SOM-L-000652-18 05/17/201811:53:02 AM Pg 1 of 20 Trans ID: ch'201886733'7 ATTORNEYS AT LAW NEW YORK OFFICE JAMES SULLIVAN: 60 MAPLE AVENUE 5 Columbus Circle, 1111} Floor GORDONTS. 32??ng 0 19.0. BOX 912 New York, NY 10019 LEE 5C0 07963-0912 (212) 8359462 CHRISTINE C. RYAN 0 (973) 540?087}? DANYELLE H. GOLLAND FAX (973) 540'3019 RAFAEL A. LLANO KELLY A. SHERWOOD JAMES F. SULLEVAN, JR 0 Certi?ed by the Supreme Court of NJ as a Civil Trial Attorney Rule 1:40 Quali?ed Mediator 0 Also admitted in NY May 15, 2018 Via Electronic Filing Clerk Somerset County Courthouse 20 N. Bridge Street Somerville, NJ 08876-1262 Re: NJPLIGA v. TODD KOPPEL, M.D., ET AL. Docket No. TO BE ASSIGNED Our File No. 12442-000-3 Dear Sir or Madam: Enclosed please find: (X) Verified Complaint (X) CIS Form (X) Filing Fee $250.00 Acct #140340 Would you please: (X) File LSleas Enclosures 8 05/17/2018 11:58:02 AM Pg 2 of 20 Trans ID: ch2018887887 Lee S. Befeler - NJ ID No. 024661987 SULLIVAN AND GRABER 60 Maple Avenue PO. Box 912 Morristown, NJ 07963?0912 (973) 540?0877 Attorney for Plaintiff Our File No. 12442?000-3 NEW JERSEY PROPERTY-LIABILITY INSURANCE GUARANTY ASSOCIATION, Plaintiff, vs. TODD KOPPEL, M.D., GARDEN STATE PAIN MANAGEMENT, P.A., JOHN DOES 1-100, JANE DOES 1-100, ABC INC. 1? 100 and DEF INC. 1?100, Individual Defendants, and NORTH AMERICAN PARTNERS IN ANESTHESIA, NORTHERN NJ ORTHO SPECIALISTS, TRINITAS REGIONAL MEDICAL CENTER, TRINITAS ANESTHESIA ASSOCIATES, BACK WORKS CHIROPRACTIC, P.C., SADDLE BROOK SURGICENTER, COASTAL ANESTHESIA ASSOCIATES, METRO ANESTHESIA ASSOCIATES, CLIFTON SURGERY CENTER, CITIMED SERVICES, P.A., ST. JOSEPH REGIONAL MEDICAL CENTER, SURGICORE SURGICAL CENTER, HEALTH PLUS SURGERY CENTER, DYNAMIC SURGERY CENTER, SPECIALTY SURGERY OF SECAUCUS, ASISH PATEL, SUN PHARMACY, and GLEN RIDGE PHARMACY, Interested Party Defendants. SUPERIOR COURT OF NEW JERSEY LAW DIVISION: SOMERSET COUNTY Docket No. Civil Action VERIFIED COMPLAINT AND JURY DEMAND SOM-L-000652-18 05/17/2018 11' :53:02 AM Pg 8 51?20 Trans ID: LCV2018867337 The plaintiff NEW JERSEY INSURANCE GUARANTY ASSOCIATION (hereinafter by way of Verified Complaint against the defendants TODD KOPPEL, M.D., GARDEN STATE PAIN MANAGEMENT, P.A., JOHN DOES 1-100, JANE DOES 1-100, ABC INC. 1?100 and DEF INC. 1?100 state as follows: NATURE OF ACTION AND RELIEF REQUESTED 1. This is an action brought by NJPLIGA against defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1?100, Jane Does 1?100, ABC Inc. 1? 100 and DEF Inc. 1-100 for violations of New Jersey statutes and regulations and the New Jersey Insurance Fraud Prevention Act, N.J.S.A. e_t seg. 2. To address their injuries, the plaintiff seeks an Order: i. Declaring that the defendants are ineligible to receive Personal Injury Protection benefits from the plaintiff and that the plaintiff is not obligated to pay claims the defendants have submitted to the plaintiff; ii. Declaring that the defendants are not entitled to Personal Injury Protection benefits from the plaintiff and that the plaintiff is not obligated to pay claims the defendants have submitted to the plaintiff; which contain fabricated and misleading billing and treatment records regarding among other things, patients? complaints, patients? patients? diagnoses, patients? examinations, the location of the service and the individuals providing the treatment, examinations and/or testing; Declaring the defendants are not entitled to PIP benefits from the plaintiff for any bills based on their payment of kickbacks to referring providers; iv. Declaring that any previously decided arbitration awards do not have to be paid pending the outcome of this action; v. Staying all arbitrations and lawsuits the defendants have instituted against the plaintiff; SOM-L-000652-18 05/17/2018 11:58:02 AM Pg 4 of 20 Trans ID: ch2018887387 vi. Awarding the plaintiff restitution and reimbursement of all monies paid to the defendants; vii. Awarding the plaintiff compensatory and treble damages under the New Jersey Insurance Fraud Prevention Act, N.J.S.A. e_t including but not limited to, compensatory damages, investigation