725/9381032919 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0727/5381046851 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0809/6381101391 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0819/1381151143 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0829/7381189852 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $166.26 2170854885 0830/5381198006 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0907/5381222567 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0916/0381267698 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0926/8381312639 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $58.11 2170854885 0926/9381312648 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1011/4381385134 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1018/3381412818 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170859885 1020/8381424923 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1031/7381464262 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $290.92, 2170854885 1104/7381485151 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 1111/8381513798 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $73.36 2170854885 1205/5381604617 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1207/7381620241 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1209/5381634479 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 1227/2381709539 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $58.11 2170854885 1227/3381709548 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0110/7381766491 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 250.00 2170854885, 0111/7381771783 2005, FLORIDA INSTITUTE FOR NEURO REHAB INC 14 1205/6381604626, Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 66 of 157 PagelD 66 Exhibit 1: Damages Chart Payment Date Payment Payee Payor Amount Claim No. Check No. 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0203/8381866571 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0213/0381904857 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0222/0381956796 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 800,00 2170854885 0315/6382051647 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 100.00 2170854885 0321/2382081446 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $109.01 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0329/0382124466 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0417/3382206798 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0424/0382237893 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $113.04 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0503/5382285755 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 0523/9382366485 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $147.94 2170854885 0606/8382415445, 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 0607/6382422024 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2170854885 0615/3382459617 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 0629/7382513689 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 NEUROLOGIC, ALLSTATE INSURANCE COMPANY $1, 800.00 2170854885 0801/6382615812 2006 FLORIDA INSTITUTE FOR 15 0215/3381923352 0323/6382097763 2170854885 0328/1382117824 2170854885 0501/7382271994 0511/6382321044 0710/5382539348 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 67 of 157 PagelD 67 Damages Chart Payment Paynlent Date Page Payee Payor Amount Claim No. Check No. 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000, 00 2170854885 0807/7382634973 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2170854885 0831/5382744485 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170851885 0831/6382744494 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2170854885 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 4920/8382828032 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $65.00 2170854885 0926/9382853052 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 0927/3382859316 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 1019/2382950765 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000,00 2170854885 1023/4382959342 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2170854885 1107/8383028003 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 1120/9383091588 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 2006., FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 1207/3383158881 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 1218/1383201424 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $144.42 2170854885 1228/1383243625 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 1228/2383243634 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2170854885 0108/8383286429 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170854885 16 0821/6382691097 0911/4382778262 1012/6382923639 103116382998132 1128/9383120037 0118/0383336289 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Page 68 of 157 PagelD 68 [Damages Chart Payment Payment Payee Date Payor Amount Claim No. Check No. 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $94.83 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170859885 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2170859885 0207/8383427234 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2170859885 0219/5383472779 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $115.88 2170859885 0221/8383484771 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 800.00 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $65.00 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2170859885 1221/5600351680 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2170854885 1222/0600355281, 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $893.81 2170854885 1222/1600355282 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $3, 800.00 2170859885, 1229/0600358413 ALLSTATE INSURANCE COMPANY $9, 500.00, 2170854885, 0105/7600361171 FLORIDA INSI IIUIE FOR NEUROLOG1L 2010 REHAB FLORIDA INS I/IUIE FOR NEUROLOGIC. 2170859885 0122/3383348097 2170859885 0129/0383383269 0228/3383513904 2170859885 0427/0383779071 ALLSTATE INSURANCE COMPANY $509.00 2170854885 0126/7600370986i ALLSTATE INSURANCE COMPANY $10, 450.00 2170854885 0210/0600377324 ALLSTATE INSURANCE COMPANY $9, 500.00 2170854885 0210/1600377325 2010 REHAB FLORIDA INS IIIUIE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0215/0600379031 2010 REHAB ALLSTATE INSURANCE COMPANY $9, 500.00 2170854885 0217/8600380357 2010 REf LAB, ALLSTATE INSURANCE COMPANY $306.93 ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0223/8600383032 ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0309/2600389929 ALLSTATE INSURANCE COMPANY $6, 800.00 2170854885 0316/8600393068 ALLSTATE INSURANCE COMPANY $41.07 2170854885 0325/0600397560 ALLSTATE IN SU RANCE COM PANY $8, 500, 00 2170859885 0902/7600401789 ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0402/8600401790 ALLSTATE INSURANCE COMPANY $9, 350.00 2170854885 0913/6600405814 ALLSTATE INSURANCE COMPANY $8, 500.00 2170854885 0423/1600411329 2010 REHAB FLORIDA INS IIIUIE FOR NEUROLOGIC, 2010 REHAB FLOFUDA INS IIIDIE FOR NEUROLOGR, 2010 REHAB FLORIDA INS III UI F FOR NEUROLOGIC. FLORIDA INS IllUIL 1-UR NEURULOWL 2170854885 0222/4600382325 FLORIDA INS IIIUIE FOR NEUROLOGIC. 2010 REHAB FLORIDA INS illUlt FUR NEURULOUIU 2010 REHAB FLORIDA INS1 1lUIL 1-UR NEUROLOGIC. 2010 REHAB FLURIUA INS111U1 I FUR NkUROLUCIIL 2010 REHAB FLORIDA INS IIIUIE I OR NEUROUX,R. 2010 REHAB hLUR1DA INSIIIUIL hUR NEURULUOIL 2010 REHAB FLORIDA INS 1 1 1 Ult FOR NLUROLUbIL 2010 RE11AB FLORIDA INSI IIUIL FOR NEUROLOGIC. 2010 REHAB 17 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 69 of 157 PagelD 69 Exhibit 1: Damages Chart Payment Payment Payor Payee Date 1 I 0" I'S r 1. a r I'S I Amount Claim No. Check No. ALLSTATE INSURANCE COMPANY $8, 000.00 2170854885 0506/0600417066 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0518/5600421438 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0521/9600423443 ALLSTATE INSURANCE COMPANY $8,250, 00 2170851885 0617/0600433471 ALLSTATE INSURANCE COMPANY $7, 500.00 2170851885 0625/6600437501 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0701/5600439890 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0708/3600441819 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0720/76004469134 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0721/0600147765 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0813/3600457845 ALLSTATE INSURANCE COMPANY $8, 250.00 2170854885 0813/4600457846 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0823/6600461547 ALLSTATE INSURANCE COMPANY $8, 250.00 2170854885 0915/2600470993 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0916/6600472295 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0929/3600477542 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0930/1600478172 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 1008/7600481669 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 1025/7600488502 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 1101/7600491818 ALLSTATE INSURANCE COMPANY $8, 250.00 2170854885 1112/2600498218 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 1122/9600501728 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 1206/5600507663 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 1213/3600510896 2010 ALLSTATE INSURANCE COMPANY $7, 500.00 2170859885 1222/3600515261 2011 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0106/1600521542 ALLSTATE INSURANCE COMPANY $750.00 2170854885 0110/5600523106 ALLSTATE INSURANCE COMPANY $7, 500.00 2170859885 0131/4600532558 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0204/8600534707 ALLSTATE INSURANCE COMPANY $51.36 2170854885 0204/9600534708 ALLSTATE INSURANCE COMPANY $8, 250.00 2170854885 0217/9600541301 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 2010 fik w. 1 le I" II• 1 I V' I IV 1 I'S 0' I Ii• 1 VS Or I'S 01 2010 2010 11•111. 2010 REHAB IF" II, s 11, 2010 1 I 2010 2010 VII. 1 I'S I r 2010 REHAB r 2010 tio. P, 1 II s• 1 VS r I'S I 0 2010 I I'll, 2010 REHAB i• I. e• rk, I. P. I a. I'S 1 u s• vs 1 I 2010 2010 I'S o 2010 REHAB 2010 4). o• 1 1 1 1.• e 2010 It7V. 2010 I. V. I I' 1 I'S V 0' 1 VS. 2010 REHAB Il• 2010 I+ 1 I 2010 SNII, IP S' I..0 0 a 2010 REHAB II" I, 1 I 111 VI 11. I. 1 I V' VS SNIIP. 1 I 10 1 VI 0 1 I II' 1 11•0 S 2010 2010 2010 RE1tAB IV II. 2011 i• I, fr. la, e I'la r 1 vis w S' 1 I'S a Il• 1 •I II I 01 1 e s• 11, 1 I I'll, •1 I 1014/8600483989 V' 2011 2011 2011 2011 REHAB 1-LORIDA INS! .HU I t 1-UK NtURULUUL 2011 REHAB 18 0222/9600543719 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages Page 70 of 157 PagelD 70 Chart Payment Payment Pa Icor Payee Date Amount Claim No. Check No. ALLSTATE INSURANCE COMPANY $35.00 ALLSTATE INSURANCE COMPANY $7, 500, 00 2170854885 0324/3600559094 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0331/2600562034 ALLSTATE INSURANCE COMPANY $8, 250.00 2170854885 0408/4600566694 ALLSTATE INSURANCE COMPANY $7, 500.00 2170859885 0908/5600566695 ALLSTATE INSURANCE COMPANY $6, 000.00 2170859885 0408/6600566696 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0511/9600581557 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0519/2600586091 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0520/4600587064 ALLSTATE INSURANCE COMPANY $278.12 2170854885 0523/1600587295 ALLSTATE INSURANCE COMPANY MIN 2170854885 0526/5600589077 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0602/1600592178 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0606/6600593527 ALLSTATE INSURANCE COMPANY $7, 500, 00 2170854885 0607/2600599443 ALLSTATE INSURANCE COMPANY $8, 250.00 2170854885 0610/5600595888 ALLSTATE INSURANCE COMPANY $7, 500, 00 2170854885 0627/3600603413 ALLSTATE INSURANCE COMPANY $210.00 2170854885 0630/5600605263 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0706/5600607231 ALLSTATE INSURANCE COMPANY $7, 500.00 2170854885 0708/4600609104 ALLSTATE INSURANCE COMPANY $105.00 2170854885 0826/6600631152 ALLSTATE INSURANCE COMPANY $6, 500.00 2170859885 0912/4600638094 2011 REHAB ALLSTATE INSURANCE COMPANY $775, 25 2170859885 0502/0164788319 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $787.89 2172448520 0506/7600265409 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $10, 450.00 2172448520 0528/5600273864 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2172948520 0604/2600277113 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $138.83 2172448520 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $298.47 2172448520 0714/2600293169 2011 iv il 1 1 ir, 1 I S' N vs r I'S S• 2011 REHAB so 2011 2011 vie. 2011 1 s e. 1 I 9' 1 vs r I'S 9 It1N sow 2011 REi LAB 2011 II° I. 1 V II' 1 I"11 r 2011 2011 1 I 9' 1 19 r 2011 REHAB 2011 I'S 01 Il• I• I V• I, I 9' 1'9 1 il" I'S I 11" 1 I'S r e a* 1 Ivo r 2011 •2011 REHAB V' 11, 1 2011 11•11. 2011 ip. P. 1 2011 2011 ir. IiI1 ip, 1 1 1-•• ir 0' VI r II' I'S Ir 1 e. I I 2011 I. 5, 2011 REHAB 11 11, 2011 2011 11411 1 I II' 10 2170854885 0303/4600547999 r 19 2172448520 0528/4600273863 0604/3600277114 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 71 of 157 PagelD 71 Exhibit 1: Damages Chart Payment Payment Payee Date Payor Amount Claim No. Check No. 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $10, 950.00 2172418520 0721/2600296058 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172148520 0804/0600302080 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 0804/1600302081 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172148520 0804/7600302077 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 400.00 2172948520 0804/8600302078 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2172448520 0804/9600302079 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172948520 0914/6600317674 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 0914/7600317675 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 2172948520 0914/8600317676 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 2172448520 1012/5600328960 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172118520 1012/6600328961 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 1020/7600332145 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 1105/0600338672 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500, 00 2172498520 1105/9600338671 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 2172498520 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172498520 1210/8600350376 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172498520 1210/9600350377 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2172498520 1229/7600357837 ALLSTATE INSURANCE COMPANY $8, 500.00 2172498520, 0105/8600361158 ALLSTATE INSURANCE COMPANY $8, 500.00 2172498520 0804/6600302076 1026/2600333825 1125/1600345126 1-WRIDA INS I 11 Ul 1 HJR NLURUUJCill. 2010 REHAB 1-LUR1DA INS IllUIL f-UR NtUROLLHAL 2010 REHAB 20 010519600361771 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Page 72 of 157 PagelD 72 Damages Chart Payment Payment Payor Payee Date Amount Claim No. Check No. ALLSTATE INSURANCE COMPANY $9, 350.00 2172448520 020410600375112 ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 0212/0600378351 ALLSTATE INSURANCE COMPANY $8, 500,00 2172448520 0217/1600379009 ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 0305/7600388661 ALLSTATE INSURANCE COMPANY $6, 800.00 2172448520 0316/2600393481 ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 0318/8600394766 ALLSTATE INSURANCE COMPANY $9, 350.00 2172448520 0401/3600401217 ALLSTATE INSURANCE COMPANY $8, 500.00 2172448520 0413/0600406144 ALLSTATE INSURANCE COMPANY $9, 150.00 2172448520 0413/1600406145 ALLSTATE INSURANCE COMPANY $8, 500.00 2172948520 0413/9600406143 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0506/2600416716 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0506/3600416717 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0527/1600425393 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0527/2600425394 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0615/6600431937 ALLSTATE INSURANCE COMPANY $8, 250, 00 2172498520 0615/7600431938 ALLSTATE INSURANCE COMPANY $7, 500.00 2172498520 0701/7600439829 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0712/3600443224 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0721/8600447684 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0803/5600452918 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0803/6600452919 ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 0824/4600462281 ALLSTATE INSURANCE COMPANY $8, 250, 00 2172448520 2010 REHAB ALLSTATE INSURANCE COMPANY $7, 500.00 2172448520 1005/3600480145 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0629/4382513734 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0710/7382539429 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910986 0719/1382571766 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 950.00 2553910486 0808/1382635018 2010 1 I 0' I'S I' 2010 REHAB r 2010 li e• s• o, e• t, 1 al e• 5•1I. 1 I I" 1 I 0" vs 2010 2010 1 I'S 2010 REHAB 1^^ l'S I 2010 iv, 11, I. IA e• r 2010 1 I 10 I'S S' I IP1 I'S 5' 2010 REHAB 1, 2010 REHAB 2010 IP' I. 5' I. 1 111' 11•0 2010 V 1 I'S 2010 REHAB 5' 1 S' I V I IP' 1•11 2010 1 UPI 2010 REHAB 5' 10. I'S IV I'S IP' 2010 REHAB 1 2010 1 S' IIIUH psJqijll{sIIs1eIu 2010 I I II, II' 1 •'S 2010 REHAB 1 r•Is II 2010 2010 5' 59). I'S 5' 1'0 Ir 2010 REHAB 1 I 1 I 1 2010 I" 5' 0829/5600462282 I's 21 0731/8382609062 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 73 of 157 PagelD 73 Damages Chart Payment Payment Date Page Payee Amount Payor Claim No. Check No. 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $485.28 2553910486 0809/1382646088 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $3, 900.00 2553910486 1226/9383229036 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0103/4383266233 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE $9, 350.00 2553910486 0111/9383306427 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0119/2383391689 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0130/3383388912 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 2553910486 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0220/8383978075 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0301/2383520726 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 800.00 2553910486 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0321/2383605259 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0410/2383699007 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 350.00 2553910486 0416/8383723955 $8, 500.00 2553910486 2007 FLORIDA INSTITUTE FOR COMPANY, NEUROLOGIC, ALLSTATE INSURANCE COMPANY_ 0209/9383437755 0307/1383547222 0423/6383755896 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910986 0501/3383792067 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 500.00 2553910486 0511/2383835771 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 700.00 2553910486 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 550.00 2559932129 1106/5137421339 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2559932129 1118/0144542054 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2559932129 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500,00 2559932129 1208/2107421748 22 0521/2383867442 1130/3104419778 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 74 of 157 PagelD 74 Exhibit 1: Damages Chart Payment Payment Date Payor Payee Amount Claim No. Check No. 1216/3167618755 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2559932129 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2559932129 1230/5137431993 ALLSTATE INSURANCE COMPANY $10,450.00 2559932129 0115/2170718814 ALLSTATE INSURANCE COMPANY =El 2559932129 0120/4127421856 ALLSTATE INSURANCE COMPANY $9, 500.00 2559932129 0120/5127421857 ALLSTATE INSURANCE COMPANY $9, 500.00 2559932129 0127/9190705381 ALLSTATE INSURANCE COMPANY $5, 700.00 2559932129 020818180752642 ALLSTATE INSURANCE COMPANY $8, 900.00 2559932129 0225/2130538718 ALLSTATE INSURANCE COMPANY 1111.ffil 2559932129 0225/3157611983 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 0301/1177628347 ALLSTATE INSURANCE COMPANY $6, 800.00 2559932129 0310/5134422714 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 0317/8130544680 ALLSTATE INSURANCE COMPANY $8, 500,00 2559932129 0330/0107456733 ALLSTATE INSURANCE COMPANY $9, 350.00 2559932129 0420/8167671424 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 ALLSTATE INSURANCE COMPANY $1, 168.83 2559932129 0422/5197639108 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 0427/0120496622 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 0518/0120502500 ALLSTATE INSURANCE COMPANY $1, 410.30 2559932129 0520/0130570884 ALLSTATE INSURANCE COMPANY $17, 000, 00 2559932129 0526/4114454637 ALLSTATE INSURANCE COMPANY $599.40 2559932129 0622/9157664433 ALLSTATE INSURANCE COMPANY $17, 850.00 2559932129 0625/0170797850 ALLSTATE INSURANCE COMPANY $8, 500.00 ME 0629/4110573120 ALLSTATE INSURANCE COMPANY $1, 094.12 2559932129 0720/8180825595 ALLSTATE INSURANCE COMPANY $3,100.00 2559932129 0727/3130589480 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 0803/0104504093 ALLSTATE INSURANCE COMPANY $9, 350.00 2559932129 0818/8147724817 ALLSTATE INSURANCE COMPANY $248.12 2559932129 0819/6170824905 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 0830/0114489742 2010 REHAB LURIDAINSHIUILIUR NEUROLOUIL ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 0914/7120540736 2010 REHAB ALLSTATE INSURANCE COMPANY $4, 250.00 2559932129 0929/6154672530 Il• D. 1 I 1 I'S D. 1 I I vs 2010I 2010 REHAB V" 11, I I•S I VS 2010 REHAB S' 0., 2010 10. 1 410 1 VS II I'S V' 2010 REHAB 1 V D., V I" D. I 111' 0•1 IL I II' a D. 2010 REHAB I'S 111 2010 1 1•10 0' 2010 2010 REHAB I' D. 0 ill• 11' IL, II 0' 11. 0 r 2010 1 I•• 2010 VII. 1 I I'S 2010 REHAB iv o, 1 I V' VII II. D. 1 I 0' 1°0 Ir 0. 