Preview
FILED: NASSAU COUNTY CLERK 10/12/2022 03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 123 RECEIVED NYSCEF: 10/12/2022
FILED: NASSAU COUNTY CLERK 08/29/2022
10/12/2022 05:34
03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 123
92 5164395161
15164395161
1 RECEIVED NYSCEF:
p.1
P.1 08/29/2022
10/12/2022
25 19 11:02a
2519 11:02a Alexandria
1:15;M ND,
No, 2592 P.
P- 22
See, 20
368.20, 20'9
20 '9 1 : 15;M
W"
RECORD CERTIFICATION
Dorf & Nelson LIP
LLP
The International
The international Corporate
Corporate Center
Center
555
S55 Theodore Fremd Avenue
Frernd Avenue
Rye, MY.
1N, 1Q580
10580 '
Dear
Dear Counselors,
I,I, the
the undersigned,
undersigned, am3m authorized
authorized by by Pvcciq,;
•Pec n-.-^ cfr-••
Ci U~t• ({'Su-cd
• 5L-1-f.'61'T~i -S^-j
w^rne of
at onElty
entity providing
114rIle twoviaifia rmioin
r^cc^O! ' Ci ^
to certify the records and
and state
state the following:
fallowing:
The attached records are a copy of the original records which were made hin the ordinary and
business, they were made at the time of the events recorded therein
regular course of business, or within
therein or within
a reasonable time thereafter and It It was the regular and ordinary course of business of of this
this
entity
entity to make records such -as these.
as these.
r rv
Signature
Sfefiaturft
Sf.s
! •y.
Cr,Ctirq".‘-k
Print Name
000001
000001
FILED: NASSAU COUNTY CLERK 08/29/2022
10/12/2022 05:34
03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 92
123 RECEIVED NYSCEF: 08/29/2022
10/12/2022
1
Syed M. Sayeed M.D.
Precision Surgery of New York PC
139
139 Plandome Rd Manhasset, NY 11030 1 1030
P: (516)-439-5160 F: (516)-439-5161
(516)-439~5161
Progress Note:
))\n0 no Bonavi+01
80f)(3vi|tfl
000002
FILED: NASSAU COUNTY CLERK 08/29/2022
10/12/2022 05:34
03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 92
123 RECEIVED NYSCEF: 08/29/2022
10/12/2022
Syed M. Sayeed, M.D.
Precision Surgery of New York PC
Precision PC
139
139 Plandome Rd
Plandome Rd
Manhasset, NY 11030
Tel (516)439-5160 Fax Fax (516)439-5161
(516)439-5161
FAX TRANSMITTAL SHEET
To:
To: From:
From:
• 1))UY-i - Glee her AiMQrrkjuD
ALWanAteD
d
Company:
Company: Date:
Date:
1OI25h .
Fax Number:
Fax Number: Tel Number:
Number:
-Li(k-Co(o03 5.1(0 —4610- cpLoco
5h~moiD-(do£b
Total Number
Number of Pages Pages Including this this Cover:
Cover: (0
Notes/Comments:
Notes/Comments:
eN
opeot)ve ))1n0 &Mt/ .
CONFIDENTIALITY NOTICE: NOTICE: Including any attachments, is for the sole use of the
intended recipient
recipient (s) and may contain confidential and privileged information or otherwise be be
protected by
protected by the
the law.
law. Any
Any unauthorized review;
review; use, disclosure or distribution is prohibited.
prohibited. If
If
you are not
you not the intended recipient,
recipient, please contact the sender by reply and destroy all copies of thethe
original message.
message.