costs, attorney?s fees, costs of suit and interest. FIRST COUNT 1. The plaintiff is authorized by statute to provide statutory PIP benefits to individuals that qualify under the New Jersey Property?Liability insurance Guaranty Association Act, gt and 39:6?61, gt 2. Pursuant to 17:1-15e, and P.L. 2003, c. is directed to assume responsibility for all management, administration and claims functions of the Unsatisfied Claim and Judgment Fund (UCJF) and'various insolvent insurance carriers including but not limited to Consumer First and 3. The defendant Garden State Pain Management, PA. is a business entity holding itself out as performing medical treatment and testing for individuals involved in motor vehicle accidents. 4. The defendant Todd Koppel, M.D., holds himself out as performing treatment and testing for individuals involved in motor vehicle accidents. 5. The defendants John Doe 1?100, represent medical providers including but not limited to physicians and chiropractors that hold themselves out as performing treatment and testing for individuals involved in motor vehicle accidents and may have treated claimants of the plaintiff. AM Pg 5 of 20 Trans LCV2018867337 6. The defendants Jane Doe 1-100 represent individuals that hold themselves out as performing treatment and testing for individuals involved in motor vehicle accidents and may have treated claimants of the plaintiff. 7. The defendants ABC Inc. 1-100 represent business entities that may have provided treatment for individuals involved in motor vehicle accidents that had claims against the plaintiff. 8. The defendants DEF Inc. 1400 represent business entities that may have provided billing and management services for medical providers treating individuals involved in motor vehicle accidents that had claims against the plaintiff. 9. The defendants have submitted claims to the plaintiff for the payment of PIP benefits for medical treatment and testing they claim to have performed. 10. At all relevant times, the defendants submitted and continue to submit claims for PIP medical expense bene?ts under statutorily?provided coverage by the plaintiff for medical treatment and testing the defendants claim they provided to individuals who are involved in the automobile accidents. 11. At all relevant times, the defendants intentionally and knowingly submitted false, fraudulent and misleading billing, treatment and testing records in which the defendants: i. Falsely represented the complaints, physiCal examination findings, injuries and need for treatment and testing; ii. Falsely represented that physical examinations were performed; Falsely represented the individual providing the examinations, treatment and testing of patients; iv. Falsely represented that the medical treatment and testing the defendants claim they provided were medically reasonable or 4 05/17/2018 11:53:02 AM Pg 6 of 20 Trans ID: LCV2018867337 necessary within the requirements of N.J.S.A. e1. the New Jersey No Fault Act, N.J.A.C. e_t and violated controlling requirements of law including N.J.S.A. gt 3529;, N.J.A.C. gt N.J.A.C. 13:35?11 e_t seq, N.J.A.C. 13:35?26, N.J.A.C. 13:35-65, N.J.S.A. 45:1?1 e_t s_eq;, N.J.S.A. e_t s_eq;, N.J.S.A. 39:6?61 e_t N.J.S.A. N.J.S.A. 17:1~15e, and P.L. 2003; v. Paid kickbacks to chiropractors, physicians and other individuals for the referral of patients; vi. Billed for procedures not performed; vii. Were not qualified to perform the procedures billed; Did not have hospital privileges to perform the procedures billed and/or performed; and ix. Did not have medical malpractice coverage for the procedures billed and/or performed. 12. The defendants were not eligible to recover benefits for the treatment and testing they allegedly performed based on the violations of controlling statutes and regulations. II 13. The defendants submitted claims to the plaintiff for bene?ts for the treatment and testing they allegedly performed with knowledge that they were not eligible to recover benefits. 14. The defendants? actions were undertaken for the purpose of defrauding the plaintiff by the submission of false, fraudulent and misleading claims for the payment of PIP medical expense benefits. 