1 Il• 11•5 Ir 2010 2010 2010 REHAB S• 0., I S', VI fle 1 I I" 1 VS r 2010 D. 2010 II?11111II IUIUIIikIi1 uji.iuiejti 2010 I IV IL 1 I Il• 11•0 11" ID' IL 1 I I" I'S 11' 2010 2010 0420/9167671425 i IV IL I IV, 01•0 I S• IL I 0•, I'S I 2010 2010 REHAB Il• It., I II', VII IP' D. 1 I 1 I'S S• a., V I' I•S 2010 2010 I 2010 REHAB i-LORIDA iNs IIIUIL RA( NEURDLOCIIC 2010 REHAB IV D. 1 I I' 1 I'S Ir f• I, 1 I Il• 1 V* 5 2010 23 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Page 75 of 157 PagelD 75 Damages Chart wis•W•11.1••• Payment Payment Date Payor Payee FLORIDA INS II IUIL Amount Claim No Check No NtURULtitiR, ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 1013/9107509483 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 1021/0150807974 ALLSTATE INSURANCE COMPANY $839.16 2559932129 1022/1147754564 2010 REHAB FLORIDA INS LUU IL TOR NELIROLOGIL ALLSTATE INSURANCE COMPANY $7, 650.00 2559932129 1025/5104531165 2010 REHAB FLORIDA INS I I I LI it FUR NtLIKULUb1C ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 1025/6127501148 2010 REFIAB ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 1027/5170855808 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 1027/9170855809 ALLSTATE INSURANCE COMPANY $8, 500.00 2559932129 1104/9197733913 ALLSTATE INSURANCE COMPANY $9, 350.00, 2559932129 1108/8180876301 2010 REHAB FLORIDA Prism u I L FOR NEUROLOGIC 2010 REHAB FLORIDA INSIIIUI t FOR NEUROLOGIC- 2010 REHAB FLORIDA INSII tUR NEUROLLX311. FLORIDA INSIII UI t FUR NtUROW6IL 2010 REHAB FLORIDA INSIII U I t FUR NhUROLOWL 2010 REHAB FLORIDA INS III Ul L FUR NELJROLUb1(... 2010 REFIAB FLORIDA INSIIILlIt FOR NEUROLOGIC, ALLSTATE INSURANCE COMPANY $268.25 2559932 129 1019/8110607723 2011 REHAB ALLSTATE INSURANCE COMPANY $672, 00 2559932129 0502/0164788320 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $630.00 2881939595 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 160.00 2881939595 0309/4383559633 2007, FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 240.00 2881939595 0309/5383559642 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0321/6383606325 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 160.00 2881939595 0321/7383606334 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 530.46 2881939595 0326/8383630346 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0409/7383687712 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 234.51 2881939595 0501/7383792778 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 0501/8383792787 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0522/3383872716 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0607/1383933367 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2010 REHAB FWRIDA INS! IIUI FOR NWROLObIL 24 0221/4383485689 0419/6383745303 0501/9383792796 0612/3383947893 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 76 of 157 PagelD 76 Exhibit 1: Damages Chart Payment Payment Date Payer Payee Amount Claim No. Check No. 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $925.86 2881939595 0613/4383953779 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 0626/2383995845 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0626/3383995854 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0725/6384110658 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0727/7384118938 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 060.82 2881939595 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0801/8384133572 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 0814/5600002818 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0911/1600019427 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $904.97 2881939595 0911/2600014426 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 0926/4600021295 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $651.82. 2881939595 1002/5600024178 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 1002/6600024179 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 1002/7600024524. 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 1025/0600033835 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 1029/7600034954 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 129.85 2881939595 1030/4600035456. 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 1126/0600046243 NEUROLOGIC, ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 1126/1600046662 2007 FLORIDA INSTITUTE FOR 25 0710/3384050232 0730/4384123492 0828/3600009482 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 77 of 157 PagelD 77 Exhibit 1: Damages Chart Payment Date Payment Payee Payor Amount Claim No. Check No. 1207/4600051732 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $7.89 2881939595 0616/4600130530 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1.24 2881939595 1224/3600207497 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5.92 2881939595 1224/5600207498 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1.24 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0109/0600062389 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $600.00 2881939595 0109/1600062390 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 183.80 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 0111/0600063884 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0114/0600064072 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0121/3600066969 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 103.33 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0128/6600070315 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0128/7600070316 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 425.00 2881939595 0212/7600075890 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0225/0600080371 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1,442, 39 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0307/6600086167 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 400.00 2881939595 0326/7600092110 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000, 00 2881939595 0326/8600092357 26 2881939595 1224/7600207499 0109/9600062388 0124/0600068590 0201/2600072466 0306/8600085666 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 78 of 157 PagelD 78 Exhibit 1: Damages Chart Payment Payment Date Payee Payor Amount Claim No. Check No. 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $968.20 2881939595 0409/9600097413 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 0428/2600106075 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0508/8600111007 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $868, 31 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0512/8600112101 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0605/2600124754 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0616/3600130530 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0717/0600142149 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0717/1600142450 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 0717/9600142189 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 134.51 2881939595 0718/0600143592 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 134.51 2881939595 0718/9600143591 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 529.81 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $953.55 2881939595 0722/8600194844 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0728/8600147195 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 033.46 2881939595 0806/0600150340 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 865.49 2881939595 0811/5600151882 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0815/0600154863 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 0829/3600160516 27 2881939595 2881939595 0404/5600095768 0512/7600112100 0616/2600129690. 0722/7600194843 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages 79 of 157 PagelD 79 Chart Payment Payment Date Page Payee Payor Amount Claim No. Check No. 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 121.88 2881939595 0904/5600162318 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0908/6600164316 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0922/2600169747 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 860.79 2881939595 1009/7600176510 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 1017/7600180256 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000, 00 2881939595 1030/3600185605 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 340.20 2881939595 1112/7600190904 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 340.20 2881939595 111218600190905 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 1113/7600191869 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 1117/5600193044_ 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 261.77 2881939595 1224/2600207497 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 1224/4600207498 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 261.77 2881939595 1224/6600207499 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 200.00 2881939595 1226/6600208007 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $21.70 2881939595 0123/7600219041 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 552,32 2881939595 0115/5600215334 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0123/6600219041 28 1009/6600176509 1030/4600185606 1112/9600191292 1224/8600207630 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Page 80 of 157 PagelD 80 Damages Chart Payment Payment Payee Date Payor Amount. Claim No. Check No. 0127/1600220050 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 600.00 2881939595 0128/0600220678 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 0204/9600223661 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $959.94 2881939595 0205/6600224156 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $6, 000.00 2881939595 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 400.00 2881939595 0220/2600231540 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $1, 480.20 2881939595 0312/4600241483 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 550.00 2881939595 1201/9600346785 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2881939595 1210/9600350493 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 500.00 2881939595 1222/8600355730 ALLSTATE INSURANCE COMPANY $9, 500.00 2881939595 0112/6600364961 ALLSTATE INSURANCE COMPANY $9, 500.00 2881939595 0114/5600366196 ALLSTATE INSURANCE COMPANY $9, 500.00 2881939595 0212/0600378808 ALLSTATE INSURANCE COMPANY $9, 500.00 2881939595 0212/1600378809 ALLSTATE INSURANCE COMPANY $7, 600.00 2881939595 0212/8600378806 ALLSTATE INSURANCE COMPANY $10, 450.00 2881939595 0212/9600378807 ALLSTATE INSURANCE COMPANY $8, 500.00 2881939595 0310/9600391093 ALLSTATE INSURANCE COMPANY $8, 500.00 2881939595, 0315/8600392455 ALLSTATE INSURANCE COMPANY $6, 800.00 2881939595 ALLSTATE INSURANCE COMPANY $8, 500.00 2881939595 0329/4600399083 ALLSTATE INSURANCE COMPANY $7, 500.00 2881939595 0412/6600405101 ALLSTATE INSURANCE COMPANY $7, 150,00 2881939595 0412/8600405518 ALLSTATE INSURANCE COMPANY $6, 500.00 2881939595 2010 REHAB 1-LORIDA INS hUlL FOR NEUROLOGIC, ALLSTATE INSURANCE COMPANY $5, 2881939595 0428/9600413742 20101REHAB ALLSTATE INSURANCE COMPANY FLORIDA INS $600.00 2881939595 1202/5600347019 FUR NEUROLOGIC UI 2010 REHAB '1-LOR1DA INS tIlUlt FUR NEUROLOGIC 2010 REHAB 1-LORIUA INS FUR NEUROLOGIc 2010 REHAB 'FLORIDA COMPANY_ 0211/8600226990 INS III lilt FOR NEUROLOGIL. 2010 REHAB FLORIDA INS IlwIt FOR NEUROLOGIC 2010 REHAB FLORIDA INS alum FOR NEUROLoGR, 2010 REHAB FLORIDA INS HIM E NEUROLoGic 2010 REHAB FLORIDA INS ifluit FOR NEUROLOGIC 2010 REHAB FLORIDA INS IIIUIL I-OR NEUROLOOR, 2010 REHAB 0325/8600397624 FLORIDA INS IIIUIL VOR NtuROLOGIc 2010 REHAB FLORIDA INS! 11 t FOR NEUROLOGIL 2010 REHAB FLORIDA INS EH LPL FOR NEUROLOGIC 2010 REHAB FLORIDA INS IIIUIE OR NEUROLOGIC 2010 REHAB 't-WRII)AINSIIIIJIL 0428/8600413604 FOR NEUROLOGIC 29 850.00, $314.81 2881939595 0611/1600430818 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages Page 81 of 157 PagelD 81 Chart Payment Payment Payee Date *RUM I Payor S 2010 REHAB I I I II. 01411. I Check No. ALLSTATE INSURANCE COMPANY $9.37 2882309301 0414/2600406364 ALLSTATE INSURANCE COMPANY $10.52 2882309301 0817/0600459558 ALLSTATE INSURANCE COMPANY $22, 800.00 2882309301 0202/2600373639 ALLSTATE INSURANCE COMPANY $10, 450.00 2882309301 0223/0600383006 ALLSTATE INSURANCE COMPANY $9, 500.00 2882309301 0309/2600389898 ALLSTATE INSURANCE COMPANY $9, 500.00 2882309301 0315/9600392905 ALLSTATE INSURANCE COMPANY $7, 600.00 2882309301 0323/1600396648 ALLSTATE INSURANCE COMPANY $9, 500.00 2882309301 0414/1600406364 ALLSTATE INSURANCE COMPANY $8, 600.00 2882309301 0419/1600408867 ALLSTATE INSURANCE COMPANY $8, 800.00 2882309301 0505/9600416158 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0517/7600421107 ALLSTATE INSURANCE COMPANY $7, 200.00 2882309301 0517/8600421108 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0614/5600431361 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0614/6600431362 ALLSTATE INSURANCE COMPANY $8, 800.00 2882309301 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0708/8600441792 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0712/3600443280 ALLSTATE INSURANCE COMPANY $9, 484.00 2882309301 0726/5600450124 ALLSTATE INSURANCE COMPANY $6, 400.00 2882309301 0817/9600459558 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0824/6600462289 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 082710600464321 ALLSTATE INSURANCE COMPANY $8, 800.00 2882309301 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0908/6600467726 ALLSTATE INSURANCE COMPANY $8, 800.00 2882309301 0923/8600475212 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0930/8600478780 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 1020/8600487141 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 1025/7600488463 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 1110/0600496173 ALLSTATE INSURANCE COMPANY $8, 800.00 2882309301 1122/7600501682 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 1130/1600504383 I'S 2010 011 I'S s I'S r 2010 REHAB s Claim No. I'S 2010 s Amount IS 2010 I'S 2010 I S'r 1 I Ii•Ir 1 I O' 1 I'S 1 I'S 2010 2010 REHAB S• r I II' 1 I'S I I' 1 I'S I 5" I'S 2010 liii IIJ1 I 2010 2010 REHAB L-LORIDA INSIIILHE FOR NEUROLOGIC 2010 REHAB V l'• I 0" I•S I I 0' 1 I 2010 11410" 2010 REHAB S• 1 I'S 2010 I" 20101 114111. I 5" I'S 5' 2010 REHAB LOMA INS I I UIE FOR. NEUROLOGIC 2010 REHAB s. s• re 2010 CID. 1 S.' 1 1'5 1 I'S 2010 REHAB I f• 2010 I" 1 I 0' 1 I'S 10 5. 1 I 5' 1 I'S 0' 2010 2010 REHAB I o. iv' I'S 2010 I. 1 I S' I 5' I I'D 2010 5" 1 I I'S 2010 2010 1"11 I I 5' I'S I S I'S 2010 REHAB 1 2010 REHAB 1101/2600491785 r 2010 I" 0930/9600478781 I'S 2010 REHAB I" 0903/5600466923 I'S 2010 0. 0706/4600440773 I'S 111 SI 30 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages Page 82 of 157 PagelD 82 Chart Payment Payment Payee Date Payor Amount Claim No. Check No. ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 1209/0600509372 ALLSTATE INSURANCE COMPANY $5, 600.00 2882309301 1216/6600512868 ALLSTATE INSURANCE COMPANY $8,000.00 2882309301 1227/2600516589 ALLSTATE INSURANCE COMPANY $6, 400.00 2882309301 0107/0600522410 ALLSTATE INSURANCE COMPANY $7, 200.00 2882309301 0204/8600535453 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0207/9600535619 ALLSTATE INSURANCE COMPANY $8, 800.00 2882309301 0216/8600540619 ALLSTATE INSURANCE COMPANY $8,000.00 2882309301 0222/6600543707 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0310/5600551526 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0404/6600563976 ALLSTATE INSURANCE COMPANY $4, 800.00 2882309301 0420/5600571868 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0420/6600571869 2011 REHAB ALLSTATE INSURANCE COMPANY $6, 400.00 2882309301 0420/7600571870 2011 ALLSTATE INSURANCE COMPANY $7, 200.00 2882309301 0425/2600574042 ALLSTATE INSURANCE COMPANY $8, 000,00 2882309301 0505/0600579069 •2011 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0516/6600584649 2011 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0519/5600586073 ALLSTATE INSURANCE COMPANY $8, 800.00 2882309301 0617/9600599437 ALLSTATE INSURANCE COMPANY $8, 000.00 2882309301 0720/5600613857 ALLSTATE INSURANCE COMPANY $7, 200.00 2882309301 0720/6600613858 ALLSTATE INSURANCE COMPANY $13, 815.20 2882309301 0804/7600620992 ALLSTATE INSURANCE COMPANY $8, 338.91 2882309301 0804/8600620993 ALLSTATE INSURANCE COMPANY $8, 930.50 2882309301 0831/7600632841 ALLSTATE INSURANCE COMPANY $9, 728.50 2882309301 0831/8600633453 ALLSTATE INSURANCE COMPANY $250, 25 2882309301 0502/2164788322 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 0102/8374998275 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 0102/9374998284 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 0111/2375061905 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 200.00 2901672985 0123/3375127002 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $6, 300.00 2901672985 0123/4375127011 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 0215/2375249123 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 700.00 2901672985 0221/9375280668 2010 IP' 11, 1 I 0" VS W 2010 I•S I I •2010 REHAB I. 1 i e• 1 us r 1 I 41• 1 I'S W 2011 V It 2011 2011 lV 0' I. I 1 I'S W 2011 REHAB e• 1 1 il• 1 vs e (1•10. 1 I 41. 1 I'S 0 I 0' I'S W 1 1'0 Or 2011 2011 I Ilt 2011 REHAB 41' It I II' IP' It 11 II' 1•0 V- I I' I'S W 2011 2011 II, 1 2011 S'ill. I I'S S• REHAB V II, I. It 1 I IV' I O• 1 I'S W l'S W 2011 2011 REHAB 2011 O• It 1 I 0' 1 1'0 0 2011 2011 i P., I V' 11•• V I 11' IVO W 2011 REHAB Il• I. 1 2011 REHAB tWRIDA 'NS i 1 I U I E MR NEURULUbIL 2011 REHAB 31 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 83 of 157 PagelD 83 Damages Chart Payment Payment Date Page Payee Check No. Claim No. Amount Payor 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 0306/3375345657 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 2002 FLORIDA INSTITUTE FOR NEURO REI IAB INC ALLSTATE INSURANCE COMPANY $5, 600.00 2901672985 0312/3375374214 2002 FLORIDA INSTITUTE FOR NEURO REI IAB INC ALLSTATE INSURANCE COMPANY $7, 700.00 2901672985 0409/0375520977 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7,000.00 2901672985 0418/1375572817 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 0419/9375580737 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 0422/3375589701 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 0429/6375624504 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $7, 000.00 2901672985 0509/0375692112 2002 FLORIDA INSTITUTE FOR NEURO REI IAB INC ALLSTATE INSURANCE COMPANY $7, 000, 00 2901672985 0522/8375768864 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $700.00 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $97.32 2901672985 0822/1377922042 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 500.00 2901672985 0321/0377210781 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $850.00 2901672985 0327/0377245305 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 000.00 2901672985 0402/0377278443 2003 FLORIDA INSTITUTE FOR NEURO REI IAB INC ALLSTATE INSURANCE COMPANY $8, 800, 00 2901672985 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE $8, 000.00 2901672985 0505/3377433918 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $6,400.00 2901672985 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 000.00 2901672985 0527/4377533845 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8,000.00 2901672985 0529/6377546121 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 000.00 2901672985 0616/0377625312 $8, 800.00 2901672985 0616/1377625321 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8,000, 00 2901672985 0708/9377720478 INC, ALLSTATE INSURANCE COMPANY $800.00 2901672985 0716/0377759205 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $8, 000.00 2901672985 0730/2377821305 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $43.10 2901672985 0109/3670410855 2002 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 1231/2376807068 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $0.88 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000,00 INC, ALLSTATE INSURANCE COMPANY $164.14 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0205/1376987698 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0214/9377034174 2003 FLORIDA INSTITUTE FOR NEURO IAB INC ALLSTATE INSURANCE 2003 FLORIDA INSTITUTE FOR NEURO REHAB 2003 FLORIDA INSTITUTE FOR NEURO REHAB 32 COMPANY_ COMPANY, 0312/2375374205 2901672985 2907688985 0605/4375826851 0423/8377378181 0522/9377521407 0311/0377150436 2907688985 0116/1376891569 2907688985 0120/9376904394 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 84 of 157 PagelD 84 Damages Chart Payment Payment Date Page Payee Payer Amount Claim No, Check No. 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $1, 000.00 2907688985 0219/4377053767 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 0221/7377064369 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0221/8377064378 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $14, 500.00 2907688985 0309/2377112393 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $89, 29 2907688985 0310/4377140923 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500, 00 2907688985 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0311/8377150427 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $223.28 2907688985 0311/9377150436 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0324/6377219187 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 0331/1377261649 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $138.04 2907688985 0331/2377261658 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0331/3377261667 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 29076813985 0424/0377382555 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0505/3377932667 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0514/3377480691 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $159.17 2907688985 0514/4377480709 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $193, 90 2907688985 0529/6377545293 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0529/7377545302 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0606/4377586279 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0617/8377632611 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0619/5377646174 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 062016377651322 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $127, 32 2907688985 0711/1377737866 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0714/2377745858 2003 FLORIDA INSTITUTE FOR NEURO REFIAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0724/8377792919 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 072510377798175 0311/7377150418 0415/8377391299 0602/8377558667 INC., ALLSTATE INSURANCE COMPANY $351.05 2907688985 0725/9377798166 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0805/6377845749 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0812/7377876205 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $93,02 2907688985 0908/7377990838 2003 FLORIDA INSTITUTE FOR NEURO REHAB 33 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 85 of 157 PagelD 85 Damages Chart Payment Date Page Payment Payee Payor Amount Claim No. Check No. 