?au, coib(rn 11xe401 of-k- law! /
"Than
7724%)
V- oq
000003
000003
FILED: NASSAU COUNTY CLERK 08/29/2022
10/12/2022 05:34
03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 92
123 RECEIVED NYSCEF: 08/29/2022
10/12/2022
OfficeJet Pro X576dw MFP Series
HP Officejet Fax Log for
Alexandria
15164395161
15164395161
Oct 25 2017
201 7 12:36PM
12:36PM
Last Transaction
Date Time
Time Type
Type Station
Station ID
ID Duration Pages
Pages Result
Digital
Digital Fax
Fax
Oct 25 12:34PM Fax Sent 15164666603
15164666603 2:29
2:29 8
6 OK
OK
N/A
000004
FILED: NASSAU COUNTY CLERK 08/29/2022
10/12/2022 05:34
03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 92
123 RECEIVED NYSCEF: 08/29/2022
10/12/2022
(4°Na\
OCA Official Form No.: 960
H *P A 4 •
AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA HEPAA
[This
[This form has been approved by the New York State Department of Health]
Patient
Name
PatieniName < Date
Date of Birth
Binh , Social Security Number
Pi
Dino no Booctv,-1-a
fongxvma
Patient Address
Patient Is?*
V £>ir\c\a^°\ PltSwi ome.
Pia"clowte, mad , 46k-Ak4Sse4" i•If
NW 11030
Ii03o 4-1.
4 VI61-514.0
8. person to whom this information will be sent:
8. Name and address of person(s) or category ofperson Phone 516-466-6600
Dr. Burt Greenberg 833 Northern Blvd.,
Blvd » »Suite 230 Great Neck,
Neck NY 11021
11021 Fax
Pax 516-466-6603
1 1 —— i i i trnmtmmm-m
i i ii
9(a). Specific information to be released:
0 Medical Record from (insert date) to (insert date)
Entire Medical Record, including patient histories, office notes (except psychotherapy notes), test results, radiology
3A Entire
`Xi radiology studies,
studies, films,
films,
referrals, consults, billing records, insurance records, and records sent to you by other health care providers.
providers.
0 Other:
Other Include: (Indicate by Initialing)
Alcohol/Drug Treatment
T reatment
Mental
Mental Health Information
Information
Authorization to Discuss
Discuss, t -• Itkformation
• formation -„, HIV-Related Information
(b) in VI
p By initialing here {VIP y( II authorize Q'~"~—
/) r S1 ee IJ -^rfyr-r/
-r4 c"1/
-.11" nitials
111"-Initials Nance o
Nameofi individual health care provider
individual
to discuss my health information with •
• Dr.
Dr. Burt Greenberg and/or his associates
10.
10. Reason for release of information: 11.
11. this authorization will
Date or event on which this will expire:
At the request of
of the above referenced 1
1 year from date of signature
patient
12. If the patient, name of person signing form:
Ifnot the 13.
13, Authority to sign on behalf of patient:
,..
II
il items on this
c been completed and my questions about
about this
this form
form have been answered.
have been answered. In
In addition,
addition, II have
have been
been provided
provided a
a copy
lot
copy
'the
"the form.
paU'ent or representative authorized by law.
Signature of patient
Date:
Date: lfll 22114- \1r
Human Immunodeficiency
Immunodeficiency Virus that causes AIDS.
AIDS. The New York
York State Public
Public Health Law protects information which
reasonably could identify someone as having HIV symptoms or infection and information regarding a person's contacts.
1.•d
I'd B88:
8 666
mm™00 vz100
FILED: NASSAU COUNTY CLERK 08/29/2022
10/12/2022 05:34
03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 92
123 RECEIVED NYSCEF: 08/29/2022
10/12/2022
rrorn:
rrom: on raxiviaj*^ io:
10: tsun
bun ureenoerg
oreenoerg page:
Page: trr
iu i(j,iklku:ct.n
4:cts::so PM
uate: Tyu^AAil r tstiua pm
Hicksville
ZWANGER-PESIRI
ZWANGER-PESIR!
Hleksvflle
272 North Broadway
Hicksville, NY 11801
11801
RADIOLOGY
RADIOLOGY Phone: (516)686-0900
(516)686-0800
Fax: (516)681-0302
(516)6B1-0302
:: Burt Greenberg, MD Patient:
Patient: Dino Bonavita
:::: 833 Northern Boulevard, Suite 230 MRN: 2561238
Great Neck,
Neck, NY
NY 11021
11021 Act*
Aco#: 15791121
15791121
DOB:
Home Phone: (516)860-8819
(516)860-8819
Exam Date: 10/18/2017
1 0/1 8/201 7 11:55
1 1 :55 AM
Exam: MRI-3T RIGHT
RIGHT HAND PRE
AND POST IV
73220
IV CONTRAST
CONTRAST | I
MRI-3T RIGHT HAND PRE AND POST IV IV CONTRAST
History:
History: Right
Right hand pain and limited range of motion.
motion. Attention to the fourth finger.