15. In reasonable reliance upon the defendants? actions and representations, both direct and implied, the plaintiff paid some of the defendants? claims for PIP benefits. 05/17/2018 11:53:02 AM Pg 7 of'20 Trans ID: LCV2018867337 16. At all relevant times, the defendants? conduct violated the New Jersey Insurance Fraud Prevention Act, e_t s_e_q, 17. The defendants engaged in a pattern and practice of violating the New Jersey Insurance Fraud Prevention Act. WHEREFORE, the plaintiff seeks a judgment against the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1?100, Jane Does 1-100, ABC Inc. 1-100 and DEF Inc. 1?100 jointly and severally: i. Declaring pursuant to the New Jersey Uniform Declaratory Judgment Act, N.J.S.A. gt E. that the defendants are not entitled to PIP bene?ts from the plaintiff and that the plaintiff is not obligated to pay claims submitted by or on behalf of the defendants. ii. Awarding the plaintiff restitution and reimbursement of all monies paid to the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1?100, Jane Does 1-100, ABC Inc. 1- 100 and DEF Inc. 1?100. Staying all arbitrations and lawsuits that have been instituted against the plaintiff by or on behalf of the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1-100, Jane Does 1?100, ABC Inc. 1?100 and DEF Inc. 1?100. iv. Vacating all arbitration awards and judgments that have been obtained against the plaintiff by or on behalf of the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1? 100, Jane Does 1?100, ABC Inc. 1~100 and DEF Inc. 1-100. v. Staying the enforcement of all arbitration awards and judgments that have been obtained against the plaintiff by or on behalf of the defendants. vi. Requiring the defendants to indemnify the plaintiff for all PIP medical expense benefits paid to other medical providers as a result of the defendants? fraudulent conduct. vii. Awarding the plaintiff compensatory and treble damages including, but not limited to, investigation costs, attorney?s fees, costs of suit and interest. 05/17/201811:53:02 AM Pg 8 of 20 Trans IDE: Awarding the plaintiff whatever other relief the Court deems appropriate and just. SECOND COUNT (Breach of Contract) 1. The plaintiff repeats all of the allegations contained in the First Count and incorporates them as if set forth at length herein. 2. The defendants submitted claims to the plaintiff for reimbursement of no fault benefits as assignees under the statutory benefits afforded by the plaintiff to the patients. 3. The plaintiff NJPLIGA is governed by New Jersey statutes, Administrative Cedes, regulations and Decision Point Review Plan. 4. The defendants, as assignees, are subject to the New Jersey statutes, Administrative Codes, regulations and Decision Point Review Plan governing the plaintiff. WHEREFORE, the plaintiff NJPLIGA seeks a judgment against the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1?100, Jane Does 1?100, ABC Inc. 1?100 and DEF lnc. 1?100 jointly and severally: i. Declaring pursuant to the New Jersey Uniform Declaratory Judgment Act, N.J.S.A. E. that the defendants are not entitled to PIP benefits from the plaintiff and that the plaintiff is not obligated to pay claims submitted by or on behalf of the defendants. ii. Awarding the plaintiff restitution and reimbursement of all monies paid to the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1~100, Jane Does 1-100, ABC inc. 1- 100 and DEF Inc. 1?100. Staying all arbitrations and lawsuits that have been instituted against the plaintiff by or on behalf of the defendants Todd Koppel, M.D., scum-00065248 05/17/2018 11:53:02 AM Pg 9 of 20 Trans ID: LCV2018867337 Garden State Pain Management, P.A., John Does 1?100, Jane Does 1?100, ABC Inc. 1?100 and DEF Inc. 1?100. iv. Vacating all arbitration awards and judgments that have been obtained against the plaintiff by or on behalf of the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1? 