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0908/8377990847 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0922/2378060714 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1006/6378123408 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $217.82 2907688985 1015/2378168696 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 500.00 2003 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $213.97 2907688985 1015/3378168705 2907688985 1112/7378288675 ALLSTATE INSURANCE COMPANY $3.62 2907688985 0311/2378819864 2009 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $23.51 2907688985 0929/2379019007 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $98.82 2907688985 0803/3379417797 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $60.66 2907688985 0804/1379425708 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $37,81 2907688985 0806/3379438092 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $23.01 2907688985 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $200.71 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $30.00 2907688985 0108/8670413267 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 0203/8378628884 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0213/0378686448 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000,00 2907688985 0305/8378793872 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $297.88 2907688985 0305/9378793881 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0322/9378867177 2004 FLORIDA INSTITUTE FOR NEURO REFIAB INC ALLSTATE INSURANCE COMPANY $4, 500.00 2907688985 0329/3378902093 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $161.67 2907688985 0419/0378964242 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5,000.00 2907688985 0427/4379005678 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0428/6379011384 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0429/1379019007 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0602/4379155033 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0602/5379155092. 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0621/7379235709 2004 FLORIDA INSTITUTE FOR NEURO REI1AB INC ALLSTATE INSURANCE COMPANY $15, 000.00 2907688985 0628/1379260351 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $88.60 2907688985 0722/1379368684 $5, 500.00 2907688985 0803/2379417797 2009. FLORIDA INSTITUTE FOR NEURO REHAB INC 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC, ALLSTATE INSURANCE COMPANY 34 0811/9379457037 2907688985 0824/0379512954 0311/1378819864 0505/9379046259 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 86 of 157 PagelD 86 Damages Chart Payment Date Page Payment Payee Amount Payor. Claim No. Check No. 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 500.00 2907688985 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0806/1379438083 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0806/2379438092 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $44.30 2907688985 0811/0379457046 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0811/1379457055 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0811/8379457037 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $25, 000.00 2907688985 0819/7379491876 2009 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0824/9379512954 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE $5, 000.00 2907688985 0826/1379525473 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0831/4379544058 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0910/7379590714 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0924/4379655766 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0930/0379682793 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $4, 000, 00 2907688985 100817379725669 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1028/9379804977 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1108/5379849743 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 1118/0379890576 2009 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1207/9379968723 2004 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0104/2380083401 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0110/2380112066 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0120/7380165337 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $55.99 2907688985 0408/0380560518 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0411/0380567367 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0414/9380584584 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0428/9380657331 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $55.94 2907688985 0510/7380710143 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000, 00 2907688985 0510/8380710152 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0520/7380757672 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0601/6380802042 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $12.82 2907688985 0610/7380891246 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985, 0610/8380841255 35 COMPANY, 0804/0379425708 1214/3380002032 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages 87 of 157 PagelD 87 Chart Payment Payment Date Page Payee Payor Amount Claim No. Check No. 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0615/0380862288 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0617/0380875491 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0623/6380899287 2005 FLORIDA INSTITUTE FOR NEURO REF1AB INC. ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0705/7380948877 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $59.42 2907688985 0705/8380948886 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0715/8380993913 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $122, 79 2907688985 0722/3381026403 2005 FLORIDA INSTITUTE FOR NEURO REHAI3 INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0727/0381096923 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0809/3381101589 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0824/8381170214 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $50.76 2907688985 0901/4381210777 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0907/2381222648 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0916/8381267828 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0926/2381312738 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $72.23 2907688985 0926/3381312747 0819/0381151485 INC. ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1012/0381390354 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1018/7381412994 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1024/1381435489 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1027/2381452625 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 1123/4381562452 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1205/7381604752 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1207/1381620403 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1209/3381634551 2005 FLORIDA INSTITUTE FOR NEURO REHAB INC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1228/4381717639 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0110/7381766527 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0111/7381771846 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0202/0381860568 2005 FLORIDA INSTITUTE FOR NEURO REHAB 36 0201/8381853368 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 88 of 157 PagelD 88 Damages Chart Payment Payment Date Page -Payee Payer Amount Claim No. Check No. 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500, 00 2907688985 0215/4381923514 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0222/8381956904 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0301/0381994947 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 0314/5382046184 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0329/9382124511 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500, 00 2907688985 0417/0382206978 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000, 00 2907688985 0424/5382237938 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0503/0382285908 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0516/3382336389 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5,000,00 2907688985 0523/2382366584 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0616/6382464531 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000, 00 2907688985 0626/2382499577 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0731/6382609296 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0731/7382609305 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $55.39 2907688985 0814/6382662783 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0829/9382730805 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0927/9382859442 37 0321/2382081464 0608/6382428477 0629/7382513815 0807/6382635117 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 89 of 157 PagelD 89 Damages Chart Payment Date Page Payment Payee Payer Amount Claim No. Check No. 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 1002/1382878558 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 1002/2382878567 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1016/5382933665 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1025/3382973994 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000, 00 2907688985 1106/3383021838 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 1115/5383072805 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1121/6383099247 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $77.43 2907688985 1128/2383120172 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1130/5383133231 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $3, 500.00 2907688985 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1226/9383229099 2006 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1229/3383249016 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0119/3383341752 2007 FLORIDA INSTITUTE FOR NEUROLOGIC :ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0130/5383388948 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0209/7383437782 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 500.00 2907688985 0222/8383491332 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $125.00 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 38 2907688985 0928/5382866183 1023/8382959459 1211/2383169492 0111/5383306481 0223/4383496579 2907688985 0301/1383520798 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 90 of 157 PagelD 90 Exhibit 1: Damages Chart Payment Payment Date Payee Payor Amount Claim No. Check No. 2007 FLORIDA INSTMITE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 0307/8383547294 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0326/4383629644 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0416/6383724027 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0424/5383763285 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0501/9383792175 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5,000.00 2907688985 0504/2383809401 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0511/6383835843 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0521/6383867487 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 0605/1383923395 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0608/9383938353 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0621/6383986548 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0703/5389029955 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0713/1384067017 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 500.00 2907688985 0808/0600000540 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0816/4600004014 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $2, 000.00 2907688985 0914/3600016568 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $170.00 2907688985 0917/2600016786 2007, FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0927/3600022360 39 0430/7383784579 0730/7384123195 0824/3600008815 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 91 of 157 PagelD 91 Damages Chart Payment Date Page Payment Payee Amount Payor Claim No. Check No. 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1010/5600027599 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000, 00 2907688985 1019/9600031622 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1022/8600032107 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1026/1600034434, 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $212.65 2907688985 1026/2600034738 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $212.65 2907688985 1031/4600035990 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1031/5600035991 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1101/0600036594 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 1112/5600040525 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE $4, 500, 00 2907688985 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1130/7600049222 2007 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $3, 500.00 2907688985 1231/0600058721 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0121/0600066941 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000,00 2907688985 0204/6600072762 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY -$212.65 2907688985 0212/7000000000 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0220/2600079408 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0303/8600084185 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 500.00 29076813985 40 COMPANY, 0928/16000225136 1121/7600045554 0116/4600065234 0219/4600078442 0318/9600089381 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 92 of 157 PagelD 92 Damages Chart Payment Date Page Payment Payee •Payor Amount Claim No. Check No. 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 010319600095044 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0414/7600098939 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $3, 500.00 2907688985 0505/0600108994 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0520/7600115843 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0527/3600118474 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0605/1600124584 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0619/1600132595 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0714/2600140946 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 535.00 2907688985 0723/4600145211 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0728/2600146577 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0807/4600151086 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 535.00 2907688985 0826/5600158507 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0910/3600165008 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $3, 750.00 2907688985 1013/7600177625 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $3, 750.00 2907688985 1013/8600177948 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1121/3600195974 41 0401/7600094362 0505/9600108993 0701/6600137019 0820/3604156072 0918/5600168501 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages 93 of 157 PagelD 93 Chart Payment Payment Date Page Payee Payor Amount Claim No. Check No. 1121/4600195975 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $2, 500.00 2907688985 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1125/2600197215 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1125/3600197216 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 1212/8600203654 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1215/4600204161 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 535.00 2907688985 1217/9600205624 2008 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1230/7600208679 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0121/6600217433 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0121/7600217434 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500, 00 2907688985 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0209/1600225723 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0209/9600225721 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 845.00 2907688985 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000, 00 2907688985 0306/9600238800 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 0313/7600242464 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00. 2907688985 0403/8600251628 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0410/9600254265 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0429/3600262469 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0504/7600264163 42 0121/5600217432 0209/0600225722 0306/0600238801 0323/1600245479 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 94 of 157 PagelD 94 Exhibit 1: Damages Chart Payment Date Payment Payee, Amount Payor Claim No. Check No. 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 69000 2907688985 0513/0600268139 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0526/0600272865 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE $5, 000.00 2907688985 0602/2600275960 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0612/5600280860 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0622/3600281493 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 225.00 2907688985 0701/8600288640 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0713/9600292630 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0724/4600297964 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0803/4600301710 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0817/6600306691 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0828/1600310582 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0831/3600312195 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0924/7600322139 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5,000.00 2907688985 0924/8600322140 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1001/0600325147 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 845.00 2907688985 1012/5600328482 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1022/1600332818 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1102/7600336630 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE $5, 500.00 2907688985 1112/6600340677 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1203/4600347644 43 COMPANY, COMPANY, 1119/6600343228. Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 95 of 157 PagelD 95 Exhibit 1: Damages Chart Payment Payment Date Payor Payee Amount Claim No. Check No. 