Concern for glass foreign body. Injury in July 2017.
Pain
Pain fingers, M79.644
M 79. 644
Contusion/bruise/discoloration, S60,00XA
S60. OOXA
Stiffness, M25.64
M2S.64
Comparison Studies: Right
Right fourth finger radiographs and 10//2017,
1O//2017.
Technique: The right hand was imaged in a 3.0 Tesla ultra high field magnetic resonance
imaging unit. Axial fat-saturated TI-weighted,
Tl-weighted, Tl-weighted and fat-saturated proton
density images; sagittal proton density Images; and coronal TI-weighted,
images; arid Tl-weighted, gradient echo and
STIR images were obtained. Next, following the Intravenous
intravenous administration of 80.4cc of
Gadavlst contrast, axial, corona!
coronal and sagittal fat-saturated TL-weighted
Tl-weighted images were
obtained. Subtraction axial images were created from the precontrast and postcontrast
posteontrast data
sets.
Findings:
Findings:
Enhancing subcutaneous edema is present at the dorsal aspect of the fourth MP joint and
fourth finger proximal phalangeal base. See sagittal images 1Q and
Images 27 of series 10 and .
posteontrast series 14, axial images 29-36 of series 5, series 6, series
postcantrast series 11,
11, postcontrast
posteontrast
series 12 and subtraction series
series 100.
100.
The same images demonstrate a partial tear of the fourth finger extensor tendon
tendon at
at the
the
joint, with associated sagittal
level of the fourth MP Joint, band injury.
sagittal bandInjury. This noted in
is noted
This is in
association with the presence of numerous surrounding punctate low signal structures.
structures.
tissues dorsal
These correlate with a faintly radiopaque foreign body seen in soft tissues to the
dorsal to the
10/4/2017 (this density
right fourth MP joint on the lateral radiograph from 10/4/2017 is partially
density is partially
super-imposition on the proximal phalangeal bases).
obscured by superimposition
10/4/2017 demonstrated additional faintly
The lateral radiographs from 10/4/2017 faintly radiopaque
radiopaque
subcentlmeter foreign bodies dorsal to the distal shaft
clustered subcentimeter shaft of
of the
the right
right fourth
fourth
GFI Faxfulaker
FaxMaker lax
This fax was sent with GFI fax server. For
For mete visit http://www.gfi.com
mere information,
information, visit
http.7Awww.sfi.com
Zd
2'd
wm >z 100
FILED: NASSAU COUNTY CLERK 08/29/2022
10/12/2022 05:34
03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 92
123 RECEIVED NYSCEF: 08/29/2022
10/12/2022
From:
From: GA
GFI Faxmisilas\
FaxM^«\ To: Burt Greenberg Page: 2/2 Date: '046
912017 4:58:35 PM
^UK^/2017 PM
Continued...
MRN: 2561238
2561238 Exam
Exam Date: 10/18/2017
10/18/2017 11:55 AM
AM
Patient:
Patient: Dino
Dino Bonavita
Bonavita Exam:
Exam: MRI-3T
MRI-3T RIGHT
RIGHT HAND
HAND PRE
PRE AND
AND POST
POST IV
(V
Aca:
Acc#: 15781121
157S1121 CONTRAST I1 73220
finger proximal
proximal phalanx. Sagittal image
image 27 of series 14
14 and axial images 21
21 of series 6
and post contrast series 21
21 demonstrate mildly
mildly enhancing subcutaneous edema in this
region. Associated low signal structure seen within the subcutaneous fat could represent
the foreign bodies seen on radiographs, though some may represent vessels.