100, Jane Doe's 1?100, ABC Inc. 1?100 and DEF Inc. 1?100. v. Staying the enforcement of all arbitration awards and judgments that have been obtained against the plaintiff by or on behalf of the defendants. vi. Requiring the defendants to indemnify the plaintiff for all PIP medical expense benefits paid to other medical providers as a result of the defendants? fraudulent conduct. vii. Awarding the plaintiff compensatory and treble damages including, but not limited to, investigation costs, attorney?s fees, costs of suit and interest. Awarding the plaintiff whatever other? relief the Court deems appropriate and just. THIRD COUNT (Breach of Covenant of Good Faith and Fair Dealing) 1. The plaintiff repeats all of the allegations contained in the First and Second Counts and incorporates them as if set forth here at length. 2. The defendants owe a duty to the plaintiff to abide by the implied covenant of good faith and fair dealing, which by operation of law, is embodied in the rules, regulations, statutes and Plan of the plaintiff. I 3. Through the course of conduct previously alleged, the defendants have breached the covenant of good faith and fair dealing in numerous instances. The defendants? actions have, among other things, deprived the plaintiff of its rights under the statutes, regulations and Plan and are contrary to the spirit of the New Jersey soul-00065248 05/17/201811:53:02 AM Pg 10 of 20 Trans ID: LCV2018867337E Property?Liability Insurance Guaranty Association, the Unsatisfied Claim and Judgment Fund and their enabling statutes. 4. As a consequence of the defendants? breaches of the covenant of good faith and fair dealing, the plaintiff has suffered damages. WHEREFORE, the plaintiff NJPLIGA seeks a judgment against the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1?100, Jane Does 1?100, ABC Inc. 1-100 and DEF Inc. 1?100 jointly and severally: i. Declaring pursuant to the New Jersey Uniform Declaratory Judgment Act, N.J.S.A. _e_t that the defendants are not entitled to PIP benefits from the plaintiff and that the plaintiff is not obligated to pay claims submitted by or on behalf of the defendants. ii. Awarding the plaintiff restitution and reimbursement of all monies paid to the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1?100, Jane Does 1-100, ABC Inc. 1- 100 and DEF lnc.? 1?100. Staying all arbitrations and lawsuits that have been instituted against the plaintiff by or on behalf of the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1?100, Jane Does 1?100, ABC Inc. 1?100 and DEF Inc. 1-100. iv. Vacating all arbitration awards and judgments that have been obtained against the plaintiff by or on behalf of the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1? 100, Jane Does 1400, ABC Inc. 1-100 and DEF Inc. 1?100. v. Staying the enforcement of all arbitration awards and judgments that have been obtained against the plaintiff by or on behalf of the defendants; vi. Requiring the defendants to indemnify the plaintiff for all PIP medical expense benefits paid to other medical providers as a result of the defendants? fraudulent conduct. vii. Awarding the plaintiff compensatory and treble damages including, but not limited to, investigation costs, attorney?s fees, costs of suit and interest. SGML-000652918 AM Pg11of20'Tranle:LCV2018867337 Awarding the plaintiff whatever other relief the Court deems appropriate and just. FOURTH COUNT (Unjust Enrichment) 1. The plaintiff repeats all of the allegations contained in the First, Second and Third Counts and incorporates them as if set forth here at length. 2. The defendants? actions resulted in the unjust enrichment to the defendants to the detriment of the plaintiff. WHEREFORE, the plaintiff NJPLIGA seeks a judgment against the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1?100, Jane Does 1?100, ABC Inc. 1400 and DEF Inc. 1-100 jointly and severally: i. Declaring pursuant to the New Jersey Uniform Declaratory Judgment Act, N.J.S.A. gt that the defendants are not entitled to PIP bene?ts from the plaintiff and that the plaintiff is not obligated to pay claims submitted by or on behalf of the defendants. ii. Awarding the plaintiff restitution and reimbursement of all monies paid to the defendants Todd' Koppel, M.D., Garden