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $4, 535.00 2907688985 1221/5600354711 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 2010 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0105/7600361174 ALLSTATE INSURANCE COMPANY $5, 500, 00 2907688985 011410600366565 2010 REHAB ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0126/0600370997 2010 ALLSTATE INSURANCE COMPANY $130.62 2907688985 0126/1600370998 ALLSTATE INSURANCE COMPANY $4, 535.00 2907688985 0209/7600376424 ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0211/3600377611 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 ALLSTATE INSURANCE COMPANY $4, 535.00 2907688985 0304/1600388137 ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 0311/0600391666 2010 REHAB ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0319/5600395082 2010 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0405/4600402394 ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0415/3600407642 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0423/9600411326 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0506/36004 16785 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0513/8600419666 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0524/5600423881 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0601/0600426561 ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0611/7600431179 ALLSTATE INSURANCE COMPANY $4, 845.00 2907688985 0622/1600435562 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0701/4600439903 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0712/5600443786 ALLSTATE INSURANCE COMPANY $4, 690.00 2907688985 0802/4600452387 2010 ALLSTATE INSURANCE COMPANY $4, 690.00 2907688985 0802/5600452388 20101 ALLSTATE INSURANCE COMPANY $5, 345.00 2907688985 0816/8600458437 ALLSTATE INSURANCE COMPANY $5, 000,00 2907688985 0823/2600461563 ALLSTATE INSURANCE COMPANY $5, 035.00 2907688985 0914/5600470155 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0929/9600477559 ALLSTATE INSURANCE COMPANY $35.00 2907688985 0930/3600478185 ALLSTATE INSURANCE COMPANY $5, 000.00 11•11. V el Id V aSRLIUJ(SJUMLI 2010 I'S II' 2010 S. Id 1 I I.' e si• II'S W Ivo r 2010 REHAB s. 1,, 1 2010 2010 I' b. 1 I II' 1 VIP 11• D. 1 I 0" I'S 2010 vs a r 2010 2010 Id 1 I 641, 1 I Id 1 V S' 41•11, 1 I S' Skil. I V 5' V' 4I• 1 I'S W I'S 8 2010 2010 REFIAB Il• VII 41 2010 1 I'S 2010 •'S 5' 2010 REHAB 2010 11' Id S' D• 1 I II' 1 V'S IV 1 VS S' I'S W 2010 2010 REHAB S' Ild 1 I e• 2010 0' flod I I" •'ll IP 2010 REHAB 2010 or jDJI1uI1H SRLlUJkSjuIeRI 2010 1•11• 2010 REHAB I V 0219/7600381767 S 2010 ii 1222/2600355289 II' •'S 5 44 2907688985 1004/4600479332 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Damages Page 96 of 157 PagelD 96 Chart Payment Payment Date Payor Payee VII. 1 I 1 I 1 I 9' I s• I 4I" Amount Claim No. Check No. I 1004/5600479333 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1004/6600479334 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1012/2600482750 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1025/8600488953 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1102/5600492550 ALLSTATE INSURANCE COMPANY $5, 035,00 2907688985 1111/0600497023 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1122/1600501739 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1206/6600507669 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1213/4600510900 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 1222/5600515596 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0109/4600520254 ALLSTATE INSURANCE COMPANY $500, 00 2907688985 0110/8600523119 ALLSTATE INSURANCE COMPANY $5, 000, 00 2907688985 0131/8600532567 ALLSTATE INSURANCE COMPANY $4,690.00 2907688985 0209/9600534733 ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 ALLSTATE INSURANCE COMPANY $5,000.00 2907688985 0218/7600542335 ALLSTATE INSURANCE COMPANY $35.00 2907688985 0319/9600553110 ALLSTATE INSURANCE COMPANY $5,000.00 2907688985 0324/8600559098 ALLSTATE INSURANCE COMPANY $5,000.00 2907688985 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0408/7600566719 ALLSTATE INSURANCE COMPANY $4, 000.00 2907688985 0408/8600566720 ALLSTATE INSURANCE COMPANY $5, 500, 00 2907688985 0408/9600566721 ALLSTATE INSURANCE COMPANY $4, 690.00 2907688985 0421/0600572663 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0503/8600577759 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0519/0600586093 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0520/9600586768 ALLSTATE INSURANCE COMPANY $4, 535.00 2907688985 0602/8600592184 ALLSTATE INSURANCE COMPANY $5, 500.00 2907688985 0610/1600595912 ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0627/5600603423 ALLSTATE INSURANCE COMPANY $35.00 2011 REHAB I-LORIDA INS IIIUIL FUR NEUROLOGIC. ALLSTATE INSURANCE COMPANY $5, 000.00 2907688985 0706/5600607238 2011 REHAB ALLSTATE INSURANCE COMPANY $4, 845.00 2907688985 2010 REHAB .11•11. VII 2010 REHAB 2010 REI1AB ip• iI 2010 I'S 2010 I'S ego,. s 2010 1 I I' I'S 2010 REHAB 2010 I I' I fl• I'll I 2010 REHAB I'll. 1 1 •'5 2010 REliAB .9" IIJ1hII 2011 I. 1 991. 1 IV I 0" 011 2011 11' I'S 0' I" I'S I 2011 REHAB I' I. 1 I 2011 REHAB 411. vs I, 2011 11. I 5' 1 I'S I 0' 1 I'S 2011 REHAB fl• ISJi III 2011 2011 REHAB 1 'I I 1 1 0210/8600538456 I 0 2011 REHAB 0330/8600561339 e•fII7II 1 III tIJISRIii1{IJU1C11I 2011 I. 11, I 11' I'S 9 2011 REHAB ELURIDA INS IIILPIE 1-CIR NEUROLOGIC. 2011 REHAB ELURI0A INS IIIUIE FUR NEUROLMIL. 2011 REHAB IVO 9 2011 11411. I I IVO III 1 I 11•9 1 V 2011 2011 REIIAB P S' I'S 9 2011 REHAB I-LURIDA INS IIIUIL I-UR NEUROLOGK. 2011 REHAB 1-LURILA INS IIIUIE bORNLURULULil(, 2011 REHAB I-LURIDA INS I1IUIE FOR NtuRoLouic. 2011 REHAB FLORIDA INS I 2907688985 0705/4600606726 I CH t I-UR NtURULCKAL 45 0708/6600609108 Case 8:12-cv-01935-JDW-MAP Document 1 Exhibit 1: Filed 08/24/12 Payee. 1-LURIVA 11\lb IllUIL 97 of 157 PagelD 97 Damages Chart Payment. Date Page Payor Payment. Claini No. Amount Check No. I-UR NEUROLUbK. 2011 REHAB ALLSTATE INSURANCE COMPANY $766.50 2907688985 0502/1164788321 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $48.82 2909659216 0918/8600320084 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $2, 700.00 2909659216 0714/2600293177. 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 000.00 2909659216 0716/3600294090 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 000.00 2909659216 0811/7600304533 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 000.00 2909659216 0817/4600306659 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 000.00 2909659216 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 200.00 2909659216 0903/7600314241 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $9, 900.00 2909659216 0918/7600320084 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 800.00 2909659216 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 1001/8600325133 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 1014/6600329975 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 1021/8600332215 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 1027/7600334921 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 1103/4600337058 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 800.00 2909659216 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 1119/1600343145 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 1202/9600347453 2009 FLORIDA INSTITUTE FOR NEUROLOGIC ALLSTATE INSURANCE COMPANY $16, 000.00 2909659216 1215/9600352243 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0104/4600360955 ALLSTATE INSURANCE COMPANY $8, 800.00 2909659216 0118/4600367288 FLORIDA INSI 11 Ul 0903/6600314240 0928/0600323228 1027/6600334920 1111/8600340186 I-UR NEURULIXAC 2010 REHAB FLORIDA INS IllUlt I-UR NEURULOWL, 2010, REHAB 46 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 98 of 157 PagelD 98 Exhibit 1: Damages Chart Payment Payment Date Payer Payee Amount Claim No. Check No. I-LURIDA INS IllUlt I-UR NLUROLLX211, ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0125/1600370906 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0202/0600373611 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0209/6600376726 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0308/1600389145 ALLSTATE INSURANCE COMPANY $6,900.00 2909659216 ALLSTATE INSURANCE COMPANY $8,000.00 2909659216 0319/5600395340 ALLSTATE INSURANCE COMPANY $8,000.00 2909659216 ALLSTATE INSURANCE COMPANY $8, 800.00 2909659216 0422/5600411196 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0426/2600412132 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 050311600415260 ALLSTATE INSURANCE COMPANY $8, 000, 00 2909659216 0518/3600421363 2010 REHAB ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 2010 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0615/6600431900 ALLSTATE INSURANCE COMPANY $8, 800.00 2909659216 0615/7600431901 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0623/8600436156 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0712/1600443153 ALLSTATE INSURANCE COMPANY $8, 000.00 2909659216 0722/1600448965 ALLSTATE INSURANCE COMPANY $8, 000, 00 2909659216 0723/2600449122 201011 ALLSTATE INSURANCE COMPANY $8,000.00 2909659216 2010 ALLSTATE INSURANCE COMPANY $8, 800,00 2909659216 0816/3600458332 ALLSTATE INSURANCE COMPANY $7, 900,00 2909659216 ALLSTATE INSURANCE COMPANY $7, 100.00 2909659216 0916/9184688130 ALLSTATE INSURANCE COMPANY $7,700, 00 2909659216 0917/5600472570 ALLSTATE INSURANCE COMPANY $35, 00 2909659216 0924/6600475826 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 1007/9600980898 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 1012/0600982687 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 1027/4600490222 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 1103/5600493036 ALLSTATE INSURANCE COMPANY $7, 700.00 2909659216 1112/8600497779 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 1122/8600502147 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 2010 REIIAB D• V 11' S' 2010 2010 Do 1 I ONIDo 1 1 11' 111' 111 2010 S' 2010 REHAB 2010 41' Do II' D. I I' I'S r 2010 11' 1 1 I ID1 I•S S 1 1 1 I'll 111 2010 REHAB Do 2010 o• so 1 5" 1 r 2010 I kilo 1 1 I'S O 2010 o•oo• o o• 0413/3600406250 I'S 111 2010 S'ilo 0316/8600393967 0526/8600425192 o's 2010 REHAB FLURILK INSI IlUlt I-OR NEUROLUbli- 2010 REHAB 11' Do 0.' e'er 2010 ID, I I•S I' 2010 REHAB lo 1 I 0" I'S 2010 0•411, I 0' 0' I 11' 1 I'S 0' I'S r 20101 Do 2010 liI o• oL o• r S• I'S 111 2010 I 2010 REHAB 2010 I• 1 I 11" I'S 01 I V' I•S I' I S' l'S r I 11' I'S r o• o.o r S• I'S I' 2010 I I 2010 REHAB 1011, 1 1 20101 s Do 2010 oL 2010 lI o I 2010 REHAB I 47 0803/3600452911 0823/2600461470 0928/5600476715 1216/5600513029 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 99 of 157 PagelD 99 Exhibit 1: Damages Chart Payment Payment Date Payor Payee v. 1 b. il I'll 111 2010 1 5•1 I 1 1•11 W 1 41' I'S I I I" 111 I Ili• 1 I'll V 5 1 111•• W 1 1•5 W US r 2011 REHAB 8•11, 2011 REHAB I' 2011 I• 1 Lii II' 1. V' 11. 2011 1 2011 REHAB 11•111, 1 V V' 1 V 5' 2011 REHAB O. 2011 REHAB 2011 11i VII• 1 I I" •15 V 1 I 0" VII W l'• s 2011 REHAB 041. 2011 Ir4 I, I ii 2011 IL S. I I. I'S I 0' 1'0 2011 REHAB Ski). 1 2011 2011 VI, V II" l'• W V V' 1'0 li I IP .1 i 0. 11 VII 911I. 1 I I' 1 I'S W 111. 1 I 1111 l'• W s. o. 1 o s• 1 vs r a* 5, 1 1 1 1 111 1 1 fb 2011 REHAB 01 VA 1 2011 II, 1 II, 2011lli 2011 2011 2011 I, 1 11. $230.00 ALLSTATE INSURANCE COMPANY $9.21 ALLSTATE INSURANCE COMPANY $33.14 2909659216 0426/8600574931 ALLSTATE INSURANCE COMPANY $7,000.00 2909659216 0107/7600522608 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0110/2600523530 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 ALLSTATE INSURANCE COMPANY $7, 700, 00 2909659216 0127/6600531782 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0204/5600535026 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0204/6600535027 ALLSTATE INSURANCE COMPANY $35.00 2909659216 0204/7600535028 ALLSTATE INSURANCE COMPANY $7, 700, 00 2909659216 0228/6600546456 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0308/3600550156 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 ALLSTATE INSURANCE COMPANY $35.00 2909659216 0321/4600557325 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0324/9600559341 ALLSTATE INSURANCE COMPANY $7, 000, 00 2909659216 ALLSTATE INSURANCE COMPANY $5, 600.00 2909659216 0408/4600567122 ALLSTATE INSURANCE COMPANY $7, 700.00 2909659216 0408/5600567123 ALLSTATE INSURANCE COMPANY $5, 600.00 2909659216 0426/7600574931 ALLSTATE INSURANCE COMPANY $14, 000.00 2909659216 0503/5600577698 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0504/9600576325 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0519/8600586155 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0520/7600586722 ALLSTATE INSURANCE COMPANY $35.00 2909659216 0602/5600592607 ALLSTATE INSURANCE COMPANY $7, 700.00 2909659216 0615/6600598009 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0713/1600610503 ALLSTATE INSURANCE COMPANY $35.00 2909659216 0713/2600610504 ALLSTATE INSURANCE COMPANY $7, 000.00 2909659216 0713/3600610505 ALLSTATE INSURANCE COMPANY $35.00 2909659216 0823/4134597467 ALLSTATE INSURANCE COMPANY $310.25 $7, 600, 321.39 2909659216 1019/3110607662 2909659216 0107/8600522608 0124/5600529147 0321/3600557324 0330/0600561744 UV 2011 5• ALLSTATE INSURANCE COMPANY 1•11 2011 4. Check No. 1111 2011 REHAB IV Claim No. 110 2011 I' Amount 1 V 2011 REHAB 2011 IS' I. iv' o, I V 11, 1 V 1 l'ill V 111 1 VI V V' 1 1115 V I 2011 2011 2011 REHAB 0615/7600598010 FLORIDA INS 111 U I L FOR NFUROLU(11C 2011 REHAB Total 48 2909659216 0502/1144757141 Case Document 1 Filed 08/24/12 Page 100 of 157 PagelD 100 Case,8:127,cv7019.3.5TJQW, MAP. Documenti,. Filed .08/24112. Page 101..of., 157 Page11:1•101-FAL sans Records of New Med ko By PETER k.PLE., Neu 2i.ckr,../.44; 7t2, frg$4 Wolin! 9n; lit %livers 7I5t New York 'Mrn(1651- 2.0071 RBI Seizes Records of New Medico By PETER KERR Agents of the Federal Bureau of Investigation entered the corporate headquarters yesterday of New Medico Health Care Systems of Lynn, Mass., the operator of chain of a national bratn.injury rehabilitation centers, and seized records. The F.B.I. said the move was part of a national investigation of "alleged health care fraud." New Medico, which until recently operated 42 rehabilitation and nursing home facilities in more than 15 states, has been accused by former patients, employees and Congressional investigators of promising nearimpossible cures to emotionally dev. astated families, overcharging patients and discharging them as their insurance ran out. as soon The company has denied such charges and says it provides the high. esb-quallty care. Federal Warrant Served F.B.I. agents entered the company's headquarters at 7:30 A.M. yes. terday, served a Federal warrant and asked to have access to company files, particularly those dealing with patient records, Jack Barrette, a New Medico spokesman, said. Mr. Barrette said he was unaware of the nature of the investigation. "This process does not mean there allegations, Charles A. Stillman, a lawyer who represents New Medico, said. "This means they have decided te gather together dem- are new =Ms. Our cooperative obligation as we is to be as can." A spokesman for the F.B.I.'s i3os. office said that he could disclose nothing more about the investigation of New Medico than to say it involved his agency, the Federal Department of Health and Human Services and criminal investigators of the Defense ton Department, in Congressional testimony earlier this year about New Medico facilities, family members of former patients described rehabilitation programs that admitted and kept patients who could not benefit from treatment and that sometimes Charged as much as $30, 000 a month. A lawsuit by former employees in New 'York charges that the company systematically cheating Medicare and private insurance Com- panies. New Medico now operates 27 cenaround the country, down from 42 a year ago, Mr. Barrett, the COMpany's spokesman, said. Two of the centers are being shut down, he said, and others are being sold. New Medico is a privately held company founded and operated by Charles Brennick, a longtinie operator of nursing homes. ters 14.42Ndr,91 krin:sgon eitIG COMVIS Met. FLTESSF reoxdocrat oroMitd IOWA perrrimion. EXHIBIT 9 tiT Case Document 1 Filed 08/24/12 Page 102 of 157 PagelD 102 Case 8:12-cv-01935-JDW-MAP 'gram Document 1 Filed 08/24/12 Page 103 of 157 PagelD 103 FLORIDA INSTITUTE FOR NEUROLOGIC REHABILITATION5.INC. mipp. The Florida Institute for Neurologic Rehabilitation, Inc. (FINR) is 'dedicated to :t• excellence in the provision .of rehabilitation, education and vocational services to the survivors of brain injury. 1 i MISSION Through the provision of individualized assessment, restorative service and foundational retraining in behavior, psych-social, cognitive, physical functioning, communication, daily living, education and vocational areas, FINR seeks to assist its clients in attaining their maximum level of functioning and quality of life in the most normalized and least restrictive environment. FINR is also dedicated to promoting ptibliC awareness of the needs of brain injured survivors and their families and enriching the knowledge base in the field ofrehabilitation through education and research. order for each client to achieve successful community re-entiy, services must provided that enhance the client's strengths and abilities and overcome rHILOSOPHY existing barriers to independence. This is accomplished by providing training and therapies which focus on functional living skills, by gradually increasing the demands placed on the client, and by providing opportunities to Practice newly acquired skills in the •t- In s• 1 be community. Rehabilitation .services at FINR, are provided bY an integrated treatment team led by a Case -Manager who focuses on the client as a whole 'person. This individnal serves as the primary client advocate and manages transdisciPlinary rehabilitation services designed to ensure positive outtomes for the client served. "Transdisciplinary service" in this situation refers to services provided by several members of a treatment team in• such a way as to transcend the traditional boundaries of their respective disciplines. of the individual and philosophy acknowledges the rights and dignity important member 'of the rehabilitation team. This Goals recognizes that the client is the mOst FINR, through its rehabilitation programs, family and client suppOrt systems, and community involvement, is committed to the following long-term goals: Quality Tratinent: Through individualized client services, transdisciplinary treatment teams and learning 'environments, we hope to maximize the abilities of our clients. Evaluation. Ongoing program evaluation efforts through a data-based, outcome-oriented Program ensure to will be utilized program effectiveness and quality. system and Client Adjustment. By effective discharge planning, fathily education and guidance, and Family client advocacy; FINR attempts to increase adjustment of the client and the family to the residual effeets of he ad inj my., Community Awareness. Through presentations to community organizations, allied health professionals, and legislative bodies, elient/community interactions, public school education and involvement in head injmy support groups, .we seek to increase the community's awareness of the causes and consequences of head injuly _Foster Return to the Community. FINR attempts to develop a system of personal and community resources, in Order to "foster successful client re-entry to the community. Staff Education.. Through a system of formal training professional conference attendance and research, FINR aims to provide the resources necessary for continuing education and professional growth of its staff. functional For additional information or to schedule call 800-697-5390 osogizr, tait. ..00%.'s N, P.O. Box 1348 0 a or Wauchula, FL 33873 pre•screening visit a our www.fintnet CARF in Brain a evaluation at no cost or obligation website at www.finnnet 861-773-2857 0 Injury Joint Commission on Accreditation ofHealthcare Organizations 800-697-5390 i' EXHIBIT Case Document 1 Filed 08/24/12 Page 104 of 157 PagelD 104 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 105 of 157 PagelD 105 igaz!t FLORIDA INSTITUTE FOR NEUROLOGIC REHABILITATION, INC. Intensive Rehabilitation Program FACT SBEET F.T i he Florida Institute for Neurologic Rehabilitation, Inc. (FINR) has, designed its Intensive Rehabilitation Program for individuals who have sustained severe physical, cogMtive, 'and/or speechllanguage impairments due to a brain injury. Aggressive physical, occupational, and speech/language therapy are provided As well as neuropsychology, hehaviartherapy, vocational training, and medical management.. The overall goal, of the Intensive Rehabilitation Program is to provide clients with the aggressive therapy they need to restore functioning to the highest possible level with reduced needs for support; supervision, and assistance to enable rerintegration into the home, work-place, or community with as mudh fimctional independence as possible. Upon admission, the clinical team will conduct an intensive evaluation to identify each client's strengths .and the barriers to independent functioning. Following the evaluation of approximately 30-days, an _individual treatment plan is developed that will include strategies to overcome and/or compensate for identified barriers to community living. and -vocational success. these rehabilitation services are provided daily in a structured learning envirdnment that emphasizes those skills to be learned rather than the client's impairment. Areas Health Education/Medical Personal and Self-care Physical functioning and offocus include: Management Pharmacological Evaluation Social Skills Acquisition mobility. Recreation. and Leisure Skills Vocational Rehabilitation Cognitive Skills Functional Communication Behavioral Adjustment. Skills Psycho-social functioning Behavior Community Integration Neuropsychological Testing Safety Awareness The ultithate goal of the Intensive'Rehabilitation Program is to provide each client with_ the skills necessary to live and work in the least restrictive environment possible, given the clients:current barriers to independence. A Program Case Manager, in conjunction with the Program Director and the Clinical Team, is responsible fOr monthly staffmgs, reports, and- discharge.planning. FOr additional information or to schedule a pre-screening evaluation at no cost or or visit our website at www.finrmet call 800-697-5390. obligation 1 EXHIBIT koviv, P.O. Box 1348 cair Waucliula, FL 33873 0 www.firmilet 9 863-773-2857 9 CARF in Brain Injury Joint Commission onAcereditation of Healthcare Organiaation s 0 800-W/-539-0 Case Document 1 Filed 08/24/12 Page 106 of 157 PagelD 106 Case 8:12-cv-01935-JDW-MAP Document 1 Ai& FLORIDA INSTITUTE Filed 08/24/12 Page FOR NEUROLOGIC 107 of 157 PagelD 107 REHABILITATION, INC. Neurobehavioral Rehabilitation FACT SHEET Changes in 'personality and behavior are often the most tragic and limiting conSequenees of brain injury. Although some issues, such as severe physical and verbal aggression, are quite obvious, others including reduced inhibition, judgement, and initiation can be much less so. Behavioral expression of these difficulties can range from subtle, off-color comments to frankly disinhibited and extreme sexual responding. Unfortunately, behavior patterns of this type often set up a "revolving doer", pattern that starts with inappropriate behavior, legal attention, psychiatric placement, and rapid discharge to begin the pattern again. Our staff secured Neurobehavioral Program .was established with *the specific purpose of providing effective treatment that would stop this "revolving door" cycle, and for those individuals with neurologic impairment whose behavior has made them ineligible for other treatment programs. Neurobehavioral Problems Include: Physical Aggression Verbal Aggression Self-injurious Behavior Poor Judgement and Safety Awareness Inappropriate Social Behavior Noncompliance Egocentricity Depression Substance Abuse Sexual Disinhibition Property Destruction Medication Compliance A Reduced Ability to Initiate Purposeful Behavior The Neurobehavioral Program