A federal district court in Florida has denied a motion by a nail salon owner to quash two nonparty subpoenas served on her by an insurer that filed a lawsuit in New York alleging insurance fraud.

The Case

State Farm Mutual Automobile Insurance Company filed a civil case in the U.S. District Court for the Eastern District of New York, captioned State Farm Mutual Automobile Ins. Co. v. Parisien, No. 1:18-cv-00289-ILG (E.D.N.Y.) (the “Underlying Action”), that included allegations of a fraud-derived racketeering enterprise in Brooklyn, New York, that allegedly occurred in a clinic where physicians, chiropractors, acupuncture therapists and medical sources providers submitted bills to State Farm for treatments to automobile accident claimants. State Farm alleged that these treatments were medically unnecessary, ineligible for reimbursement, and/or never occurred. One of the issues in the Underlying Action was whether nonphysicians owned and controlled the Brooklyn clinic, directed patient treatment and siphoned the proceeds of the treatment to themselves.

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