State Pain Management, P.A., John Does 1-100, Jane Does 1-100, ABC Inc. 1- 100 and DEF Inc. Staying all arbitrations and lawsuits that have been instituted against the plaintiff by or on behalf of the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1?100, Jane Does 1-100, ABC Inc. 1-100 and DEF Inc. 1-100. iv. Vacating all arbitration awards and judgments that have been obtained against the plaintiff by or on behalf of the defendants Todd Koppel, M.D., Garden State Pain Management, P.A., John Does 1- 100, Jane Does 1-100, ABC Inc. 1-100 and DEF Inc. 1-100. v. Staying the enforcement of all arbitration awards and judgments that have been obtained against the plaintiff by or on behalf of the defendants. 10 05/17/2018 11:58:02 AM Pg 12 of 20 Trans vi. Requiring the defendants to indemnify the plaintiff for all PIP medical expense benefits paid to other medical providers as a result of the defendants? fraudulent conduct. vii. Awarding the plaintiff compensatory and treble damages including, but not limited to, investigation costs, attorney?s fees, costs of suit and interest. Awarding the plaintiff whatever other relief the Court deems appropriate and just. FIFTH COUNT Interested parties - Medical Providers 1. The plaintiffs repeat each and every allegation of the preceding Counts and incorporate them as if set forth here at length. 2. The following parties may have legal rights, duties, obligations andfor other interests affected by this action. They are named as interested parties pursuant to the provisions of the New Jersey Declaratory Judgment Act, N.J.S.A. 2A216-50 gt 3. The interested party defendants (including John Doe defendants, Jane Doe defendants, ABC defendants and DEF defendants) North American Partners in Anesthesia, Northern NJ Ortho Specialists, Trinitas Regional Medical Center, Trinitas Anesthesia Associates, Back Works Chiropractic, PC, Saddle Brook Surgicenter, Coastal Anesthesia Associates, Metro Anesthesia Associates, Clifton Surgery Center, Citimed Services, PA, St. Joseph Regional Medical Center, Surgicore Surgical Center, Health Plus Surgery Center, Dynamic Surgery Center, Specialty Surgery of Secaucus, Asish Patel, Sun Pharmacy and Glen Ridge Pharmacy are medical providers who perform medical services, administer anesthesia, host procedures performed by the defendants or provide medication prescribed by the defendants. 11 8 05/17/201811:58:o2 AM Pg 13 of 20 Trans ID: LCV2018887387 4. The interested parties named in this Count are licensed medical professionals, licensed medical facilities and/or medical/surgical practices who are or should have been registered with the New Jersey Department of Health also known as Physician?owned ambulatory surgery centers who are charged with and presumed to have knowledge of the significant qualifying requirements of the law pertaining to their delivery of medical services. 5. The interested party defendants have submitted claims to the plaintiff for medical services that they allegedly provided with the defendants. 6. The interested party defendants may have known that Todd Koppel was paying kickbacks for the referrals of patients. 7. The interested party defendants may have known that the procedures billed by Dr. Koppel were not being performed. 8. The interested party defendants knew or should have known that Dr. Koppel did not have the requisite training and hospital privileges or alternative privileges granted by the New Jersey Board of Medical Examiners to perform the procedures being billed for and/or performed. I 9. The interested party defendants are not entitled to PIP reimbursement for any service billed by Dr. Todd Koppel and/or Garden State Pain Management, P.A. because those services were performed in violation of New Jersey law. 10. The interested party defendants are named in this action for the purposes of discovery pursuant to Arcel v. Ashland Chemical Co.. Inc, 152 ML. 471 (Law Div. 1979) and N.J.S.A. 12 05/17/2018 11:53:02 Pg 14 of 20 Trans lD: ch2o18887887' WHEREFORE, the plaintiff seeks judgment: i. Declaring that the interested party defendants are not entitled to