is based on the idea that positive teaching is a more effective way to change behavior than -punishment and restriction. :Initially, individuais are provided with the level. of staff support and supervision required to minimize the factors in the environment that prompt loss of -cOntrol. SiMultaneously, teaching in the areas of self management and self control strategies .occurs at the level permitted by current cognitive functioning. Strategies range from the fairly simple and concrete to the sophisticated and abstract, with an emphasis on learning positive control. Frequent.and intensive rehearsal apd practice of simple coping skills occurs with annile opportunities for practice of newly acquired skills. maintained -through staff supervision 'rather than locked units, chemical restraint, Or mechanical restraint. Achieving increased self monitOring.and self control is stressed, praised, and.reinforced rather than simply encouraging individuals to comply so as to avoid negative and arbitrary consequences. As progress with regard to behavior, internal control, and motivation occurs, external prompts, aids, and supports are reduced to the point -where available support matches the needs of the individual.. Structure and safety are For additional information or to schedule a pre-screening evaluation at no cost or or visit our website at www.finnnet call 800-697-5390 P.O. Box 1348 Caa •"•ftxtiO 0 Wauchula, FL 33873 Mint Commission www.fintnet 863-773-2857 CART? in Brain Injury Accreditation ofHealthcare on 0 Organizations 800-697-5390 "g obligation EXHIBIT Case Document 1 Filed 08/24/12 Page 108 of 157 PagelD 108 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 109 of 157 PagelD 109 with. FLORIDA INSTITUTE FOR NEUROLOGIC REHABILITATION, INC. Ism Community Integration Program FACT SHEET Amajor difficulty transfening obstacle to successful community integration for individuals with neurologic impairment is in or generalizing skills learned in the typical rehabilitation treatment environment to.that of the "real world." We have found that teaching-, practice, and training is most effective when practiced under. "real world" eonditions and situations. The Coinmunity Integration Program (CIP) at FINR iS a Unique approach to brain injury rehabilitation with provisions for both -growth and ultimate independence as Well as mechanisms for continued support and supervision in the community. This community alternative utilizes "real world" settings to teach and apply the skills needed to live and work successfully.. The overall goal -of the CIP program is to provide active rehabilitation and ongoing support/assistance to persons with brain injuries in their home/apartment, workplace and the community. This program is designed to teach the skills necessary for Community living and to continuously apply these skills in the natural, "real Specific goals often To develop include the following: the skills needed for self-direction, self-management and self-advocacy.. developing individual community and social support systems. To assist each individual in their process of adjusting to life after sustaining a brain injury. TOdevelop the skills needed. to access the labor market or pursue avocational interests. To assist each individual in developingproductive leisure and recreational activities. To assist each individual in To develop and-utilize appropriate To assist each prosocial skillsfor improved.social interaction with Others. individual with personal budget and money management. Typically, individuals involVed in the CIP Program have experienced acute and perhaps post acute rehabilitation other program. After an initial assessment fo determine safety and other Critical issues, individuals in the CIP program progress tO the least. restrictive Jiving eiwironinent, whether in aresidence with minimal supervision or an apartment in town. Support and assistance are tailored to the either at FINk or at some individuaPs need. As indicated; the full array of skilled in this prOgram; For additional information therapy and medical services available at FINR are available to individuals to schedule a pre-screening evaluation at no cost or call 800-697-5390 or visit our website at www.finr.net or EXHIBM 4trivf., P.O. Box 1348 rail V-----'4, obligation Wauchula, FL 33873 wwwfmr.net 0 863-773-2857 CARF in Brain Injury Joint Commission on Accreditation of Healthcare Organizations e 800-697-5390' Case Document 1 Filed 08/24/12 Page 110 of 157 PagelD 110 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page LORIDA INSTITUTE FOR NEUROLOGIC Vocational Rehabilitation 111 of 157 PagelD 111 REHABILITATION, INC. Program FACT SHEET neurologically impaired persons, acquiring or re-entering and .sustaining gainful employment canbe quite difficult. With, in most cases, an already diMinished feeling of self-worth, inability to secure andmaintain .a job can cause demoralization and depression. Consistent work is necessary to facilitate financial stability for sustained independent living. or The Vocational Rehabilitation Program provides individuals with neurologic impairment the.skills and abilities the necessary to evaluate themselves for a. potential positiOn and to sustain that position. PartiCipation in Vocational Rehabilitation Program inchides rehabilitation for fimetional improvement as well as' training for necessary job skills. Specific program conponents include: Vocational Evaluation. Used to assess functional abilities and vocational pursuit possibilities. Pre-Vocational Training. Improvement of functional skills aS well as appropriate and accepted behavioral practices. -Job Placement in Occupational Work Trials. Trial employment on-campus to provide a working assessment. Job Coach Services. Staff is provided to guide and direct the clients while in the work environment. Adaptive Work Behavior Training. On-the-job assessment with-integration from all therapy areas. Job Development/Exploration.- Research on possible employment opportunities related to a client's functional abilities. Job Seeking Skills Training. Training to enable clients to independently fmd and apply for job vacancies. Job Aimlysis: Analysis of_specifie a specific job for appropriateness related to funCtional Working•Community. LegitiMate.employment at FTNR or in the surrounding community. Trauniatic Brain Injury Education. Teaching focuSed on improving 'awareness of the abilities and limitations of brain Our injury on functional abilities. -on-campus employment includes over 80 positions available dependent. on functional ability and job readiness. For additional information or to schedule a pre-screening evaluation at no cost or or visit our website at wwwfinrmet call 800497-5390 EXHIBIT .4,04z.fe7„. P.O. Box 1348 0 Wauchu1a, FL 33873 0 CarrCARF Johit Corninission *MAO obligation oi wwwfmtnet 6 863473-2857 in Brain Injury Ameditation ofIrealthearo Organizations 800-697-5390 iq Case Document 1 Filed 08/24/12 Page 112 of 157 PagelD 112 Case 8:127cv-0.1935-JDW-MAP ...Docurnent.1._ filed 08124112 _Page 1130 157.PagelD 113 Page 1 of 2 Accredited Brain Injury Rehabilitation at MIR ABOUT US CONTACT US CAREERS MAKE A REFERRAL ESPAROL Find Us On Facebook fill& FLORIDA Iit4TITUTE FOP:. millr-NtURCiLOGIC REHABILITATIONi- INC i/ t. 1„: --con_ximagmmaaraus iniumg.watuggsmatt Tam igiteno FINR Accreditations PRINT PAGE About Florida Institute for Neurotonic Rehabilitation (FINRI> FINR Accreditations CARF FINR Brain injury Program is Residential Rehabilitation Programs Adults Three-Year Accreditation Residential Rehabilitation Programs Pediatric Specialty Program Three•Year Accreditation Vocational Services Adults Three-Year Accreditation Joint Commission MR Behavioral Health (Residential Group Homes Adult/Child/Youth) SMRC o C' Long Term Care Traumatic Brain injury State-Designated by the Florida Brain and Spinal Cord Injury Program National Council for Private School Accreditation (NCPSA) (AISF) IpAssociation EXHMore of Independent Schools of Florida About Us http://www.finr.nctiabout-us/accreditations/ 7/17/2012 _Case 8:12-ov.-019857,1pW7MAP Document-1. .Filed 08/24/12 Accredited Brain Injury Rehabilitation at PINR Page- 114 of .157-Pagel D 144.. Page 2 of 2 Qukk Links Make a Referral Request Program Information a Tour See All Our Fadllties Arrange GO BACK HOME 3D Brain Explore Our ..1 t L_ ONE Lir THE SUBTLE ES TIINT VI'S JIVE TOti NLU4'OLOEIC REHABILTIMION J.-T- vac .TAT. CARFLogo #2 PO Box 138 800-697-5390 1962 Varidolah Rd. Wauchula, FL 33879 888-TBI•FINR Contact Us http://www.fintnet/about-us/accreditations/ 7/17/2012 Case Document 1 Filed 08/24/12 Page 115 of 157 PagelD 115 Case8 il 2cV-01935LJ DIA/MAP DOcurrfertt 1', Page '116 .of 157-Page I D-116 Filed Oa/241-12 r f. 0E3/V3/.2002 1.1: 34 F4X 8E3 773 0867 VINR ...10 1103 Minifiaionu.. a V••*:3, f s PLORItiA 1N$TJTUTE kini. NEtROLOGic REliApILITATION, INC.. .1 I: i: 1.---4-,u-L,L, 'Phone Finri-697:1106 Priu.R61.1/1.7041,. 0 I..... Orli osed Treatnient Pla.n 2.., June 28, 2002 1..• a... J I 1 Thb (Theat&neis a iisvesed plan, of catollawa ón the 1'611% of u field interview end review of Unified inedi61 recOlds, It 4bauld nolbe regardedle diagnostic; preo,stio, or repre'eentativelif a' miaow:Me opinionik tip heeled inctividuailes not warved elf:dont aerete4 frpfii. Ea Maitre irottitnto as. oft& nothd dam...., r.. i I. i. 11111111 ga 1year-did (DOB IIIIIt, righi-handed:ntaie who was I.. motor ichio e accident on involved, ii- a.. hate -9, '2002, He felt fronithe hoed of a Car that he was riding, 'aiid hit.. the back of his head•of. the grating. Ille'had run awaifrorbilis hotre eaillei thaf day and liad;Placed himself oi.thelood of-svmeonele•tir, lie reihsed to get-off,hd•the driver accelerated ttieVehiole -abruptly11.1 and then braked was, thrown from the 'car. He was brbught to his home e. evening, bin left again bcfor6 the parents were, a6lo to hrinii him 'te th-. hOspittil, thee, He was retimed .on June •10 atid Ireported..expedeneing seyere Ileadaehes, teiken to., •Children's Hospital of Michigan for an evgiugipn. Hi Was iiotedlo be sleepy but aRiusiblo uponhis inilla,l'eviluation., initial CT scan of his head )vai road as nigative; but he aperienced bouts of emesis„ headache and lethargy. lyipeat CT on j.1111015, xevea.led a small right frental contusion With edemaand i resolving right temporal lobe hemorrhagio contusiim W, ith-adjoining edema. theic was. nurnass•effeet or midline shift. He waS.. placed on ivtanaitol- and, Deoadion preventatively. "Ili reported to- have.a pfemorliici•p4chiatric instork of oitcliv.et disorder. He. underwent an inPatient hosiiitalizaiion at New' Center Cdminunity Mental Health Center, His behavioral iksues.,, have included trunnty, ste•aling and fightiog:1-1e:ivoe adopted into, his current family'at age8, buf, they had b.s.en foster parents for hini sinpe age.5. was Bssen on ifia by the Md evaluation ma records from-Childron's Hospital of.. is ...appropriate for a 30-.4.1 60 day.. course of evaluatiim and. the treatment.at Florida Instittite.for iNieurol, Oilo Ikeha'hilitation During his stay1.1.111 *ill be evaluated,. treated' and followed by the neuropsychiatriat and-nctuviligiit..RefaxaN for coasultatiOns, will be Made as appropriate. Ho will be evaluated 'by the nompsycholopy departrhent. to. deterAlhe hii, shility to participate, in sfandardlied asseksMcnt and:to:monitor cognitive functioning and to .make .1/eatment 'and-discharge recomnienda.lious. The. physical, occupational and. speech and, language departraehts will evaluate hlsspociiie needs and treat hipa hi the appropilato group•amlior' individual sessions. The behavieral• service departinont; will' establish, protOcols to aid in his, returning to• optima hilepondence, The nursing staff. will monitor his ovefall health and provide Michigan, on 'rimi,ndcd n edon as, neoded...: Medicationati These evaluations will ho used•to develop-an individual. comPrehensivo treatment plait This Irian. will guide his :treat:n(14 during hia stay and, will, be re,'evaluated and iipdatad ea needed. The EXHIBIT. i9 Case '8:12.cv-01935-JDW-MAR DoCuirient't Q8/28/2002 11:45 i PA.;{ ke§. 773 p8a7. FINS Filed 08124712 Page'117 of 157 Pagel") 117 IA A 0 4. 4dmtssions,, 1 .1'..-iF:':',.. I, ::v, 1 i ;Ptip 2 Pr.oposed l'reatrocril Plan IMIIII1111., therapists -will coniziumicate with the case manager to' help meet =Ms needs, altd So keep his 1. family EnVare.of his progress.. Health. il was noted bad no to.hav,e no difileultieS with. bowel or bl4dder, Management. Ha•. ttg'TM vyith Chewing or Swallowing. He was 5'3" 'tall•and wOglied I I5'piiiids.; „lite .Dietician will eValuatehis nutritional needs' an&reconnuend an-appropriate diet..He had no difilculdw :With his, vision pr. hearing.- He has' a "diagnosis of attention 'deficit disorder. Ttio -nur*w.staff, and physician, will monifo'r hiS oVerall health. and compliance. Referrals' will bc made 'us Indicated, by the, Medical Direct= Current medications hieluded Dióadron on weikning d'oses, rnedie:ation.... i, 'Peramial -and 8elf.are, Iie waS tible to. .in batidng, woomhig and dressing'. independent taskseHe -would Occasienally forptire thief? or poinpts tb cornplete tasks. The-Occupational Therapy Department will verify his safety and. efficiency, in iCCitnpletiug those; tasks,, notecols will guide' the residential staff in providing the proper' cues or :assistance lo. encourage his independenee. Was noted to fedd himself independently. toilet himself without assistance. He i. was 4 x Physical 'Funitioning and Mobility.1111111was noled to be At* independent in all aspects ?f ambulation.* transfers. He was noid to be lethargic and to fatigue quickly: The' Physieal TheraPy Depattment Will evaluate his overall physicalfunctioning- with speoitiveinphasis on his higher-level balince skills and-safefy, awareness. IfepPropriate, he. will be plaeed in an independent e'jtreise progratn..to inci•ease' his strengtbt starneina and., e endOrthico, Cognitive Skills/Aendpnale1unetion4 demonstrated mild to moderate diffient was noted to bci.' alert and oriented. Ile CS. with short-terrn: and ketit tueineiy. He. demmistrated impairM problem :Solviiig'.and judgment .skills:.- He was noted to diSplay yEitiable. attention,. and had diffietifty Maintaining concentration. -He, apPeared to have diffithilty loaming new 30ormation. through vaiotis rdodalities. I-le iwas repOrtecl‘ to have a'• ..nonspeeific learning 'ditability, and bad' SUffered from tManoy. The-, 'Netuppaytholegy, Department, will, conduct a coMprehensive,eyalnation to d4terrnine hiil specifiO tognitiYo dotioits, arid his current academic functioning, He, was roPocted t6 have-bien a C" student. prior to middle school. Hii will .he placed in. a small -sehool setting and. proVided with academic laSks to Maintain and improve his sdhool perfe)mance. He willbe placed in iddividual- and -.group aetivitibsAlesigued to' introduce hirn• to the' use of compensatory,, Strategies for attention;inemory 4.nd problem 'solving. able to totnplde .meai independently. I-le was 'reported to- independeniinleisure wasnoted to be activities., He yas 'care-and tasks. bonsehold, tasks,..,. He dignpleted clothing preparation able le numage smatl amounts ofInthioywithout assistance'. He Commuoity In tegraiion, engage, in filik taking behaviors with hiS friends,. and- requiredi strootpictl maintain•his.safeiy.:He will be placed in budgeting end yooking.groups to alas 'and 'teach him neW strategies -to. Cherease his independence, He will -he.. gauge his to Participate in. on arid off carifpos, recreational _activities,. and. opportunity afforded:the envifonment tp 1 1 1 i i Case 8:12-cv-01g35-JDW-MAP .0Ccurneeitl. r 00/51/2002, 1130 leAX,.803 77,3. 0307.. Filed 08/24112 .Page 118 cif 1-18' 157PagelD 005 F, INR Actol, ssi• o0s,. .....T.1-•• a i. P, coposed Troatmout Nan Midget Biekeigteif 1 Page 3 of 3 'community outings, designed to lricrea,se big Weialization I,: opriate community skills:, with peers, and to Practice Conimunication.1111111111was reported' to lhavo-funetional.canmuniqatiOn skills;. He' w.fta, .able to follow simple direetiond arid to eitpress -his Wtiiits and coherent. 'The Speeeli. and. „Language. li.athokigy ikkid no4:13: His speeoh was .clear Depart/tient will evAluate his:. hia cognitiva.linguistie" abilities: corm'nnioation 's:kills wiih a- particular emphasis, on Interventiofis will be developdd to hicrease his use of varbai Strategies to prohlern'sofve and reduce his impulsivity„ BebaYiorat AdkistmOlinisy'ehatieCial: 11111 was' 'reported to., have expedeneed hallucinations pridr id. his .accidept. He engaged' in, high-4-1dr behaviors, and Was infured; i while riding on the hood 'of a.ear. He was notefi to use inappropriata lichaviors to gain 'attention. He was-agitated and has destrojed property. Re ;was unable toiesist impulids: I-le: was withdrawn from otliers since the accident. He 4ppear4d to bp moderately afixiou and.. was having difficulty with appröpriate'secial interactions, Ho had not thq.results of his injury and was dice nan-eornpliant ‘Vith authority flgureth The Behavior Departrieni will. conduct 'a, tanbtional analysis. of his taniadaptive 14ehaViors and develoi .a. plan ..to intiOdneeappropriate sUbstitute behaviord, •the 1aopaYelilairist will evaluate his current, .aco4ted mOcations and mccimarekl. clang-Di:to Increase hiS'ittyition and hihaviorgt °orator. *The NeurOpsychologist. will _evaluate big ability,, 16, henat from Counseling, and education. regarding his injury. Family training will be offered in. a group 'modality.en a monthly basis. IndiVidual.tarnily training and education will oCcneon 'arras npetied basis,.. 4 i 0 Discharge Redoinniendationi. The, eurrent discharge, plan- is for with his familronce• his inaladaptiVe hehaviom hive:beep.redue :at thanager will begin_ i evikathig to -return •inamiged. home: The ease this, and other disoharp op1p110 npon his admission.. Discharge phins_will.he 8hareki with his family Members as The evaluations propoed through, ilia itaY'at Um Florida hisiitiite..... i.. I Thank you 'for 'your consideratioT XI the rehabilitation and evaluation provide6 Cot Mr. i. for iiibistitate Miliff: Isleurologie, Rehaliilitatin as. Do not hesitaie to call ifwe'e an,., pmVide any-Additional information reganding this proposed treatment plan. i..... i. 1 a 0/ Pte 69490) 6 eVin'ff. 0' -1. e, Fsy/P. 'ate 'Plinical Nenrepsyehologist., Lied ciSnslo-. Psyehogiat PY508 f.,,, a a t., I. a 1 r I I;., I e, e t., 4 r I i I,. 1 a Case Document 1 Filed 08/24/12 Page 119 of 157 PagelD 119 Case 8:12-cv-01935-JDW-MAP Document 1 Segregated An Filed 08/24/12 Page 120 of 157 PagelD & Secluded: of D.C. Residents at the Florida Institute for Neurologic Rehabilitation Investigation May 19, 2008 University Legal Services, Inc. The Protection and Advocacy Program for the District of Columbia 220 I Street, ME., Suite 130 Washington, D.C. 20002 EXHIBIT 13 /0 120 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 121 of 157 PagelD Page 2 of20 UNIVERSITY LEGAL SERVICES, INC, Since 1996, University Legal Services, Inc. (ULS), a private, non-profit organization, has been the federally mandated protection and advocacy (P&A) program for individuals with disabilities in the District of Columbia. Congress vested the P&As with the and authority responsibility to investigate allegations of abuse and neglect of individuals with disabilities. Accordingly, ULS provides administrative and legal advocacy to protect the civil rights of District residents with disabilities. ULS staff directly serves hundreds of individual clients annually, with thousands more from the results of investigations, institutional reform litigation, outreach and benefiting education and group advocacy efforts. ULS staff addresses client issues relating to, among other things, abuse and neglect, community integration, accessible housing, financial exploitation, access to health care services, discharge planning, special education, and the improper use of seclusion, restraint and medication. For more information about this report Jane Brown Executive Director University Legal Services, Inc. (202) 547-0198 Telephone (202) 547-2657 TTY or to request additional copies, please contact: 121 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 122 of 157 PagelD Page 3 of 20 TABLE OF CONTENTS Executive Summary Introduction Investigation Community Integration Restraint & Seclusion Other Complaints Conclusion and Recommendations 4 5 7 9 11 18 19 122 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 123 of 157 PagelD Page 4 of 20 Executive Summary At least 21 District of Columbia residents with disabilities have been sent, through the Child and Family Services Administration and the Department on Disability Services, to the Florida Institute of Neurologic Rehabilitation (FINR), an institution in rural Florida, in the past five years. Starting in April 2006, University Legal Services (ULS) began receiving serious complaints regarding excessive use of seclusion and other human rights violations at FINR. In response, ULS attempted to conduct an institutionwide investigation of all District of Columbia residents at FINR. FINR refused to provide documents to ULS as required by Federal law. Nevertheless, ULS moved forward. As this report details, District residents at FINR are subjected to violations of District of Columbia human rights policies, including the use of chemical restraint with individuals with developmental disabilities, seclusion for up to seven days at a time, and the informal use of physical restraint without a written doctor's order. Other residents report staff cursing at them and treating them "like garbage." The residents at FINR spend most of their time isolated from the community. The vast majority of residents ULS interviewed desperately wanted to return home. numerous ULS raised all of these concerns directly with FINR and with the Department on Disability Services. There is no evidence that FINR has ceased these practices, or that the District has taken effective steps to ensure that