The visualized neurovascular
neurovascular structures are unremarkable.
Physiologic
Physiologic fluid is
is seen within
within the
the Included
included articulations.
articulations.
There is
is no
no evidence of stress injury, fracture, osteonecrosis, osteomyelitis or osseous
neoplasm.
neoplasm.
No
No capsuloligamentous injury isis visualized.
visualized.
There is mild
mild enthesopathy at the metacarpal attachment of the radial collateral ligament
of the second MP joint.
joint
No
No soft
soft tissue
tissue mass
mass is
is visualized.
visualized .
No soft tissue cyst or extrasynovial fluid
fluid collection
collection is
Is visualized.
visualized.
Impression:
Impression:
Partial
Partial tear of the right fourth finger extensor tendon and
and sagittal
sagittal band at the level of
the fourth MP joint, accompanied by enhancing edema. Within this edema are are several
several
punctate low signal structures which correlate with a faint radiopaque foreign body
body on the
lateral
lateral radiograph 10/4/2017. Additional smaller foreign bodies seen dorsal to the fourth
radiograph 10/4/2017.
finger proximal phalangeal shaft on the radiographs are less well seen on this study
study -- see
see
description above.
Extensor
Extensor tendon
tendon tear,
tear, 566.319A
S66.319A
Superficial foreign body of right
right hand, initial
Initial encounter S60.551A
Signed by: Jonathan Klug
Klug MD
Signed Date:
Signed 10/19/2017 4:09
Date: 10/19/2017 4:09 PM
PM
Jonathan Klug,
Klug, M.D.,
M.D., Ext,
Ext, 4048
4048
Reports
Reports and
and images
Images are available on the Physicians
Physicians portal.
Portal.
This fax was sent with GFI F-axMaker
sstver.. For
FaxMaksr fax server.
For more information, visit
Visit- http:/Mrww.gfixorn
http://www.gfi.carn
c'd
e-d d88:666. 'z 0
FILED: NASSAU COUNTY CLERK 08/29/2022
10/12/2022 05:34
03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 92
123 RECEIVED NYSCEF: 08/29/2022
10/12/2022
"Woo
bm
Syed M. Sayeed M.D. p*
Precision Surgery of New York PC PC
139 Plandome Rd Manhasset, NY 11030
139 1 1030
P: (516)-439-5160
(516)-439-5160F: F: (516)-439-5161
(516)-439-5161
Ms. Jordan,
This letter responds to your letter of February 6, 2018, and April 10th 2018
2018 wherein asserted that
you asserted
wherein you that
patient D.B.'s claim "was processed and paid in error" because the "operations performed
performed did not meet
did not meet
the standard of care as reviewed by an independent review organization."
organization." Ihave reviewed the "expert
I have reviewed the "expert
reviewer report" enclosed with your letter, and found that none of the reviewer's findings
findings are
are
supported by the medical records. Set forthbelow are detailed explanations of the errorsmade
made by the
by the
"expert reviewer" excerpts of which II have included for clarity.
clarity.
This patient sustained a laceration to the right hand
Slowing procedures! '
following procedures: '° *** ^ °n 7/2'/R °" 7/21/1 7- « performed the
on 7/21/17. On 7/21/17, Dr. Sayeed performed the
I.
I.wound exploration
exploration
2. tendon repair
extensor tendon
extensor ring finger
right ring
repair rightfinger
3.