reimbursement; ii. Compelling the interested party defendants to provide the information and documents requested in the plaintiff?s demands for discovery; Declaring that in the event the defendants fail to comply with the plaintiff?s demands for discovery, they shall be ineligible for no fault payments from the plaintiff; and iv. Granting any other relief that the Court may deem appropriate and just. DEMAND FOR DISCOVERY Demand is hereby-made upon each of the defendants for discovery as follows: 1. Provide fully responsive and certi?ed answers to the plaintiff?s First Set of lnterrogatories attached as Exhibit A to this Complaint in accordance with the Court Rules. 2. Respond to the plaintiff?s First Notice to Produce attached as Exhibit to this Complaint in accordance with the Court Rules. 3. Produce for depositions the person or persons with knowledge of the subject matter of this action within 30 days of the defendants? providing full and complete responses to the plaintiff?s First Set of lnterrogatories and First Notice to Produce. 4. Produce the defendant Todd Koppel, MD. and Asish Patel for depositions within 30 days of the defendants? providing full and complete responses to the plaintiff?s First Set of interrogatories and First Notice to Produce. 5. Produce for depositions a representative of each of the interested party defendants. 13 SGML-000852418 05/17/2018 11:53:02 AM Pg 15 of 20 Trans ID: LCV2018887887 JURY DEMAND The plaintiff hereby demands a trial by a jury of six (6) persons on all issues herein. TRIAL COUNSEL DESIGNATION Pursuant to 4:25?5, Lee S. Befeler, Esq. is hereby designated as trial counsel for the plaintiff. CERTIFICATION OF NO OTHER ACTION 1. The within matter in controversy is not the subject of any other action pending in any Court or any pending Arbitration proceeding with the exception of those actions and arbitrations listed in Exhibit 1 and any additional arbitration demands and PIP suits that the defendants or other individuals and entities may have filed that are unknown at this time. 2. No other parties should presently in this action. ICEE s. DATED: May 15, 2018 14 SOM-L-000652-18 05/17/2018 11' :53:02 AM Pg 16 of 20 Trans LCV2018887887 VERIFICATION DOUGLAS HILLMAN, of full age, being duly swarm upon his oath deposes and says: I am the Director of Claims of the plaintiff New Jersey Property-Liability Insurance Guaranty Association. I have read the attached Veri?ed Complaint. have knowledge of the facts set forth. I verify that the allegations contained in the Complaint are true to my knowledge, information and belief. oedema swoan T0 and SUBSCRIBED before me this 3 day of mm?? .2018 out ?a?kndidrp? Ul LORI Notary Public State of New Jersey 3 My Commleaton Exams Octebar 6. 2919 "15 8 05/17/2018 11:58:02 AM Pg 17 of 20 Trans ID: EXHIBIT 1 BACK WORKS CHIROPACTIC P.C. a/s/o J.G.P. Forthright No. Claim No. 1614398 CITIMED SERVICES PA 31510 A.A.C. Forthright N0. Claim No. 1615120 SERVICES PA als/o B.A. Forthright No. Claim No. 1615120 CLIFTON SURGERY CENTER a/s/o A.A. Forthright N0. Claim No. 1615120 CLIFTON SURGERY CENTER als/o B.A. Forthright N0. Claim No. 1615120 CLIFTON SURGERY CENTER alts/0 DP. Forthright N0. Claim No. 1611565 COASTAL ANESTHESIA ASSOCIATES P.T. Forthright N0. Claim NO. 1512319 COASTAL ANESTHESIA ASSOCIATES a/S/o V.M. Forthright N0. Claim No. 1611456 DR. TODD KOPPEL GARDEN STATE PAIN MGMT.) als/o A.A. Forthright N0. Claim No. 1615120 DR. TODD KOPPEL (DBA GARDEN STATE PAIN MGMT.) afslo B.A. Forthright N0. Claim No. 1615120 DYNAMIC SURGERY CENTER a/s/o A.A.C. Forthright N0. Claim NO. 1615120 GARDEN STATE PAIN MANAGEMENT als/o B.H. Forthright N0. Claim No. 1611242 GARDEN STATE PAIN MANAGEMENT a/s/O D.P. Forthright N0. Claim No. 1611565 GARDEN STATE PAIN MANAGEMENT E.V. Forthright N0. Claim No. 1615992 GARDEN STATE PAIN MANAGEMENT a/S/o F.L. Forthright N0. Claim 1614928 16 SGML-00065248 05/17/201811:53:02 AM Pg18lof 20 Trans GARDEN STATE PAIN MANAGEMENT, PA J.C. Forthright N0. Claim No. 1610503 GARDEN STATE PAIN MANAGEMENT a/s/O J.V. Forthright N0. Claim No. 1710335 GARDEN STATE PAIN MANAGEMENT a/s/o