Fort Lauderdale Office

713 East Broward Blvd, Suite R

Fort Lauderdale, FL 33301

Tel: (954) 845-0505

Fax: (954) 206-0050

Palm Beach Office

515 N. Flagler Drive, Suite P-300

West Palm Beach, FL 33401

Tel: (954) 260-5228

Fax: (954) 337-6227

Justin Weinstein, Esq.

Founding Partner

Justin@Weinstein-Legal.com

Matt Shafran, Esq.

Partner

Matt@Weinstein-Legal.com

Danielle Zukowsky, Esq.

Associate

Danielle@Weinstein-Legal.com

www.Weinstein-Legal.com

CLOSING STATEMENT

Client: Hector Fagundo Serrano

Date of Accident: June 26, 2019

Date of Closing: May 1, 2020

GROSS SETTLEMENT PROCEEDS: $7,100.00

DEDUCTIONS FOR OUTSTANDING MEDICAL BILLS ($90.00)

(Reduction letters attached)

DEDUCTION FOR ATTORNEYS’ FEES: ($2,364.30)

DEDUCTION FOR ATTORNEYS’ COSTS: ($24.35)

TOTAL PROCEEDS TO TRUSTEE: $4,621.35

Marcia T. Dunn

____To the best of my knowledge, understanding and belief, the only outstanding medical bills 

are those listed on the next page, and that each provider listed thereon has agreed in writing to take 

the reduced amounts as stated thereon and agreed to be paid from the Gross Settlement Proceeds 

above. I have seen no other health care providers or incurred any other health care expenses other 

than those listed on the next page. However, if there is any additional benefits paid by my health 

insurance in connection with this accident/claim, said health insurance will have a lien on my 

disbursement and I will be responsible to pay same.

____I affirm that I have not received Medicare or Medicaid benefits or through any supplement 

of same, benefits arising out of or related to this claim. In the event that it is determined that I have 

received any benefits, I shall be solely responsible to CMS or any other entity for any claim, right, 

lien, or cause of action that Medicare or Medicaid or any other supplement may assert which may 

include an action pursuant to the Medicare Secondary Payor Act (42 U.S.C. 1395y(b)). In addition, 

I agree to contact the appropriate entity, which may include MSPRC and pay or otherwise resolve 

any conditional payment asserted by CMS, MSPRC or any other entity related to this claim, and 

further agree to secure a document releasing me from any further liability regarding the foregoing.

EXHIBIT "A"

 EXHIBIT "A"

Case 19-23676-AJC Doc 36-1 Filed 05/12/20 Page 1 of 7
____I hereby acknowledge and agree that Justin Weinstein, P.A. d/b/a Weinstein Legal, has made 

a good faith effort to resolve any and all outstanding medical bills and liens, and that any 

unresolved medical bills and liens are my responsibility. I understand that Weinstein Legal makes 

no representations as to whether any of the medical providers I treated with in connection with this 

claim may at a future time seek reimbursement for the full amount of medical bills and I agree to 

hold harmless and covenant not to seek payment or sue Weinstein Legal for any past or future 

medical bills or any subrogation interest that your medical providers may have. Further, I agree to 

hold harmless and indemnify Weinstein Legal should any action arise.

____I hereby acknowledge that Justin Weinstein, P.A. d/b/a Weinstein Legal has advised me that 

I should seek the advice of an attorney that specifically specializes in Disability and/or Social 

Security law should this apply to me. I understand that Weinstein Legal makes no representations 

as to how disability or social security benefits will be affected by this settlement. I agree to hold 

harmless and covenant not to seek payment or sue Weinstein Legal for any issue arising regarding 

disability and/or Social Security benefits in relation to this claim/settlement. 

____ I hereby acknowledge that Justin Weinstein, P.A. d/b/a Weinstein Legal has advised me that 

I should seek the advice of an attorney that specifically specializes in Bankruptcy law should this 

apply to me. I understand that Weinstein Legal makes no representations as to how bankruptcy 

will be affected by this settlement. I agree to hold harmless and covenant not to seek payment or 

sue Weinstein Legal for any issue arising regarding bankruptcy in relation to this claim/settlement.