3, (MCP) joint capsule repair right ring finger
Metacarpophalangeal (MCP)
Preview
FILED: NASSAU COUNTY CLERK 10/12/2022 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 123 RECEIVED NYSCEF: 10/12/2022 FILED: NASSAU COUNTY CLERK 08/29/2022 10/12/2022 05:34 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 123 92 5164395161 15164395161 1 RECEIVED NYSCEF: p.1 P.1 08/29/2022 10/12/2022 25 19 11:02a 2519 11:02a Alexandria 1:15;M ND, No, 2592 P. P- 22 See, 20 368.20, 20'9 20 '9 1 : 15;M W" RECORD CERTIFICATION Dorf & Nelson LIP LLP The International The international Corporate Corporate Center Center 555 S55 Theodore Fremd Avenue Frernd Avenue Rye, MY. 1N, 1Q580 10580 ' Dear Dear Counselors, I,I, the the undersigned, undersigned, am3m authorized authorized by by Pvcciq,; •Pec n-.-^ cfr-•• Ci U~t• ({'Su-cd • 5L-1-f.'61'T~i -S^-j w^rne of at onElty entity providing 114rIle twoviaifia rmioin r^cc^O! ' Ci ^ to certify the records and and state state the following: fallowing: The attached records are a copy of the original records which were made hin the ordinary and business, they were made at the time of the events recorded therein regular course of business, or within therein or within a reasonable time thereafter and It It was the regular and ordinary course of business of of this this entity entity to make records such -as these. as these. r rv Signature Sfefiaturft Sf.s ! •y. Cr,Ctirq".‘-k Print Name 000001 000001 FILED: NASSAU COUNTY CLERK 08/29/2022 10/12/2022 05:34 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 92 123 RECEIVED NYSCEF: 08/29/2022 10/12/2022 1 Syed M. Sayeed M.D. Precision Surgery of New York PC 139 139 Plandome Rd Manhasset, NY 11030 1 1030 P: (516)-439-5160 F: (516)-439-5161 (516)-439~5161 Progress Note: ))\n0 no Bonavi+01 80f)(3vi|tfl 000002 FILED: NASSAU COUNTY CLERK 08/29/2022 10/12/2022 05:34 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 92 123 RECEIVED NYSCEF: 08/29/2022 10/12/2022 Syed M. Sayeed, M.D. Precision Surgery of New York PC Precision PC 139 139 Plandome Rd Plandome Rd Manhasset, NY 11030 Tel (516)439-5160 Fax Fax (516)439-5161 (516)439-5161 FAX TRANSMITTAL SHEET To: To: From: From: • 1))UY-i - Glee her AiMQrrkjuD ALWanAteD d Company: Company: Date: Date: 1OI25h . Fax Number: Fax Number: Tel Number: Number: -Li(k-Co(o03 5.1(0 —4610- cpLoco 5h~moiD-(do£b Total Number Number of Pages Pages Including this this Cover: Cover: (0 Notes/Comments: Notes/Comments: eN opeot)ve ))1n0 &Mt/ . CONFIDENTIALITY NOTICE: NOTICE: Including any attachments, is for the sole use of the intended recipient recipient (s) and may contain confidential and privileged information or otherwise be be protected by protected by the the law. law. Any Any unauthorized review; review; use, disclosure or distribution is prohibited. prohibited. If If you are not you not the intended recipient, recipient, please contact the sender by reply and destroy all copies of thethe original message. message. ?au, coib(rn 11xe401 of-k- law! / "Than 7724%) V- oq 000003 000003 FILED: NASSAU COUNTY CLERK 08/29/2022 10/12/2022 05:34 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 92 123 RECEIVED NYSCEF: 08/29/2022 10/12/2022 OfficeJet Pro X576dw MFP Series HP Officejet Fax Log for Alexandria 15164395161 15164395161 Oct 25 2017 201 7 12:36PM 12:36PM Last Transaction Date Time Time Type Type Station Station ID ID Duration Pages Pages Result Digital Digital Fax Fax Oct 25 12:34PM Fax Sent 15164666603 15164666603 2:29 2:29 8 6 OK OK N/A 000004 FILED: NASSAU COUNTY CLERK 08/29/2022 10/12/2022 05:34 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 92 123 RECEIVED NYSCEF: 08/29/2022 10/12/2022 (4°Na\ OCA Official Form No.: 960 H *P A 4 • AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA HEPAA [This [This form has been approved by the New York State Department of Health] Patient Name PatieniName < Date Date of Birth Binh , Social Security Number Pi Dino no Booctv,-1-a fongxvma Patient Address Patient Is?