these residents' rights are protected. Instead, the District continues to fund the placement of both children and adults at FINR. 123 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 124 of 157 PagelD Page 5 of 20 I. Introduction University Legal Services, Inc., (ULS), System (P&A) including the Act) and the Act), P&As for the District of Columbia. Developmental Protection and Advocacy conduct generally or and Advocacy Pursuant to several federal statutes, for Individuals with Mental Illness Act monitoring incidents of abuse and appropriate remedies designated Protection Disabilities Assistance and Bill of Rights Act of 2000 and referral to programs and services investigate is the (PAIM1 facilities; provide education, information, addressing the neglect; approaches of (DD needs of individuals in and pursue to ensure the legal, administrative, protection of, facilities; and other and advocacy for, the is residential rights of individuals with disabilities. The Florida Institute for Neurologic Rehabilitation located on 900 adults and 30 acres youth and children under age placements District of Columbia residents who (DDS). were spend recipients all local the federal government. importantly, are funded were at by FINR in of services from the this also funds, and is (FINR means costs not Services 11 residents Of the 21 were Agency (CFSA), in the and the Department on Disability Services or Medicare. reimbursed any approximately $500 that FINR is not 90 2007, approximately 17% of April 2007, Family facility approximately the District of Columbia. FINR is not certified to accept Medicaid District must that 18. As of April of the District of Columbia Child and other 10 residents a in rural Wauchula, central Florida. F1NR houses FINR's residents had their custody (FINR) subject contained in federal regulations for facilities This portion per day means that the of this expense per resident). to the Conditions of receiving Medicaid by More Participation or Medicare 124 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 125 of 157 Page PagelD Page 6 of 20 funds. FINR is accredited Commission on Starting of a by the Joint Commission known as "JCAHO") in April 2006, ULS these complaints, began receiving complaints regarding being provided ULS services at FINR. found, with respect to that the treatment In the process of individual, that repeatedly violated the "District's Restricted Control Procedure/Behavior Policy, Disability a Department on Mental Retardation and with Services (DDS) (formerly FINR Support the District of Columbia Developmental Disabilities Administration (MRDDA)) human that limits the rights policy and Accreditation of Rehabilitation Facilities.] District of Columbia resident investigating (formally use of seclusion, restraint and aversives developmental disabilities. ULS wrote a against individuals detailed letter to FINR on August 18, 2006, explaining their policy violations and requesting that they revise that individual's behavior plan to ensure it complied with DDS policy. F1NR did not significantly revise the behavior plan. During August 2006, and learned that at that time, Furthermore, although ULS F1NR stop was using techniques willing to District's rules. ULS raised all of the above-mentioned DDS was case told managers were not during meetings with that violate D.C. comply with this request, or with DDS, routinely monitoring FINR.2 DDS that DDS policy, there was no requested that evidence that FI-NR that DDS had taken steps to enforce the It also became clear that DDS had investigating serious reportable concerns incidents that took no formal mechanism in place out of state. There place for were no The existence or absence of these accreditations, while certainly informative, should not be considered dispositive evidence that a facility meets federal or District human rights standards. Cf. Wyatt By and Through Rawlins v. Rogers, 985 F. Supp. 1356, 1429 (M.D. Ala. 1997) CJCAHO accreditation and Title XIX certification, in and of themselves, do not demonstrate compliance with the Wyatt standards or, for that matter, constitutionally required treatment."). 2 Since that time, ULS understands that DDS has been to FENR at least two times, and has become involved in monitoring the conditions and treatment of residents. more 125 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 126 of 157 Page PagelD Page 7 of 20 flexible funds in place to provide for travel on short notice for the District's Incident Management Enforcement Unit (IMEU), the own DDS department responsible for investigating reports of human rights violations, and there with Florida's Adult Protective Services investigatory agency that would allow IMEU to contract out complaint happened or or another was no formal delegate its investigatory responsibility. to come to telephone interviews, reports relationship Therefore, if the attention of the District, the District relied from the facility that is the subject of the sometimes face-to-face interviews with residents months after the a on investigation, and alleged incident took place. Because of the number of District residents at rights violations, the lack of District internal corrective action, or ULS launched federal a full FINR, the complaints of human oversight of FINR, investigation and FINR's lack of into the treatment of District residents at FINR. II. Investigation In 15 April 2007, ULS staff visited FINR for two and residents, and observed another including the living report is based on areas, the a 5 nonverbal residents. half days. ULS interviewed ULS toured the facilities, cafeteria, the school, and the vocational building. This those observations and interviews, and the in-depth review of the records of four individuals.3 This report is incomplete and was substantially delayed refused to release the records of the majority of District residents, despite ULS would like to thank the staff and administrators at F1NR for the April 2007 visit. because FINR unlawfully ULS' yearlong hospitality they extended during the 126 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 127 of 157 PagelD Page 8 of 20 attempt to obtain these records. FINR also refused to guardian.4 give ULS contact information for individuals who have a their to release these records and contact information. legal obligation legal ULS sent FINR four separate letters While FINR responded to some of the letters, they never produced legally sufficient reasons 4 The DD Act regarding for provides: A P&A shall "have to all records of--(i) any individual with a developmental client of the system if such indiVidual, or the legal guardian, conservator, or other legal representative of such individual, has authorized the system to have such access; (ii) any individual with a developmental disability, in a situation in which--(1) the individual, by reason of such individual's mental or physical condition, is unable to authorize the system to have such access; (II) the individual does not have a legal guardian, conservator, or other legal representative, or the legal guardian of the individual is the State; and (111) a complaint has been received by the system about the individual with regard to the status or treatment of the individual or, as a result of monitoring or other activities, there is probable cause to believe that such individual has been subject to abuse or neglect; and (iii) any individual with a developmental disability, in a situation in which--(I) the individual has a legal guardian, conservator, or other legal representative; (II) a complaint has been received by the system about the individual with regard to the status or treatment of the individual or, as a result of monitoring or other activities, there is probable cause to believe that such individual has been subject to abuse or neglect; (III) such representative has been contacted by such system, upon receipt of the name and address of such representative; (IV) such system has offered assistance to such representative to resolve the situation; and (V) such representative has failed or refused to act on behalf of the individual." disability who is 42 U.S.C. 1504 access a (a)(2)(1). Similarly, the PAIM1 Act sates: A P&A shall "have access to all records of--(A) any individual who is a client of the system if such individual, or the legal guardian, conservator, or other legal representative of such individual, has authorized the system to have such access; (B) any individual (including an individual who has died or whose whereabouts are unknown)--(i) who by reason of the mental or physical condition of such individual is unable to authorize the system to have such access; (ii) who does not have a legal guardian, conservator, or other legal representative, or for whom the legal guardian is the State; and (iii) with respect to whom a complaint has been received by the system or with respect to whom as a result of monitoring or other activities (either of which result from a complaint or other evidence) there is probable cause to believe that such individual has been subject to abuse or neglect; and (C) any individual with a mental illness, who has a legal guardian, conservator, or other legal representative, with respect to whom a complaint has been received by the system or with respect to whom there is probable cause to believe the health or safety of the individual is in serious and immediate jeopardy, whenever--(i) such representative has been contacted by such system upon receipt of the name and address of such representative; (ii) such system has offered assistance to such representative to resolve the situation; and(iii) such representative has failed or refused to act 42 U.S.C. on behalf of the individual." 10805(a)(4). failing 127 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 128 of 157 PagelD Page 9 of 20 to release the records.5 release records to ULS ULS sent its last letter on January 18, 2008, and reiterated discuss the issue with FINR. No response This report focuses on two areas: was of complaint consistently. For as well as areas with advocating of this report is for individual on continued our and the to willingness to of restricted use It should be noted that there where residents praised the complimented many of the teachers.6 were FINR school-age and neglect, fairly charged the focus of greatest concern, and should not be read areas other residents Because ULS is rights and protecting against abuse two of the obligation received. example, throughout the interviews, voiced satisfaction with the school and FINR's federal community integration controls, including restraint and seclusion. subjects explaining as a complete evaluation of all aspects of FINR. A. Community Integration At the time of the visit, all D.C. adult residents lived in group cabins near independent living, living" 993 the back of the property. one of several, FINR calls these cabins long term, "supported but the cabins bear little resemblance to the definition of "supported that the District of Columbia (describing supported living uses. as a See, for example, D.C. Mun. Regs., tit. 29 homelike environment for one to three residents, Pursuant to the DD Act regulations, "If a system is denied access to facilities and its programs, individuals with developmental disabilities, or records covered by the Act it shall be provided promptly with a written statement of reasons, including, in the case of a denial for alleged lack of authorization, the name and address of the legal guardian, conservator, or other legal representative of an individual with developmental disabilities." 45 C.F.R. 1386.22(i); see also 42 C.F.R. 51,43. In a letter to ULS dated August 22, 2007, FINR wrote that it "believes that if the guardians' names and contact information is to be provided to ULS, they should come directly from DHS/MRDDA, ULS explained to F1NR numerous times that the obligation to release information remains with the facilities, and that the District cannot restrict access to private facilities. 45 C.F.R. 1366.21(0. ("State law must not diminish the required authority of the Protection and Advocacy System."). 6 At the time of ULS' visit, the school had not been accredited, but ULS process of becoming accredited. The current status of this is unknown. was told the school was in the 128 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 129 of 157 Page PagelD Page 10 of 20 with each resident it is to common cabins houses kitchens, no having have or her own eight individuals in room). Instead, in FINR's "supported living, cabin, with a a kept in the cabins. two in one or approximately twenty people. Furthermore, food is rather eat in his while the cabins have full Residents do not prepare their large cafeteria, where they are One of the a room. own given the choice between food, but one of two entrees. FINR's campus is contrast to the take place on geographically Thursday night, based upon behavior. are basis, and on segregated Saturday are a allowed it does not appear that arrangements activities alone social to walk around or on are town, in small groups. activities, which return to. Trips to Wal-Mart trip is taken, usually these Furthermore, destination decisions few, if any, opportunities community rural area, and stands in stark a environments that most District residents will the mall. However, not all residents routine isolated in trips—permission are made by the made for individual eat at to is granted group; outings. restaurants, and/or There do appear many residents to the movies and be on a There participate in a number of enjoy. These include talent shows, sports activities, and dances. If placements are viewed on a spectrum of most community-integrated community-integrated, FINR should be considered one of the least integrated. state, geographically isolated, and provides most District residents. in the activities one a spending time with chosen family least It is out of stark contrast to the urban communities of Furthermore, there is little private associates with to having a home, such space as or opportunity to engage cooking, having company, or and friends. Last, due in part to the rural environment 129 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 130 of 157 PagelD Page 11 of 20 and geographic isolation, and also due to the structure of FINR, there opportunities for individual activities of choice away are very few from FINR's campus. B. Restraint and Seclusion ULS FINR was originally opened using techniques, violate DDS DDS policy. this institution-wide such as policy investigation based chemical restraint and has a long term on reports that seclusion, which category of provider conduct that is closely monitored, called "Restricted Controls."7 Within this category of Restricted Controls, procedures some circumstances. are expressly prohibited, Those that are permitted requirements due to their potential All residents uses two not and restricted controls that absolutely prohibited, must be then some are, subjected to permitted scrutiny in limited and additional for misuse and harm. interviewed, seclusion and/or secured time out are and are some of the records received, reflect that FINR absolutely prohibited: rooms. FINR also uses carefully monitored and chemical restraint and physical restraint that, while used rarely, according to DDS policy. 7 The policy was updated on November 30, 2007, and is now called Policy 6.2, "Restrictive Procedures." However, for the purposes of this report, ULS will continue to use the language that was applicable at the time the procedures at issue took place. Where there is a substantive difference between the and the old policy, that difference will be noted via footnote. new policy 130 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 131 of 157 PagelD Page 12 of 20 1. Chemical Restraint/Use of Psychotropic Medication Restrictive as a Control Of the four records ULS the of chemical use residents are One resident over reviewed, 8 three years. commonly used residents' records showed evidence of restraint, which is expressly prohibited by DDS policy. These in DDS' system, and DDS is was two subjected to at least 10 uses of medication for as a chemical While the restraint). permitted by FINR, their treatment. "anxiety and DDS Developmental Disabilities Administration (formerly use agitation" (MRDDA)). chemical restraint is used. described "needles" and "shots" person said that he saw a requested records for MRDDA explicitly a Policy, section V.G.9 few individuals' records, it is However, three additional residents they had seen being given to children at F1NR. child who had down. Another child drug the District of Columbia Mental Retardation and Because F1NR refused to let ULS review all but not clear how often a of psychotropic medications to this form of chemical restraint is prohibited by IMS overseeing (Seven of these incidents involved the administration of Ativan, control behavior is name for responsible two complained so he One many shots that the child couldn't write his was always sleepy. There is, at a minimum, 17 residents. ULS did not request records for three residents who were a their guardians and who did not authorize ULS to look at their records. However, as noted above, FINR unlawfully refused to release the majority of the records that did not require ULS to contact a guardian own prior to accessing the records because the District acts as the children's legal guardian, and unlawfully identify the guardian for those individuals whose guardians needed to be contacted. refused to 9 The policy was updated and is now contained in DDS Policy 6.5, "Psychotropic Medications." The policy forbids using psychotropic medications "expressly as a restrictive control." In turn, DDS Policy 8.2, "Human Rights Definitions, defines a restrictive control as a procedure that "fils prescribed medication to stabilize, alter, and/or change behavior or mood." Certainly, chemical restraint would fall into the category "restrictive control." In the alternative, even if these medications fell under the category of medication that is "permitted on a time limited, emergency basis, (that is, medications that are prescribed "to prevent immediate deterioration of a person's mental status when a person manifests severe psychiatric symptoms, under Policy 8.2), this would constitute a serious reportable incident. ULS specifically requested any records related to incident reports or investigations conducted by F1NR. No incident reports to DDS were received. of a psychotropic 131 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 132 of 157 PagelD Page 13 of 20 perception among the residents that chemical restraint takes place: that one child at F1NR (FINR denied facility multiple residential would be familiar with the 2. CFSA monitor wrote "reported hearing that an older patient was given anyone has died at this residents have been in a use as a result of a treatment centers PRN.)".1° PRN and died a These teenage (RTCs) prior to of PRNs and chemical restraint. Use of Seclusion and/or Secured Time Out Rooms Of the 4 records reviewed, 3 included evidence of what FINR calls cabin basing" a FINR, and "therapeutic practice that constitutes seclusion according to District policy. Notably, "therapeutic cabin basing" is not addressed However, F1NR Director of Neuropsychology Dr. O'Keefe by FINR's wrote the policies. following description of the "therapeutic cabin basing" at ULS' request: "For major behaviors (behaviors that could harm self or others), such as physical aggression, property damage, inappropriate sexual behavior with contact, provoking others, and entering client-restricted areas, [the patient] is directed to her cabin for 7 days of Therapeutic Cabin Based Programming. [The patient] is eligible to earn 1 day off of the 7 days for each day she remains incident free (i.e., not engaging in physical aggression, property damage, etc., equaling a minimum of 4 days and a maximum of 7 days." Letter from Dr. Kevin O'Keefe to Jennifer Lay, required 10 to August 15, 2006. stay in the cabins for shorter periods of time. Some residents According are to residents ULS is not aware of any resident of F1NR dying as a result of chemical restraint. However, according to Florida jury, a resident did die from a physical restraint. In 2005, a jury awarded the family of Michael Lieux $5, 000, 000 for a death resulting from a restraint in 1998, from what appears to have been an avoidable restraint: "On November 28, 1998, Defendant's staff suspected decedent of stealing some snack cakes; two of the staff went to his room and began a search for the snack cakes by going through decedent's personal belongings. Defendant's staff knew decedent was very meticulous and private about his belongings. A struggle ensued whereupon decedent was again taken to the floor and held in Defendant's own containment method. During the seven to nine minute containment, decedent defecated and urinated, but the staff did not let him up. After seven to nine minutes, the staff noticed that decedent's face had turned blue and he had stopped breathing. Minutes later, decedent's heart stopped. Efforts to save him were unsuccessful... Fla. J. Verdict Rep. 05:10-23 (October 2005). a 132 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 133 of 157 PagelD Page 14 interviewed, "roombasing" (as from 30 minutes to 7 dangerous acts than that medicine, and and practice is often called Residents also report that described by Dr. O'Keefe, such by residents) lasts anywhere "roombasing" is used for less "horseplay, refusal to take as consensual affectionate behavior without sexual contact (such a discrepancy between residents' account. however her residents are we not According daily regimen is to permitted are F1NR's account of what FINR, a completed spoke with, when they are and other devices hugging in the cabin and resident "continues to follow her at an alternate site." "roombased" residents, Id. they are required to listen to the radio or watch T.V. taken away from happens even to sit It appears that if these devices are property." They are not allowed to speak to any other residents, to staff. One resident said They eat alone in people were their rooms, and finish their school work, such as allowed out of their they do not vocational rooms participate in training or schedule, According personal 11 as kissing) between adults. There is and days. this of 20 on to all their beds radios, T.V.s, the residents' but can speak every hour to smoke. any activities after recreational activities. They they may Under both the old and new policies, a procedure that "restricts access to personal property or removes something the person owns or has earned" is a restrictive control. DDS Policy 6.2. Such procedures must be approved by the human rights committee prior to use. There is no documentation that this was done prior to ULS' initiation of the investigation. FINR never concealed its policies. On at least one occasion, a behavior plan that included the use of "roombasing" and restrictions on the use of personal property was sent to DDS. Instead of referring the plan to the human rights committee or informing F1NR about DDS policies limiting the use of restrictive controls, the DDS responded: "I received a copy of this document [the behavior plan with restrictive controls] from Ms. Heather Futch [FINR employee] and F1NR in June of 2005. After carefully reviewing the document, it was signed and approved by myself and MRDDA Division Chief Mr. Dale Williams. Our acceptance and ultimate signature on the document officially state that the MRDDA approves the document, and we fully agree and approve with [sic] the current treatment plan and methods utilized by FINR in the necessary and appropriate rehabilitation of our consumer.. Letter from DDS Case Manager Coordinator Terrance Ford to Heather Futch, FINR Case Manager, August 10, 2006. (Emphasis added). DDS was never able to explain how the document was approved without review by the Human Rights Advisory Committee. However, after this issue was raised to DDS by ULS, DDS sent a letter to FINR expressing disapproval of the very same behavior support plan due, in part, to FINR's "therapeutic Cabin Based Programming." Letter from Chrispin P. O'Conner, Supervisory Case Management Coordinator to Heather Futch, September 21, 2006. 