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FILED: NASSAU COUNTY CLERK 10/12/2022 03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 114 RECEIVED NYSCEF: 10/12/2022
FILED: NASSAU COUNTY CLERK 08/24/2018
10/12/2022 01:01
03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 1
114 RECEIVED NYSCEF: 08/24/2018
10/12/2022
SUPREME COURT OF THE STATE OF NEW YORK
Index No.:
COUNTY OF NASSAU
Date Filed:
---------- --------------------------------------------------X
DINO BONAVITA '
SUMMONS
Plaintiff '
Plaintiff designates Nassau
County as the place of trial
-against-
The basis of the venue is:
Defendant's Practice
SYED MUJAHID SAYEED, M.D., PRECISION
SURGERY OF NEW YORK, P.C., NORTH SHORE . .
Defendant's practice is
UNIVERSITY HOSPITAL, and NORTHWELL HEALTH,
located at 139 Plandome Rd,
Manhasset, NY 11030
Defendants.
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TO THE ABOVE NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED to answer the complaint in this action, and
to serve a copy of your answer, or if the complaint is not served with this summons, to
Plaintiffs'
serve a notice of appearance, on the Attorney(s) within twenty (20) days after
the service of this summons, exclusive of the day of service, where service is made by
delivery upon you personally
within the state, or within thirty (30) days after the
completion of service where service is made in any other manner. In case of your failure
to appear or answer, judgment will be taken against you by default for the relief
demanded in the complaint.
Dated: New York, NY
August 24, 2018
CAITLIN ROBIN & ASSOCIATES, PLLC
Caitlin Robin
Attorneys for Plaintiffs
DINO BONAVITA
30 Broad Street, Suite 702
New York, New York 10004
Phone: (646) 524-6026
Fax: (929) 210-7549
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DEFENDANT'S ADDRESS:
SYED MUJAHID SAYEED, M.D.
139 Plandome Road
Manhasset, NY 11030
PRECISION SURGERY OF NEW YORK, P.C.
139 Plandome Road
Manhasset, NY 11030
NORTH SHORE UNIVERSITY HOSPITAL
300 Community Dr
Manhasset, NY 11030
NORTHWELL HEALTH
2000 Marcus Avenue
New Hyde Park, NY 11042
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
----------------------------------------------------------------X
DINO BONAVITA,
Plaintiff,
-against-
VERIFIED COMPLAINT
Index No.:
SYED MUJAHID SAYEED, M.D., PRECISION
SURGERY OF NEW YORK, P.C., NORTH SHORE
UNIVERSITY HOSPITAL, and NORTHWELL HEALTH,
Defendants.
---------------------------------------- ------X
Plaintiffs, by their attorneys, CAITLIN ROBIN & ASSOCIATES, PLLC, as and
for their Verified Complaint, alleges upon information and belief as follows:
1. At all times hereinafter mentioned, Plaintiff, DINO BONAVITA, was and
is a resident of 17 Sinclair Martin Drive, Roslyn, NY 11576.
2. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., was and still is a duly licensed physician
in the State of New York engaged in the practice of his profession in the Cotmty of
Nassau, State of New York, with a principal place of business located at139 Plandome
Road, Manhasset, NY 11030.
3. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant
and/or employee of PRECISION SURGERY OF NEW YORK, P.C. to render medical
evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or
consultation to DINO BONAVITA.
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4. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal,
member, shareholder and/or owner of the Defendant PRECISION SURGERY OF NEW
YORK, P.C., to render medical evaluation, assessment, diagnosis, care, treatment,
services, testing, surgery and/or consultation to DINO BONAVITA.
5. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant
and/or employee of Defendant NORTH SHORE UNIVERSITY HOSPITAL to render
medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery
and/or consultation to DINO BONAVITA.
6. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal,
member, shareholder and/or owner of the Defendant NORTH SHORE UNIVERSITY
HOSPITAL, to render medical evaluation, assessment, diagnosis, care, treatment,
services, testing, surgery and/or consultation to DINO BONAVITA.
7. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant
and/or employee of Defendant NORTHWELL HEALTH to render medical evaluation,
assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to
DINO BONAVITA.
8. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal,
member, shareholder and/or owner of the Defendant NORTHWELL HEALTH, to render
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medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery
and/or consultation to DINO BONAVITA.
9. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., was and still is a domestic
professional corporation duly organized and existing under and by the laws of the State of
New York with its principle place of business located at 139 Plandome Road, Manhasset,
NY 11030.
10. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., was and still is a foreign
limited liability company existing
under and by the laws of the State of New York with
its principle place of business located at 139 Plandome Road, Manhasset, NY 11030.
11. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., through its agents, servants,
employees and/or other medical personnel or other individuals acting under its agency,
supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held
itself out as a provider offering professional health care services to the members of the
general public, including Plaintiff, DINO BONAVITA.
12. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., through its agents, servants,
employees and/or other medical personnel or other individuals acting under its agency,
supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held
itself out as duly qùalified to render proper medical evaluation, assessment, diagnosis,
care, treatment, services, testing and/or consultation in accordance with good and
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accepted standards of practice in the community to the members of the general public,
including Plaintiff, DINO BONAVITA.
13. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., owned, operated,
maintained, supervised, managed, and controlled certain medical facilities known as
PRECISION SURGERY OF NEW YORK, P.C., where it employed such agents,
servants and/or employees for the purpose of rending diagnosis, care, treatment, surgical
services and advice to members of the general public, including Plaintiff, DINO
BONAVITA.
14. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., hired, engaged and/or
otherwise took responsibility for the actions of healthcare professionals, staff and
personnel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D.
15. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., is vicariously liable for the
actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D.
16. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, was and still is a domestic
professional corporation duly organized and existing under and by the laws of the State of
New York with its principle place of business located at 300 Community Drive,
Manhasset, NY 11030.
17. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, was and still is a foreign
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limited liability company existing under and by the laws of the State of New York with
its principle place of business located at 300 Community Drive, Manhasset, NY 11030.
18. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, through its agents, servants,
employees and/or other medical personnel or other individuals acting under its agency,
supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held
itself out as a provider offering professional health care services to the members of the
general public, including Plaintiff, DINO BONAVITA.
19. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, through its agents, servants,
employees and/or other medical personnel or other individuals acting under its agency,
supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held
itself out as duly qualified to render proper medical evaluation, assessment, diagnosis,
care, treatment, services, testing and/or consultation in accordance with good and
accepted standards of practice in the community to the members of the general public,
including Plaintiff, DINO BONAVITA.
20. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, owned, operated, maintained,
supervised, managed, and controlled certain medical facilities known as NORTH SHORE
UNIVERSITY HOSPITAL, where it employed such agents, servants and/or employees
for the purpose of rending diagnosis, care, treatment, surgical services and advice to
members of the general public, including Plaintiff, DINO BONAVITA.
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21. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, hired, engaged and/or
otherwise took responsibility
for the actions of healthcare professionals, staff and
personnel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D.
22. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, is vicariously liable for the
actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D.
23. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, was and still is a domestic professional
corporation duly organized and existing under and by the laws of the State of New York
with its principle place of business located at 2000 Marcus Avenue, New Hyde Park, NY
11042.
24. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, was and still is a foreign limited liability company
existing under and by the laws of the State of New York with its principle place of
business located at 2000 Marcus Avenue, New Hyde Park, NY 11042.
25. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, through its agents, servants, employees and/or
other medical personnel or other individuals acting under its agency, supervision and
control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as a
provider offering professional health care services to the members of the general public,
including Plaintiff, DINO BONAVITA.
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26. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, through its agents, servants, employees and/or
other medical personnel or other individuals acting under its agency, supervision and
control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as
duly
qualified to render proper medical evaluation, assessment, diagnosis, care, treatment,
services, testing and/or consultation in accordance with good and accepted standards of
practice in the community to the members of the general public, including Plaintiff,
DINO BONAVITA.
27. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, owned, operated, maintained, supervised,
managed, and controlled certain medical facilities known as NORTHWELL HEALTH,
where it employed such agents, servants and/or employees for the purpose of rending
diagnosis, care, treatment, surgical services and advice to members of the general public,
including Plaintiff, DINO BONAVITA.
28. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, hired, engaged and/or otherwise took
responsibility for the actions of healthcare professionals, staff and personnel, including
but not limited to Defendant SYED MUJAHID SAYEED, M.D.
29. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, is vicariously liable for the actions and/or
omissions of the Defendant, SYED MUJAHID SAYEED, M.D.
30. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., held himself out as duly qualified to
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render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing
and/or consultation in accordance with good and accepted standards of practice in the
community to the members of the general public, including Plaintiff, DINO BONAVITA.
31. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., held himself out as a provider offering
professional health care services to the members of the general public, including Plaintiff,
DINO BONAVITA.
32. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., through its agents, servants, employees
and/or other medical personnel or other individuals acting
under his agency, supervision
and control, held himself out as duly qualified to render proper medical evaluation,
assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance
with good and accepted standards of practice in the community to the members of the
general public, including Plaintiff, DINO BONAVITA.
33. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., hired, engaged and/or otherwise took
responsibility for the actions of healthcare professionals, staff and personnel, and had a
duty to manage, control and otherwise supervise their work during the care, treatment and
services of persons such as Plaintiff, DINO BONAVITA.
34. That upon information and belief, at all times herein mentioned,
Defendants, PRECISION SURGERY OF NEW YORK, P.C. and SYED MUJAHID
SAYEED, M.D. individually and by and through their agents, servants and/or employees
agreed to, undertook to and did render certain medical evaluation, assessment, diagnosis,
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care, treatment, testing, and surgical services, and/or consultation to Plaintiff, DINO
BONAVITA, beginning on or about July 21, 2017 through October 31, 2017.
35. That upon information and belief, at all times herein mentioned,
Defendants, PRECISION SURGERY OF NEW YORK, P.C. and SYED MUJAHID
SAYEED, M.D. individually and by and through their principals, members, shareholders
and/or owners agreed to, undertook to and did render certain medical evaluation,
assessment, diagnosis, care, treatment, testing, and surgical services, and/or consultation
to Plaintiff, DINO BONAVITA, beginning on or about July 21, 2017 through October
31, 2017.
36. That upon information and belief, at all times herein mentioned,
Defendants, NORTH SHORE UNIVERSITY HOSPITAL and SYED MUJAHID
SAYEED, M.D. individually and by and through their agents, servants and/or employees
agreed to, undertook to and did render certain medical evaluation, assessment, diagnosis,
care, treatment, testing, and surgical services, and/or consultation to Plaintiff, DINO
BONAVITA, beginning on or about July 21, 2017 through October 31, 2017.
37. That upon information and belief, at all times herein mentioned,
Defendants, NORTH SHORE UNIVERSITY HOSPITAL and SYED MUJAHID
SAYEED, M.D. individually and by and through their principals, members, shareholders
and/or owners agreed to, undertook to and did render certain medical evaluation,
assessment, diagnosis, care, treatment, testing, and surgical services, and/or consultation
Preview
FILED: NASSAU COUNTY CLERK 10/12/2022 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 114 RECEIVED NYSCEF: 10/12/2022 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF NASSAU Date Filed: ---------- --------------------------------------------------X DINO BONAVITA ' SUMMONS Plaintiff ' Plaintiff designates Nassau County as the place of trial -against- The basis of the venue is: Defendant's Practice SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH SHORE . . Defendant's practice is UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, located at 139 Plandome Rd, Manhasset, NY 11030 Defendants. ----------------------------------------------------------------------X TO THE ABOVE NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED to answer the complaint in this action, and to serve a copy of your answer, or if the complaint is not served with this summons, to Plaintiffs' serve a notice of appearance, on the Attorney(s) within twenty (20) days after the service of this summons, exclusive of the day of service, where service is made by delivery upon you personally within the state, or within thirty (30) days after the completion of service where service is made in any other manner. In case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: New York, NY August 24, 2018 CAITLIN ROBIN & ASSOCIATES, PLLC Caitlin Robin Attorneys for Plaintiffs DINO BONAVITA 30 Broad Street, Suite 702 New York, New York 10004 Phone: (646) 524-6026 Fax: (929) 210-7549 1 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 DEFENDANT'S ADDRESS: SYED MUJAHID SAYEED, M.D. 139 Plandome Road Manhasset, NY 11030 PRECISION SURGERY OF NEW YORK, P.C. 139 Plandome Road Manhasset, NY 11030 NORTH SHORE UNIVERSITY HOSPITAL 300 Community Dr Manhasset, NY 11030 NORTHWELL HEALTH 2000 Marcus Avenue New Hyde Park, NY 11042 2 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ----------------------------------------------------------------X DINO BONAVITA, Plaintiff, -against- VERIFIED COMPLAINT Index No.: SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, Defendants. ---------------------------------------- ------X Plaintiffs, by their attorneys, CAITLIN ROBIN & ASSOCIATES, PLLC, as and for their Verified Complaint, alleges upon information and belief as follows: 1. At all times hereinafter mentioned, Plaintiff, DINO BONAVITA, was and is a resident of 17 Sinclair Martin Drive, Roslyn, NY 11576. 2. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., was and still is a duly licensed physician in the State of New York engaged in the practice of his profession in the Cotmty of Nassau, State of New York, with a principal place of business located at139 Plandome Road, Manhasset, NY 11030. 3. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant and/or employee of PRECISION SURGERY OF NEW YORK, P.C. to render medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 3 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 4. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal, member, shareholder and/or owner of the Defendant PRECISION SURGERY OF NEW YORK, P.C., to render medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 5. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant and/or employee of Defendant NORTH SHORE UNIVERSITY HOSPITAL to render medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 6. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal, member, shareholder and/or owner of the Defendant NORTH SHORE UNIVERSITY HOSPITAL, to render medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 7. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant and/or employee of Defendant NORTHWELL HEALTH to render medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 8. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal, member, shareholder and/or owner of the Defendant NORTHWELL HEALTH, to render 4 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 9. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., was and still is a domestic professional corporation duly organized and existing under and by the laws of the State of New York with its principle place of business located at 139 Plandome Road, Manhasset, NY 11030. 10. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., was and still is a foreign limited liability company existing under and by the laws of the State of New York with its principle place of business located at 139 Plandome Road, Manhasset, NY 11030. 11. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., through its agents, servants, employees and/or other medical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as a provider offering professional health care services to the members of the general public, including Plaintiff, DINO BONAVITA. 12. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., through its agents, servants, employees and/or other medical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as duly qùalified to render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance with good and 5 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 accepted standards of practice in the community to the members of the general public, including Plaintiff, DINO BONAVITA. 13. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., owned, operated, maintained, supervised, managed, and controlled certain medical facilities known as PRECISION SURGERY OF NEW YORK, P.C., where it employed such agents, servants and/or employees for the purpose of rending diagnosis, care, treatment, surgical services and advice to members of the general public, including Plaintiff, DINO BONAVITA. 14. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., hired, engaged and/or otherwise took responsibility for the actions of healthcare professionals, staff and personnel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D. 15. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., is vicariously liable for the actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D. 16. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, was and still is a domestic professional corporation duly organized and existing under and by the laws of the State of New York with its principle place of business located at 300 Community Drive, Manhasset, NY 11030. 17. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, was and still is a foreign 6 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 limited liability company existing under and by the laws of the State of New York with its principle place of business located at 300 Community Drive, Manhasset, NY 11030. 18. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, through its agents, servants, employees and/or other medical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as a provider offering professional health care services to the members of the general public, including Plaintiff, DINO BONAVITA. 19. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, through its agents, servants, employees and/or other medical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as duly qualified to render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance with good and accepted standards of practice in the community to the members of the general public, including Plaintiff, DINO BONAVITA. 20. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, owned, operated, maintained, supervised, managed, and controlled certain medical facilities known as NORTH SHORE UNIVERSITY HOSPITAL, where it employed such agents, servants and/or employees for the purpose of rending diagnosis, care, treatment, surgical services and advice to members of the general public, including Plaintiff, DINO BONAVITA. 