L.G. Forthright N0. Claim NO. 1610061 GARDEN STATE PAIN MANAGEMENT a/s/o L.T. Forthright N0. Claim No. 1614838 GARDEN STATE PAIN MANAGEMENT SADDLEBROOK SURGICENTER a/S/o P.T. Forthright N0. Claim No. 1512319 GARDEN STATE PAIN MANAGEMENT a/S/o R.J. Forthright N0. Claim No. 1613353 GARDEN STATE PAIN MANAGEMENT a/S/o R.R. Forthright N0. Claim No. 1611025 GARDEN STATE PAIN MANAGEMENT AND NORTHERN NJ ORTHO SPECIALISTS a/slo T.W. Forthright No. Claim No. 1510171 GARDEN STATE PAIN MANAGEMENT a/s/o V.D. Forthright N0. Claim No. 1610438 GARDEN STATE PAIN MANAGEMENT a/S/o V.M. Forthright N0. Claim No. 1611456 HEALTH PLUS SURGERY CENTER a/S/o A.A.C. Forthright N0. Claim NO. 1615120 METRO ANESTHESIA ASSOCIATES alslo B.A. Forthright N0. Claim No. 1615120 NORTH AMERICAN PARTNERS IN ANESTHESIA a/S/o J.C.A. Forthright N0. Claim No. 1610503 NORTH AMERICAN PARTNERS IN ANESTHESIA als/o P.T. Forthright N0. Claim No. 1512319 SADDLE BROOK SURGICENTER als/o L.L. Forthright N0. Claim No. 1610061 17 SOM-L-000652-18 05/17/201811:53:02 AM Pg 19 of 20 Trans ID: LCV2018867337 SADDLE BROOK SURGICENTER GARDEN STATE PAIN MANAGEMENT a/s/O V.B.R. Forthright No. Claim No. 1712015 SPECIALTY SURGERY OF SECAUCUS a/s/O V.M. Forthright N0. Claim No. 1611456 ST. JOSPEH REGIONAL MEDICAL CENTER OUTPATIENT a/s/o A.A. Forthright No. Claim No. 1615120 SURGICORE SURGICAL CENTER, LLC a/s/o A.A. Forthright N0. Claim No. 1615120 TRINITAS ANESTHESIA ASSOCIATES aIS/o B.H. For'thright N0. Claim No. 1611242 TRINITAS ANESTHESIA ASSOCIATES als/o D.P. Forthright N0. Claim No. 1611565 TRINITAS ANESTHESIA ASSOCIATES, LLC a/s/O L.L.G. Forthright N0. Claim No. 1610061 TRINITAS ANESTHESIA ASSOCIATES a/s/o T.W. Forthright No. Claim No. 1510171 TRINITAS REGIONAL MEDICAL CENTER a/s/o A.A. Forthright N0. Claim No. 1615120 TRINITAS REGIONAL MEDICAL CENTER a/s/O B.A. Forthright N0. Claim No. 1615120 TRINITAS REGIONAL MEDICAL CENTER B.H. Forthright N0. Claim No. 1611242 TRINITAS REGIONAL MEDICAL CENTER D.P. Forthright No. Claim No. 1611565 TRINITAS REGIONAL MEDICAL CENER als/O E.V.C. Forthright No. Claim No. 1615992 TRINITAS REGIONAL MEDICAL CENTER als/o J.C. Forthright No. Claim No. 1610503 TRINITAS REGIONAL MEDICAL CENTER als/o L.L.G. Forthright N0. Claim No. 1610061 18 SGML-0006524 8 AM Pg 20 of 20 Trans ID: LCV2O18867337H TRINITAS REGIONAL MEDICAL CENTER a/s/o P.T. Forthright No. NJ1702001715233, Claim No. 1512319 TRINITAS REGIONAL MEDICAL CENTER a/S/o R.J. Forthright N0. Claim No. 1613353 TRINITAS REGIONAL MEDICAL CENTER a/S/o T.W. Forthright N0. Claim No. 1510171 19 SOM-L-000652-18 05/17/2018 11:53:02 AM Pg 1 of 1 Trans ID: LCV2018867337 Civil Case Information Statement Case Details: SOMERSET Civil Part Docket# L-000652-18 Case Caption: NEW JERSEY PROPERTY- LIABILITY VS Case Type: INSURANCE FRAUD KOPPEL, M.D. T Document Type: Complaint with Jury Demand Case Initiation Date: 05/17/2018 Jury Demand: YES - 6 JURORS Attorney Name: LEE SCOTT BEFELER Hurricane Sandy related? NO Firm Name: SULLIVAN & GRABER Is this a professional malpractice case? NO Address: 60 MAPLE AVENUE P.O. BOX 912 Related cases pending: NO MORRISTOWN NJ 079630912 If yes, list docket numbers: Phone: Do you anticipate adding any parties (arising out of same Name of Party: PLAINTIFF : New Jersey Property-Liability transaction or occurrence)? NO Name of Defendant’s Primary Insurance Company (if known): Unknown THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION Do parties have a current, past, or recurrent relationship? NO If yes, is that relationship: Does the statute governing this case provide for payment of fees by the losing party? NO Use this space to alert the court to any special case characteristics that may warrant individual management or accelerated disposition: Do you or your client need any disability accommodations? NO If yes, please identify the requested accommodation: Will an interpreter be needed? NO If yes, for what language: I certify that confidential personal identifiers have been redacted from documents now submitted to the court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b) 05/17/2018 Dated /s/ LEE SCOTT BEFELER Signed