____I HAVE READ AND APPROVED this Closing Statement and the above paragraphs that I 

have initialed next to and hereby acknowledge that I agreed to accept and hereby accept the Gross 

Settlement Proceeds and the Net Proceeds to the Client as reflected above. 

_________________________________ ________________

HECTOR FAGUNDO SERRANO DATE

_________________________________

JUSTIN WEINSTEIN, ESQ.

Case 19-23676-AJC Doc 36-1 Filed 05/12/20 Page 2 of 7
OUTSTANDING MEDICAL BILLS AND LIENS

1) Chiropractic Clinics of South Florida ($0.00)

2) All Pro Orthopedics ($90.00)

3) Best American Diagnostic Center ($0.00)

4) Med Link Now ($0.00)

TOTAL $90.00

Case 19-23676-AJC Doc 36-1 Filed 05/12/20 Page 3 of 7
Case 19-23676-AJC Doc 36-1 Filed 05/12/20 Page 4 of 7
Fort Lauderdale Office

713 E Broward Blvd, Suite R

Fort Lauderdale, FL 33301

Tel: (954) 845-0505

Fax: (954) 206-0050

Palm Beach Office

515 N. Flagler Drive, Suite P-300

West Palm Beach, FL 33401

Tel: (954) 260-5228

Fax: (954) 206-0050

Justin Weinstein, Esq.

Managing Partner

Justin@Weinstein-Legal.com

Matt Shafran, Esq.

Partner

Matt@Weinstein-Legal.com

Danielle Zukowsky, Esq.

Associate

Danielle@Weinstein-Legal.com

www.Weinstein-Legal.com

April 22, 2020

VIA EMAIL ONLY: billing@bestamericandiagnostics.com & lisette@bestamericandiagnostics.com

Best American Diagnostics Center

Attn: Olga Bacallao

Re: My Client: Hector Fagundo Serrano

Date of Birth: January 18, 1984

Date of Loss: June 26, 2019

Dear Billing:

As you may know, we represent Hector Fagundo Serrano in connection with the personal 

injuries he sustained in an accident on June 26, 2019. On behalf of Mr. Fagundo Serrano, thank 

you for the treatment and services you have provided him. 

Unfortunately, the third-party tortfeasor’s insurance company has offered a nominal 

amount to settle the injury claim. The amount offered is not sufficient to pay all of Mr. Fagundo 

Serrano’s providers in full. According to my records, Mr. Fagundo Serrano incurred charges in 

the amount of $3,500.00 and PIP paid $1,905.26 That leaves a balance for which Mr. Fagundo 

Serrano is responsible.

We respectfully request that you waive the balance of your bill and accept the PIP 

payment as full and final settlement of Mr. Fagundo Serrano’s obligations to you. Your 

agreement in this regard will in no way impact your rights to seek additional payment from Mr. 

Fagundo Serrano’s PIP carrier. If you agree to waive Mr. Fagundo Serrano’s balance, please sign 

where indicated below. 

Sincerely,

/s/ Justin Weinstein

 Justin Weinstein, Esq.

Best American agrees to waive the balance due for Mr. Fagundo Serrano. This waiver includes 

Mr. Fagundo Serrano’s co-payment and/or deductible obligations. Upon signature below, Mr. 

Fagundo Serrano will be left with a balance of $0.00.

___________________________________

Print Name / Title

___________________________________

Signature

Date

JW/amd

olga m bacallao

4/23/20

Case 19-23676-AJC Doc 36-1 Filed 05/12/20 Page 5 of 7
Case 19-23676-AJC Doc 36-1 Filed 05/12/20 Page 6 of 7
Case 19-23676-AJC Doc 36-1 Filed 05/12/20 Page 7 of 7