* V £>ir\c\a^°\ PltSwi ome. Pia"clowte, mad , 46k-Ak4Sse4" i•If NW 11030 Ii03o 4-1. 4 VI61-514.0 8. person to whom this information will be sent: 8. Name and address of person(s) or category ofperson Phone 516-466-6600 Dr. Burt Greenberg 833 Northern Blvd., Blvd » »Suite 230 Great Neck, Neck NY 11021 11021 Fax Pax 516-466-6603 1 1 —— i i i trnmtmmm-m i i ii 9(a). Specific information to be released: 0 Medical Record from (insert date) to (insert date) Entire Medical Record, including patient histories, office notes (except psychotherapy notes), test results, radiology 3A Entire `Xi radiology studies, studies, films, films, referrals, consults, billing records, insurance records, and records sent to you by other health care providers. providers. 0 Other: Other Include: (Indicate by Initialing) Alcohol/Drug Treatment T reatment Mental Mental Health Information Information Authorization to Discuss Discuss, t -• Itkformation • formation -„, HIV-Related Information (b) in VI p By initialing here {VIP y( II authorize Q'~"~— /) r S1 ee IJ -^rfyr-r/ -r4 c"1/ -.11" nitials 111"-Initials Nance o Nameofi individual health care provider individual to discuss my health information with • • Dr. Dr. Burt Greenberg and/or his associates 10. 10. Reason for release of information: 11. 11. this authorization will Date or event on which this will expire: At the request of of the above referenced 1 1 year from date of signature patient 12. If the patient, name of person signing form: Ifnot the 13. 13, Authority to sign on behalf of patient: ,.. II il items on this c been completed and my questions about about this this form form have been answered. have been answered. In In addition, addition, II have have been been provided provided a a copy lot copy 'the "the form. paU'ent or representative authorized by law. Signature of patient Date: Date: lfll 22114- \1r Human Immunodeficiency Immunodeficiency Virus that causes AIDS. AIDS. The New York York State Public Public Health Law protects information which reasonably could identify someone as having HIV symptoms or infection and information regarding a person's contacts. 1.•d I'd B88: 8 666 mm™00 vz100 FILED: NASSAU COUNTY CLERK 08/29/2022 10/12/2022 05:34 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 92 123 RECEIVED NYSCEF: 08/29/2022 10/12/2022 rrorn: rrom: on raxiviaj*^ io: 10: tsun bun ureenoerg oreenoerg page: Page: trr iu i(j,iklku:ct.n 4:cts::so PM uate: Tyu^AAil r tstiua pm Hicksville ZWANGER-PESIRI ZWANGER-PESIR! Hleksvflle 272 North Broadway Hicksville, NY 11801 11801 RADIOLOGY RADIOLOGY Phone: (516)686-0900 (516)686-0800 Fax: (516)681-0302 (516)6B1-0302 :: Burt Greenberg, MD Patient: Patient: Dino Bonavita :::: 833 Northern Boulevard, Suite 230 MRN: 2561238 Great Neck, Neck, NY NY 11021 11021 Act* Aco#: 15791121 15791121 DOB: Home Phone: (516)860-8819 (516)860-8819 Exam Date: 10/18/2017 1 0/1 8/201 7 11:55 1 1 :55 AM Exam: MRI-3T RIGHT RIGHT HAND PRE AND POST IV 73220 IV CONTRAST CONTRAST | I MRI-3T RIGHT HAND PRE AND POST IV IV CONTRAST History: History: Right Right hand pain and limited range of motion. motion. Attention to the fourth finger. Concern for glass foreign body. Injury in July 2017. Pain Pain fingers, M79.644 M 79. 644 Contusion/bruise/discoloration, S60,00XA S60. OOXA Stiffness, M25.64 M2S.64 Comparison Studies: Right Right fourth finger radiographs and 10//2017, 1O//2017. Technique: The right hand was imaged in a 3.0 Tesla ultra high field magnetic resonance imaging unit. Axial fat-saturated TI-weighted, Tl-weighted, Tl-weighted and fat-saturated proton density images; sagittal proton density Images; and coronal TI-weighted, images; arid Tl-weighted, gradient echo and STIR images were obtained. Next, following the Intravenous intravenous administration of 80.4cc of Gadavlst contrast, axial, corona! coronal and sagittal fat-saturated TL-weighted Tl-weighted images were obtained. Subtraction axial images were created from the precontrast and postcontrast posteontrast data sets. Findings: Findings: Enhancing subcutaneous edema is present at the dorsal aspect of the fourth MP joint and fourth finger proximal phalangeal base. See sagittal images 1Q and Images 27 of series 10 and . posteontrast series 14, axial images 29-36 of series 5, series 6, series postcantrast series 11, 11, postcontrast posteontrast series 12 and subtraction series series 100. 