133 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 134 of 157 PagelD Page 15 of20 read write or (which reported that all many residents have she did while she "Roombasing, old and new forbidden." seclusion "the use Policy 6.2; "[p]lacement roombased of seclusion MRDDA policy involuntary IV.12 ability was to do). One adult resident "color." it, constitutes seclusion. Under both the or secured time out rooms" is V.H.5. Policy of an individual in and which results in activities." MRDDA limited FINR describes even as policy, DDS as prevented, DDS was a a room or DDS' old other area "expressly policy defined from which egress is isolation from others and from Under this ongoing definition, "roombasing" is seclusion, because: 1. 2. 3. The individual is required to stay in his or her room, away from others; required to stay away from ongoing activities. He or she does not participate in any part of the program, except for being allowed to quietly complete school work on her own; and Egress is prevented. For example, with one individual, a male staff person was ordered to sit with his back to the resident's doorway and prevent He or she is egress. Even if District policy did not forbid seclusion with this of seclusion is excessive. Seclusion is measure, seven days used to contain someone who is danger to herself or others. a abates, the seclusion should be stopped. mental health facility permitted. According for D.C. For purposes of residents, such long to the D.C. mental health ordered for four hours at a emergency As soon as comparison, assessed stabilization of behavioral status such that the an imminent risk of serious injury the emergency if FINR regulations, seclusion time for adults and must be discontinued to self or others." D.C. Mun. were a never be only be can as soon as consumer no any intervention, term seclusion would an 12 an population, by "there is longer presents Regs., tit. 22A 508.5. DDS issued a new policy regarding "Human Rights definitions" on November 30, 2007. See Policy No, 8.2. Although seclusion is not defined under the new policy, the "use of seclusion or secured time-out rooms" is "expressly prohibited." Policy 6.2. 134 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 135 of 157 PagelD Page 16 of 20 federal Similarly, convenience in C.F.R. regulations prohibit psychiatric 482.13; 42 U.S.C. the use of seclusion for coercion, facilities that receive Medicaid 483.356. ULS is not aware supports the conclusion that long-term seclusion is any an of any research appropriate or 42 funding. evidence that form of treatment for The Use of Physical Restraint According to FINR, FINR uses the Professional Crisis Management system of restraint.° The specific PCM procedure used Brief Assisted Required "containment" being "taken takes or place on blue mats. Relaxation ("BARR"). to the mat." It The blue mats are visible requested "All documentation related to each 'level procedure, documentation of the use as use described in FINR of restraint in an Residents as one place. to ULS refer to BARR as that restraint at FINR walks around the campus. In requesting records, of an emergency policy ("PCM") to restrain residents is called reported was It is unclear how often restraint takes a Medicare or population. 3. of or discipline, 6.2.4.2." or ULS programmatic This use policy requires incident report, which must include the "name of the individual, the date and the name of the person(s) who the implemented procedure, the time the procedure was initiated and the total duration of the procedure, a check for adverse terminated, health/physical effects (completed by the person or persons implementing the procedure), the location where the procedure was used, the behavior which initiated use of the procedure, attempts to implement less restrictive procedures, the type of procedure used, and a nursing check for adverse health/physical effects. Immediate notification of the medical director for approval and documentation of that order in the medical chart is also required. All incidents of manual restrain {sic} must be reviewed the next morning meeting by the interdisciplinary team and documentation of that 13 is policy regarding PCM is unnumbered, but it is titled "Professional Crisis Management ("PCM"), signed by Joseph Brennick, President and Owner of MR, and dated 7/3/06. FINR's 135 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 136 of 157 PagelD Page 17 of 20 review with recommendations and actions taken noted on the incident report." FINR policy 6.2.4.2 (7/3/06). The records review showed that this withheld these records (despite resident whose records ULS two year time period. recommendations, or the VI. P. In requires that the reviewed, there appeared details of the restraint "physical for Professional Crisis were not requirements psychological as those at FINR. as CFSA Management [restraint] being monitoring The father's business after concerns were Examiner, stating: used CFSA site manual restraint, in not DDS specified using these on them and other peers.. [and] Resident reported seeing a staff are not in "Since 1992, when of Children and year."I4 Despite immediate expressed by [F1NR], Florida regulatory agencies complaints. The Florida Department 14 a monitoring report, "Residents reported inappropriate CFSA stated that the children at F1NR published in one VLK. member slam another CFSA client to the floor sometime last increased their for See MRDDA risk to the individual from the Resident report staff provoking them and peers;... findings, example, documented. clearly outweighed by the risk involved procedures." MRDDA Policy a For FINR or instances of "BARR" in planned restricted controls, such and/or restricted control procedures is to to be 18 implemented However, for this individual, the interdisciplinary review, addition, According either is not specific request for them). DDS has similar documentation Policy policy danger. ULS and an these CFSA has article Joseph Brennick resurrected was his and courts have been flooded with Family has monitoring visit report, Date of site visit September 28-29, 2007. received more than 400 136 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 137 of 157 PagelD Page 18 of 20 complaints and has investigated and 'verified' more than 100 of them, department spokesman Al Zimmerman said."I5 C. Other Complaints Many residents complained that of staff "cussing." One resident said staff yelled at allegations "treated him like garbage." clients—that staff showed staff treated them with us a scar Another said that sometimes he and residents take it horseplay, above his eye, and said he got it from staff in he needed stitches for it. The complaints complaints residents made residents made to CFSA, profanity toward them including [and ()]ie resident reported There were him, threatened him, and sees seriously disrespect. fights between staff and and fight back. A child fight with them, and that to ULS are consistent with the a that "Residents staff calling her reported staff using derogatory names (i.e. bald-headed)."16 These could not be verified. complaints perceive staff as treating them poorly of the school-age children complaints about staff, reason for staff to praised is However, the fact that many residents troubling. (It should be noted that, in contrast, all the school staff and teachers almost if true, would constitute verbal abuse. There is use profanity towards a consumer or to treat uniformly). never a The legitimate a consumer in a derogatory manner. There is at least consumers respectfully. consumer's 15 16 file, there one When ULS was Bill Myers, D.C. Students Sent Supra, n. 14, written record that suggests staff do not an to began investigating F1NR, order Schools stating, we always noticed that in "Client to be taken to Hardee Facing Abuse Claims, Examiner, Sept, 20, 2007. treat one County 137 Document 1 Case 8:12-cv-01935-JDW-MAP Filed 08/24/12 Page 138 of 157 PagelD Page 19 of 20 Livestock Market monthly once Villabla/K, Slater LPN." weight, the scales that accurate weight and At first, F1NR they had FINR obtained accommodate this consumer's this weighed humiliating treats us like and needed as obtain accurate to explained that because weight. a on campus. scale from weight, a the fact that every month for a degrading procedure period adds Although medical ULS was supply Therefore, able to intervene taken to of months without anyone to an company that could a consumer was legitimacy V.O. Dr. of this individual's did not accommodate the individual. could not be obtained subsequently market to get & livestock a objecting complaints such to "staff as garbage." III. Conclusion and Recommendations FINR prohibited by openly and repeatedly has DDS. These techniques used behavior modification include the of use techniques and other human rights violations. Furthermore, as the above examples in residents' FINR staff have fostered views, an environment where behaviors is paramount, sometimes at the cost of individual ULS is sensitive to the finding a difficulty as suggesting that placed at so. desperately controlling rights and dignity. FINR, and in the District forces anyone to her will. However, it should also be noted that the vast interviewed wanted convey, that many of the District residents have had residential placement before being report be construed are long-term seclusion, chemical restraint, some that to return home and DDS does appear to be in the process of helping majority were some no way should this move against his or of F1NR residents ULS requesting assistance of these individuals in doing move. 138 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 139 of 157 Page Nevertheless, complies funded a with District moratorium should be policy. If District residents by District taxpayer money, the District has with District policies and, for that matter, of seclusion and restraint. It is not acceptable option to those as an placed information that the a on new are placements 20 of 20 until FINR to receive treatment at right PagelD to demand that FINR FINR, comply generally accepted practices regarding the acceptable entering use for the District to continue to offer F1NR the DDS system when there is public placement does not comply with basic District human rights policies. 139 Case Document 1 Filed 08/24/12 Page 140 of 157 PagelD 140 "Ca" :12-cV=1:11935;-.1DWATAP Docurrib-riti Ffled 08/24/12 Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Page Bloomberg 141 of 157 PagelD 141.• Page 1 of 11 Bloomberg Brain-Injured Abuse at For-Profit Center Scandalizes U.S. By David Armstrong Jul 24, 2012 Soon after Peter Price arrived at the Florida Institute for Neurologic Rehabilitation to recover from a brain injury, he pleaded for a rescue. "Jess, they beat me up, Price told his sister, Jessica Alopaeus, in May 2009. "You have to get me out of here." Staffers at his new home held him down and punched him in the face and groin, Price said. When Alopaeus's efforts to transfer him stalled, Price said his desperation led him to a step aimed at speeding his release. picked up during a patient outing at WalMart. After emergency surgery to remove the objects, he was allowed to transfer to another facility. He swallowed five fish hooks and 22 AA batteries he'd Residents at the Florida Institute have often been abused, neglected and confined, according to 20 current and former patients and. their family members, criminal charges, civil complaints and advocates for the disabled. These sources and over 2, 000 pages of court and medical records, police reports, state investigations and autopsies contain an untold history of violence and death at the secluded institute known as FINIt, which is located amid cattle ranches and citrus groves in Hardee County, 50 miles southeast of Tampa. Patients' families or state agencies have alleged abuse or care lapses in at least five residents' deaths since 1998, two of them in the last i8 months. Three former employees face criminal charges of abusing FINR patients one ofwhom was allegedly hit repeatedly for two hours in a TV room EXHIBIT last September. _14 Sparse Care complaints underscore the problems that 5.3 million brain-injured Americans are ha finding adequate care. Their numbers are growing, according to the U.S. Centers for Disease The http://www.bloomberg.com/news/print/2012-07-24/brain-iniured-abuse-at-for-profit-center... 7/24/2012 -tee& 8:12-cv411935..1DWMAP" Dddiittent '1 'filed 08/24/12—Page 142 of 157 Pagel D 142 Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg Control and Prevention, as Page 2 of 11 better emergency medicine and vehicle safety mean that fewer die from traffic accidents, bullet wounds and other causes of traumatic brain injuries. The long-term ills range from memory loss and physical handicaps to the inability to control violent anger or sexual aggression. Yet because insurance benefits for rehabilitation are scarce, less than half of those who need it receive it, according to the Brain of America. Organized as a company and operated for profit since 1992, FINR has become one of the largest brain-injury centers in the country, with 196 beds. Three rival providers say they know of no place bigger. Multi-site operator NeuroRestorative, owned by a holding of buyout firm Vestar Capital Partners, handles more patients. FINR hasn't grown hy opening its doors to anyone who needs Rather, its marketing is focused on the relative few who can rehabilitation, customers say. pay bills that reach $1, 850 a day. Michigan Mandate That includes those injured on jobs with generous worker's compensation benefits, and car-crash victims in Michigan --which mandates unlimited lifetime benefits for automobile injury coverage. Those who have clashed with the company over the treatment of patients say its efforts to keep costs down and extend the duration of stays take priority over care and rehabilitation. "All people are to them is a monetary gain, said Jana Thorpe, professional guardian who removed one of her wards from the company's care in 2008. 'They don't care if they do anything a for them." Steven Siporin, another guardian, says he has placed patients at FINR when no one else would take them, and doesn't expect to send more. "Is this the best society can do? No, he says of FINR. "Is this the best under current options? Yes." Difficult Clients Florida's Department of Children and Families has received 477 allegations of abuse or neglect at FINR since 2005, including 36 that were "verified" by its investigations, according to records released by the agency. The 36 verified claims and others were referred to law enforcement according to Erin Gillespie, a spokeswoman for the agency, who said she didn't know what became of the referrals. http://www.bloomberg.com/news/print/2012-07-24/brain-injured-abuse-at-for-profit-center... 7/24/2012 Page 143 of 157-PagelD 143 Case 8:12v-01935-JDIAPMAP- Documeral- •Fileci'08/24/12 Page 3 of 11 Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg FINR executives declined to comment for this story and turned down Wauchula, Florida, facility. a request to visit its Owner Joseph'Brennick said he "preferred to stay out of the news" before ending a short phone conversation and directing questions to a lawyer, who said he would not answer them. On its website, the company calls itself a leader in brain- injury rehabilitation. In past statements it has said it vends "extremely high quality care to very difficult clients" aimed at returning them to their homes, doesn't use seclusion and has "zero tolerance" for resident abuse. Elbow Shots Hardee County prosecutors have charged two FINR staffers with abusing Danny Silva, a 21-yearold autistic patient. Video of the alleged crime shows two large men flanking a smaller figure on a sofa as they punch, elbow and slap him at least 30 times. The blows often come after moans from the man in the middle, which appear to be maldng it hard for his assailants to hear the TV. "Shut up, man, they say in the video, tapedby a FINR staffer, according to police. "You are getting on my danm nerves, one of the hitters tells the smaller man between two elbow shots. A woman in nurse's clothes shows up in the video to give the alleged victim his medicine. Defendants LaKevin Johnson, 30, and Landrev Jolmson, 39, of Fort Meade, Florida, have pleaded not guilty to the charges. Their lawyer didn't return calls seeking comment. Employee McKinley Scott pulled autistic patient Gabriel Allen up from his seat and threw him to the ground last December in a second case, prosecutors say. A video in the case shows a man identified as Scott pushing Allen away from him on a couch, standing him up, kicking his legs out from under him and leaving him curled up on the floor next to a blinking Christmas tree. Scott, 48, has pleaded not guilty to an abuse charge. His lawyer didn't return calls. 'Positional Asphyxia' Lieux, a brain-injured ex- Marine from Louisiana, snffocated when four FINR employees pinned him face down until he couldn't breathe, according to a negligence In an earlier incident, Michael lawsuit that won his family a $5 million jury verdict in 2005. asphyxia, according to the medical examiner for Hardee County. The company denied it was negligent and lost its appeal in the case. It was homicide by "positional http://www.bloomberg.comlnews/print/2012-07-24/brain-injured-abuse-at-for-profit-center... 7/2412012 Cas-e 8:12-0iL01935--MW-MAP -DOCurriOht'l *-Filed-08/24/12'" -Page 144 of-157-Pagel la 144* Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg Page 4 of 1 I Two resident deaths at MIR that same year led to confidential settlements of lawsuits alleging negligence and care lapses that the company denied. In 2009) a FINR staffer pleaded guilty to battery charges after punching out a resident who had scratched him during a restraint. Fiery Fist Reginald Hicks was taken to the cafeteria by a FINR employee and given solid food that lodged in his lungs and killed him last December, according to his daughter, Heather Hicks. Her father, a former mortgage-workout specialist injured in a car accident, had a care plan that called for tube feeding because he couldn't swallow, she said. Autopsy findings cited aspiration of food and pneumonia as causes of death. More recently, FINR's marketing appears aimed at acquiring tough behavioral cases, including aggressive patients. Its website features an ad dominated by a clenched, fiery-colored fist "One of the Subtle Signs That It's Time for Neurological Rehabilitation, according to the headline. company's goo-acre spread in Wauchula passes fields of grazing cattle and trees draped in Spanish Moss. It houses 152 beds, with 44 more in nearby apartments and group homes. The "secluded, pastoral" locale keeps residents from trying to run away, the company has said. Other deterrents, current and former patients say, are the alligators and snakes roaming the The road to the property. Family History The facility was once part of New Medico Inc., a chain founded by Charles Brennick, the father of Congressional investigation highlighted allegations that New Medico staff abused patients and prolonged stays to boost revenues. FINR owner Joseph Brennick. A1992 Joseph Brenniek, then a senior New Medico employee, promised to block discharges to keep clients, the fmal Congressional report said. If one wanted to leave, staffers should "all jump all over him as a team until he stays, the report quoted a Breimick memo as saying. Around this time, of the facilities were transferred to the elder Brennick's sons, according to corporate and real estate records. Joseph, who wound up with Wauchula, has prospered as its owner, some according to former staffers. In 1995, he bought South Watch, gated estate on 62 acres near Sarasota that has a 9, 000-squarefoot home and is valued at $1.7 million for tax purposes. Brenniek bought 311 acres nearby for $6.4 Million in 2007. He owns four cars, one a 2004 Maybach 62 luxury sedan valued at $300, 000. a FINR's main campus is valued for taxes at $11.2 million. http://www.bloomberg.com/news/print/2012-07-24/brain-injured-abuse-at-for-profit-center... 