7 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 21. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, hired, engaged and/or otherwise took responsibility for the actions of healthcare professionals, staff and personnel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D. 22. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, is vicariously liable for the actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D. 23. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, was and still is a domestic professional corporation duly organized and existing under and by the laws of the State of New York with its principle place of business located at 2000 Marcus Avenue, New Hyde Park, NY 11042. 24. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, was and still is a foreign limited liability company existing under and by the laws of the State of New York with its principle place of business located at 2000 Marcus Avenue, New Hyde Park, NY 11042. 25. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, through its agents, servants, employees and/or other medical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as a provider offering professional health care services to the members of the general public, including Plaintiff, DINO BONAVITA. 8 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 26. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, through its agents, servants, employees and/or other medical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as duly qualified to render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance with good and accepted standards of practice in the community to the members of the general public, including Plaintiff, DINO BONAVITA. 27. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, owned, operated, maintained, supervised, managed, and controlled certain medical facilities known as NORTHWELL HEALTH, where it employed such agents, servants and/or employees for the purpose of rending diagnosis, care, treatment, surgical services and advice to members of the general public, including Plaintiff, DINO BONAVITA. 28. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, hired, engaged and/or otherwise took responsibility for the actions of healthcare professionals, staff and personnel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D. 29. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, is vicariously liable for the actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D. 30. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., held himself out as duly qualified to 9 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance with good and accepted standards of practice in the community to the members of the general public, including Plaintiff, DINO BONAVITA. 31. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., held himself out as a provider offering professional health care services to the members of the general public, including Plaintiff, DINO BONAVITA. 32. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., through its agents, servants, employees and/or other medical personnel or other individuals acting under his agency, supervision and control, held himself out as duly qualified to render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance with good and accepted standards of practice in the community to the members of the general public, including Plaintiff, DINO BONAVITA. 33. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., hired, engaged and/or otherwise took responsibility for the actions of healthcare professionals, staff and personnel, and had a duty to manage, control and otherwise supervise their work during the care, treatment and services of persons such as Plaintiff, DINO BONAVITA. 34. That upon information and belief, at all times herein mentioned, Defendants, PRECISION SURGERY OF NEW YORK, P.C. and SYED MUJAHID SAYEED, M.D. individually and by and through their agents, servants and/or employees agreed to, undertook to and did render certain medical evaluation, assessment, diagnosis, 10 of 21 FILED: NASSAU COUNTY CLERK 08/24/2018 10/12/2022 01:01 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 1 114 RECEIVED NYSCEF: 08/24/2018 10/12/2022 care, treatment, testing, and surgical services, and/or consultation to Plaintiff, DINO BONAVITA, beginning on or about July 21, 2017 through October 31, 2017. 35. That upon information and belief, at all times herein mentioned, Defendants, PRECISION SURGERY OF NEW YORK, P.C. and SYED MUJAHID SAYEED, M.D. individually and by and through their principals, members, shareholders and/or owners agreed to, undertook to and did render certain medical evaluation, assessment, diagnosis, care, treatment, testing, and surgical services, and/or consultation to Plaintiff, DINO BONAVITA, beginning on or about July 21, 2017 through October 31, 2017. 36. That upon information and belief, at all times herein mentioned, Defendants, NORTH SHORE UNIVERSITY HOSPITAL and SYED MUJAHID SAYEED, M.D. individually and by and through their agents, servants and/or employees agreed to, undertook to and did render certain medical evaluation, assessment, diagnosis, care, treatment, testing, and surgical services, and/or consultation to Plaintiff, DINO BONAVITA, beginning on or about July 21, 2017 through October 31, 2017. 37. That upon information and belief, at all times herein mentioned, Defendants, NORTH SHORE UNIVERSITY HOSPITAL and SYED MUJAHID SAYEED, M.D. individually and by and through their principals, members, shareholders and/or owners agreed to, undertook to and did render certain medical evaluation, assessment, diagnosis, care, treatment, testing, and surgical services, and/or consultation