7/24/2012 Case 8:12-bv-01935-JDW;MAP Document 1 Filed 08/24/12---Page 145 of 157 Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg PagelD 145. Page 5 of 11 'Taken Down' Ex-residents of FINK said they were frequently "taken down" or knocked to the floor and restrained by staff, in a routine often accompanied by beatings. They say the take-downs were described by the company as a form of restraint called BARR Relaxation. Blue mats sometimes used for the purpose are for Brief Assisted Required ubiquitous at FINR, according to patients and visitors. "I was taken down at least once a week, said Janet Clark, who stayed at FINK from 2006 to 2007 after she was injured in a car crash. Clark keeps a photo from her Wauchula days in which she is expressionless and sports a black eye that she said came from staffers. "One time they had me down and one of the staff kicked me in the eye with a boot, said Clark, a former prison guard who now lives on her own in Hillsborough, North Carolina. 'They were saying shut up, screaming at me. I was hurting so much I couldn't stop. It was terrifying." $310, 000 Bill Clark, 55, had behavioral issues while she was recovering, including times when she needed to be restrained, she said, but not with the force or frequency that FINR used. She received no psychological therapy there for her aggression problem although she was paying the company $310, 0oo a year from a personal injury settlement, she said. "Immediate and consistent psychological counseling and psychiatric treatment" were "clearly indicated" for Clark, according to an outside evaluation she obtained from Sally Katz Russell, a Miami psychologist, nine months into her FINR stay. The company relies on a network of guardians, case workers, doctors and lawyers to find patients. It has exhibited at the annual National Workers' Compensation and Disability Conference and the National Guardianship Association conference. FINR also cosponsors events for the brain-injured in Michigan, home of the lifetime benefit. There were records one 20 auto-injury Michiganders at the facility at one point last year, according to court for every 10 beds at the facility. Country Club Placements at FINR are often made by guardians in Michigan and elsewhere who control the finances and treatment of patients who have been ruled incompetent by courts. http://www.bloomberg, com/news/print/2012-07-24/brain-injured-abuse-at-for-profit-center... 7/24/2012 Case- 8:12-cv-01935-JDWAAAP. Dottiment t Filed .08/24/12.- Page-.146 of--1-57 PagelD Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg "It's human trafficking, said Kenneth Aulph, a 146- Page 6 of 11 former lumberjack who was hit by a car while walking across a highway 12 years ago. Aulph said he received little psychological therapy, was assigned useless tasks, and saw patient beatings after he was sent to FINR by Siporin, his court-appointed Michigan guardian, whose practice handles about 120 wards. "I wanted to stay in Michigan where my friends and family are, A Siporin aide showed him a Aulph said, company brochure that "made you think you were going to a country swimming pool and library on the Wauchula grounds, Aulph said. club, highlighting the lakes, Siporin praised FINR's brain-injury program and added a threat, according to Aulph: If he didn't go to Florida, Siporin would get a court order to put him in a mental institution. Sandpaper Alphabet Siporin promised in June 2009 that Aulph would be back in Michigan by Christmas, according to Cathy Kemper, his sister. Instead he stayed two years. Siporin denied threatening Aulph and said he made no promise about length of stay. Aulph went willingly to Wauchula, Siporin said. After breakfast at FINR, Aulph said would spend three hours weeding in the greenhouse, followed by lunch, then a routine in which he sanded down wooden letters of the alphabet that staff tossed into the trash afterward. Aulph said he was capable of more including the intricately carved birdhouses on display in his Michigan apartment. Patients were mostly restricted to the areas near their cabins in the evenings and recreation was rare weekends, and the swimming pool pictured in the brochure was filled with cement, Auiph said. Patients say they were rarely allowed near the lakes. Kemper said she pressed Siporin almost as soon as her brother arrived in Florida to get him out and wanted to know why he wasn't getting something better for the $900 a day his insurer was paying. D.C. Pullout "Ken was a cash cow, she said. Calls to Siporin's office often went unreturned, and when she did make contact, he assured her that Aulph was doing well, she said. lie stopped resisting a move only after she demanded to know the name of the judge in Aulph's case, Kemper said. Her brother is now in a rehabilitation center in Ann Arbor. http://www.bloomberg.com/news/print/2012-07-24/brain-injured-abuse-at-for-profit-center... 7/24/2012 Case"81 2-oM)1935-JDW-MAP Document 1-- Filed 08/24/12 Page 147-of 157 PageID-1-47- Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg Page 7 of 11 Siporin said he worked to return Aulph to Michigan, and was unaware of any Kemper query about the judge. FINR's bills have also been paid by state govermnents and the District of Columbia. They've sent patients to Wauchula as wards or when they qualify for state assistance. Over the last four years, D.C. has recalled patients from the facility. The pullout followed a 2008 investigation by the district's designated disabilities advocate that found FINR violated patients' human rights and D.C. policies by improperly secluding them in their rooms or using drugs as a 21 form of restraint. Fatality Review allegations in a letter to the D.C. attorney general. weren't restricted to their rooms, only to their cabins. The company denied those It said patients In September 2010, the state of Connecticut placed Melinda Jakobowski, 24, in the company's care. Not brain injured, she had been abused as a child and was one of seven mentally ill or disabled patients the state had placed at Wauchula. By February, Jakobowski was dead. Three resulting state- level inquiries in Florida and Connecticut raised questions about the quality of her care, injuries she received at FINR before her death, Florida's oversight of the company and the accuracy of her autopsy. during her five-month stay compared to just five restraints in the prior five months in a hospital in her home state, according to a report last month by the Connecticut Fatality Review Board for Persons with Disabilities. FINR used BARR on Jakobowski 29 times Busted Lip Jakobowsld complained that staffers were hitting her and calling her names, the board said, She had a "busted lip" and "what appeared to be bruising under her left eye" about a month before she died, according to a sheriff's office report on a mistreatment allegation it had received. The officers concluded she had not been abused. Although she had. a history of self-harm, Jakobowski wasn't showing suicidal tendencies at the end of her stay in Connecticut, the fatality board said. She tried at least six times to harm herself between September and January at FINR, including attempts to hang herself with a.phone cord and to wrap a t-shirt and a bedsheet around her neck. http://www.bloomberg.corninews/print/2012-07-24/brain-injured-abuse-at-for-profit-center... 7/24/2012 'Case 8:17-tv-01935-JDWAAAP -Document-1— -Filed 08124112 Page Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg Not 148 of 157 PagelD•1•48 Page 8 of 11 Breathing The company's plan of care for her required two staff members to be watching her and within arm's length at all times, according to an investigation by Florida's Agency for Health Care Administration, or AHCA. On Feb. 10, 2011, arriving morning shift employees found Jakobowski in her bed just after 8 a.m., not breathing, with her hair wrapped around her neck. She was rushed to a Wauchula hospital, where she died. One of the employees tasked with watching her was asleep on a couch, according to the Florida investigations. The other was awake, but not observing Jakobowsld for at least 15 minutes, the Florida Department of Children and Families determined. Both staffers were fired, the agency said. A month before she died, Jakobowski told her caregivers it would be easy for her to quickly kill herself because overnight staffers slept, according to an internal FINR document cited by Connecticut investigators. "It will only take like 3 minutes and by the time they even know it, I'll be dead and happy, the report quoted her as saying. 'Obvious Flaws' The medical examiner in Tampa, where her body was taken, ruled her death "Sudden Ventricular Arrhythmia due to Schizophrenia." The sheriffs office closed its investigation based on that finding, saying Jakobowski died of natural causes. The Connecticut report said there is no record of a schizophrenia diagnosis for Jakobowski. FINR records indicate she had bipolar disorder. "There are obvious flaws in the investigations conducted by Florida agencies and there appear to be weaknesses in the system of oversight and monitoring of the FINR facility and its program, the report said. Mari Mainland, the medical examiner who conducted the autopsy, said she doesn't remember how she determined Jakobowski was schizophrenic. "It doesn't really change the essence of the diagnosis" because sudden cardiac death has been seen in other mental illnesses, she said. Florida's AHCA found no violations of its regulations and referred the ease to the state Department of Health for further review. The health department was unaware of the referral for more than a year until Bloomberg News recently asked about it. http://www.bloomberg.cominews/print/2012-07-24/brain-injured-abuse-at-for-profit-center... 7/24/2012 Case 8:12-01935-JDW-MAP —Document 1 ...Filed 08/24/12.- Page 149 of Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg 157 PagelD 149-- Page 9 of 11 Wrong License "We are working with AHCA to resolve this issue, said Victor Johnson, director of the unit that includes DeLilla's program. FINWs license doesn't allow it to treat mentally ill patients like Jakobowski who are not brain injured, said Thom DeLilla, chief of the department's Brain and Spinal Cord Injmy Program. Allegations that FINR limits residentscontact with the outside world have surfaced in court cases in which they sought to oust Siporin as their guardian so they could leave the facility. In three such cases since 2010, patients were allegedly blocked from traveling to Michigan for hearings after the company or Siporin told the court they couldn't be safely transported, or that it would require too many staff members. When patient Gabriealle Weakley's lawyer called her at the facility days before the case, FINR imposed a one-minute limit on their conversation, hearing in her according to notes from company employees that are part of the court record. Blocked Email The notes hidicate that privacy and liberties were limited in other ways. A supervisor confiscated printouts of emails Wealdey received from outside because Siporin didn't allow communication with the man who sent them, the FINR notes say. The man was a boyfriend who brought Weakley items she wasn't allowed, such as cameras and cellphones, according to Siporin, who prevailed in court. The notes include detailed quotes from patient conversations with relatives, and discuss residents who were prohibited by the company from making and receiving phone calls. Several patients say they were blocked from sending mail from the FINR, and that emails were barred or limited. "You have more freedom in prison and at least there you know when you are getting out, says Elmer Cerano, executive director of Michigan Protection and Advocacy Service Inc., that state's advocate for the disabled. Michigan Protection represented Lori Jelanson, a patient who wanted to remove Siporin as her guardian and leave Wauchula. She lost in court, where Siporin cited his years of experience with the brain-injured and said FINR was the best place for her. http://www.bloomberg.com/news/print12012-07-24/brain-injured-abuse-at-for-profit-center... 7/24/2012 •tase 8:12-CV-01935.JDW-MAP. 'Document 1 Filed 0812411• 'Page 150 of Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg 157-PagelD. 150 Page 10 of 11 Body Sheet Price, 24 years old and brain-injured since a bicycle accident at the age of eight, said he wanted to leave FINR after he was punched in the face and groin there in May 2009. Alopaeus, his sister and legal guardian, supported the move. Siporin, who was co-guardian, opposed it FINR's treatment of Price was "inhumane, said Alopaeus. Price had a 'busted lip" and bruises that could have come from BARR restraints, according to a sheriffs deputy report dated May 8 of that year. Price had been trying to fight with staffers when they stopped him from leaving his cabin four days earlier, the report said. FINR recorded his injuries in a "Body Sheet" diagram Alopaeus said the company gave her, Under "location of bruises, scrapes, scars, rashes etc., the diagram notes blue discoloration around his left eye, one testicle larger than the other, and other discoloration on his arms and chest, The sheriffs office concluded there was no evidence of abuse, and said Price changed his story several times about which staffers were involved in the incident. Belly Cut Price was taken down more than 20 times and confined to his cabin at FINR for weeks at a time, he said in an interview. Residents kept in as part of "Therapeutic Cabin Based Programming, used to protect them from hurting themselves or others, the company has said, are Price had kind words for staff members who brought playing cards and music to his room. Others were malevolent, including one who allegedly placed a clipboard over his chest, punched him repeatedly, and told him the method would not leave bruises, Price said. After one period of seclusion, he said he was allowed to go to Wal-Mart, where he bought the batteries and fish hooks that he later swallowed. Price also cut his belly and stuffed two of the batteries and eight hooks into the wound. "I planned this" as a way to get out of FINR, Price said. "My plan wasn't to die." It was a month before he recovered from the surgery to remove the objects. He never returned to F1NR, and Siporin agreed to give up his guardianship. Price now lives in an apartment run by a different center in Florida, where he is monitored, but able to leave his apartment most days. He said he goes on fishing trips, eats out, sees movies, and has never been taken down at his new home. http://www.bloomberg.com/news/print/2012-07-24/brain-injured-abuse-at-for-profit-center... 7/24/2012 Case 8:12:Cv:01935-JDI/V.-MAP 'Document 1 Filed 08/24/12- .i3ge 15.1 of 157 Brain-Injured Abuse at For-Profit Center Scandalizes U.S. Bloomberg To contact the PagelD .151 Page 11 of 11 reporter responsible for this story: David Armstrong in Boston at darmstrongt6ab1oomberg.net To contact the editor responsible for this story: Gary Putka at gputkaPbloomberg.net 2O12 BLOOMBERG L.P. ALL RIGHTS RESERVED. http://www.bloomberg.com/news/print/2012-07-24/brain-injured-abuse-at-for-profit-center... 7/24/2012 Case Document 1 Filed 08/24/12 Page 152 of 157 PagelD 152 Case.8:12-oA1935-JDW-MAP Documentl. Filed 08/24/12...Page 153 of'157-PagelD153 ITEMIZED STATEMENT FOR THE SERVICE PERIOD OF 08/2112008 0813112006 Client Name:1111111.11111111111111111 ITEMIZATION of SERVICES RENDERED Date of Service Therapy Name 08121/06 Total Rate per Units/Days Unit Amount Due I 1 Room & Board HES Medical Management Vocational Services Case Management Services 20 3 $40.60 $40.50 $32.50 Room & Board HES Medical Management Vocational Services 1 2 20 $376.00 $40.50 $40.50 $375, 00 $81.00 Room & Board HES Medical Management 1 $375.00 2 $40.50 20 $40.60 $375.00 $81.00 $810, 00 1 2 $375, 00, $375.00 $81.00 $810.00 1 2 $376,00 $376.00 $81.00 $810, 00 $97.60. 08/22/06 :.1 1 i i I i $810.00 08/23106 Vocational Services 08/24/06 Room & Board HES Medical Management Vocational SeMces Case Management Services 20 4 $375.00 $40.60 $40.50 $32.50 Room & Board HES Medical Management Vocational Services i $375.00 2 20 $40.50 $40.60 Room & Board HES Medical Management 2 $375.00 $375.00 $40.50. $81.00 Room & Board HES Medical Management 1 2 $376.00 $40.50 $376.00 1 2 20 $375.00 $40.50 $40, 60 $375.00. $810.00 1 2 $375.00 $376, 00 $81.00 $810, 00 $130, 00 08/25/06 08/26106 I 08/27/06 z's $81, 00 08/28/06 Room & Board HES Medical Management Vocational Services 1 $81.04 08/29/06 .c1 c:•.: Room & Board. HES Medical Management Vocational Services 20 Room & Board HES Medical Management Vocational Services 1 2 20 $375, 00 $40, 50 $376.00 $81.00 $40.50 $810, 00 Room & Board HES Medical Management 1 2 20 $375.00 $40.50 $375.00 $81.00 $40.60 $810, 00 $40.50 $40.50 $81.00 $810.00.. 08/30/06 .i.•,, :4 08/31/06 Vocational Services :51 ..t ;4 •i` r4 ki :-•-'1 TOTAL ITEMIZATION FOR 08121106-08/31/06 Average Daily Charge $12, 633.50 $1, 253.35 r1 ct,b .4. -•:v co 1 EXHIBIT Cae 8:12-dv-01935-JDW-MAP- Document 1 ITEMIZED STATEMENT FOR 0312112006 Filed SERVICE PERIOD OF 63/31/2006 Client Name: ITEMIZATION of SERVICES RENDERED Date of Total Service Units/Days Therapy Name 03/21/06 Room & Board 08124/12_77154 Rate per Unit Amount Due Adult Education Vocational Services 1 4 12 $267, 00 $46.66 $40.66 $257, 00 $186.60 $559.80 Room & Board Adult Education Vocational Services 1 4 12 $257.00 $46.65 $186, 60 $46.65 $669.80 Room & Board Adult Education Vocational Services 1 4 18 $257.00 $46.65 $46.65 $267.00 $188.60 $839.70 Room & Board Vocational Services 1 12 $257.00 $46.65 $257, 00 $559.80 Room & Board 1 $257.00 $257.00 Room & Board 1 $257.00 $267.00 Room & Board 1 2 $257.00 12 $267.00 $46.65 $46.65 $257.00 $659.80 03/22/06 $267.00 03/23/06 03/24/06 03/25/06 03/26/06 03/27/06 Speech Therapy Vocational Services $93.30 $559.80 03/28106 Room & Board 1 $267.00 Vocational Services 12 $46.65 Room & Board .1 18 $267.00 Vocational Services Room & Board Vocational Services I $257.00 18 $46, 65 Room & Board 1 $257.00 Adult Education 4 12 $46, 65 $46.66 03/29/06 $46.65 $257.00 $839.70 03/30/08 $257.00 $839.70 03/31/06 Vocational Services TOTAL ITEMIZATION FOR 03/21/08-03/31/06 Average Daily Charge $257, 00 $186, 60 $659.80 $9, 544.60 $867, 69 of 157 !Dagen 154 Case Document 1 Filed 08/24/12 Page 155 of 157 PagelD 155 Case 8:12-cv-01935-JDW-MAP Allstate Insurance Document 1 Company v Florida Filed 08/24/12 Institute for Page 156 of 157 Neurologic Rehabilitation, PagelD 156 et al Exhibit 13: Mail Fraud Chart MAIL FRAUD CHART laiw numb& tnitia, ls 2901672985 G.H. 2901672985 G.H. 2901672985 G.H. 2170854885 M.B. 2901672985 G.H. 2901672985 G.H. 2170164269 M.L. 2170164269 M.L. 2907688985 D.A. 2907688985 D.A. 2907688985 D.A. 2907688985 D.A. 2881939595 T.S. 2553910486 R.S. 2881939595 T.S. 2907688985 D.A. 2907688985 D.A. 2881939595 T.S. 2881939595 T.S. 2882309301 A.B. 2172448520 A.A. 2881939595 T.S. 2170854885 M.B. 2170854885 M.B. 2881939595 T.S. 2172448520 A.A. 2882309301 A.B. 2907688985 D.A. 2907688985 D.A. 2907688985 D.A. 2907688985 D.A. 2907688985 D.A. 2907688985 D.A. 2172448520 A.A. 2172448520 A.A. 2172448520 A.A. 2172448520 A.A. 2170854885 M.B. 2170854885 M.B. 2170854885 M.B. 2170854885 M.B. 2170854885 M.B. Date 9/11/2001 1/2/2002 5/21/2002 9/2/2002 4/21/2003 6/23/2003 6/21/2005 7/6/2005 12/21/2006 10/11/2006 11/12/2007 9/11/2007 7/23/2007 5/1/2007 12/11/2007 7/11/2008 10/1/2008 12/1/2008 1/2/2009 1/4/2010 11/11/2009 11/23/2009 11/23/2009 9/1/2010 2/1/2010 9/2/2010 9/1/2010 9/1/2010 8/11/2010 10/1/2009 5/11/2009 10/22/2007 10/11/2007 3/1/2010 11/2/2009 12/11/2009 1/11/2010 4/11/2011 5/2/2011 1/21/2011 8/1/2006 8/21/2006 Front To Contents Trcatipg Doctor FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill Jorge Villalba Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill Jorge Villalba Jorge Villalba Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill FINR Allstate Bill Jorge Villalba Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill FINR Allstate Jorge Villalba Bill, Jorge Villalba I ExHiBIT 4 Case 8:12-cv-01935-JDW-MAP Document 1 Filed 08/24/12 Page 157 of 157 PagelD Allstate Insurance Company v Florida Institute for Neurologic Rehabilitation, et al Exhibit 13: Mail Fraud Chart Om I tqpif, 411:10001._ 2882309301 A.13, 2882309301 A.B. 2901672985 G.H. 2901672985 G.H. 2901672985 G.H. 2901672985 G.H. 2901672985 G.H. 2901672985 G.1-1. 2901672985 G.H. 2901672985 GM. 2901672985 G.H. 2170164269 M.B. 2170164269 KB. 2170164269 M.B. 2170164269 M.B. 2170164269 M.B. 2881939595 T.S. 2881939595 LS. 2881939595 T.S. 2881939595 T.S. 2881939595 T.S. 2881939595 T.S. 2909659216 K.S. 2909659216 K.S. 2909659216 K.S. 2909659216 K.S. 2909659216 K.S. 2909659216 K.S. 2909659216 K.S. 2559932129 T.D. 2559932129 T.D. 2559932129 T.D. 2559932129 T.D. 2554220471 J.G. 2554220471 J.G. 2553910486 R.S. 2553910486 R.S. 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F1NR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill Jorge Villalba Jorge Villalba Jorge Villalba HNR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill Jorge Villalba Jorge Villalba Jorge Villalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Vil lalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill Jorge Vilfalba FINR Allstate Bill Jorge Villalba FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill Jorge Villalba Jorge Villa Iba Jorge Villalba Waguth El Masry Waguth El Masry Waguth El Masry FINR Allstate Bill F1NR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill FINR Allstate Bill Jorge Villalba Jorge Villalba 157