100. The same images demonstrate a partial tear of the fourth finger extensor tendon tendon at at the the joint, with associated sagittal level of the fourth MP Joint, band injury. sagittal bandInjury. This noted in is noted This is in association with the presence of numerous surrounding punctate low signal structures. structures. tissues dorsal These correlate with a faintly radiopaque foreign body seen in soft tissues to the dorsal to the 10/4/2017 (this density right fourth MP joint on the lateral radiograph from 10/4/2017 is partially density is partially super-imposition on the proximal phalangeal bases). obscured by superimposition 10/4/2017 demonstrated additional faintly The lateral radiographs from 10/4/2017 faintly radiopaque radiopaque subcentlmeter foreign bodies dorsal to the distal shaft clustered subcentimeter shaft of of the the right right fourth fourth GFI Faxfulaker FaxMaker lax This fax was sent with GFI fax server. For For mete visit http://www.gfi.com mere information, information, visit http.7Awww.sfi.com Zd 2'd wm >z 100 FILED: NASSAU COUNTY CLERK 08/29/2022 10/12/2022 05:34 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 92 123 RECEIVED NYSCEF: 08/29/2022 10/12/2022 From: From: GA GFI Faxmisilas\ FaxM^«\ To: Burt Greenberg Page: 2/2 Date: '046 912017 4:58:35 PM ^UK^/2017 PM Continued... MRN: 2561238 2561238 Exam Exam Date: 10/18/2017 10/18/2017 11:55 AM AM Patient: Patient: Dino Dino Bonavita Bonavita Exam: Exam: MRI-3T MRI-3T RIGHT RIGHT HAND HAND PRE PRE AND AND POST POST IV (V Aca: Acc#: 15781121 157S1121 CONTRAST I1 73220 finger proximal proximal phalanx. Sagittal image image 27 of series 14 14 and axial images 21 21 of series 6 and post contrast series 21 21 demonstrate mildly mildly enhancing subcutaneous edema in this region. Associated low signal structure seen within the subcutaneous fat could represent the foreign bodies seen on radiographs, though some may represent vessels. The visualized neurovascular neurovascular structures are unremarkable. Physiologic Physiologic fluid is is seen within within the the Included included articulations. articulations. There is is no no evidence of stress injury, fracture, osteonecrosis, osteomyelitis or osseous neoplasm. neoplasm. No No capsuloligamentous injury isis visualized. visualized. There is mild mild enthesopathy at the metacarpal attachment of the radial collateral ligament of the second MP joint. joint No No soft soft tissue tissue mass mass is is visualized. visualized . No soft tissue cyst or extrasynovial fluid fluid collection collection is Is visualized. visualized. Impression: Impression: Partial Partial tear of the right fourth finger extensor tendon and and sagittal sagittal band at the level of the fourth MP joint, accompanied by enhancing edema. Within this edema are are several several punctate low signal structures which correlate with a faint radiopaque foreign body body on the lateral lateral radiograph 10/4/2017. Additional smaller foreign bodies seen dorsal to the fourth radiograph 10/4/2017. finger proximal phalangeal shaft on the radiographs are less well seen on this study study -- see see description above. Extensor Extensor tendon tendon tear, tear, 566.319A S66.319A Superficial foreign body of right right hand, initial Initial encounter S60.551A Signed by: Jonathan Klug Klug MD Signed Date: Signed 10/19/2017 4:09 Date: 10/19/2017 4:09 PM PM Jonathan Klug, Klug, M.D., M.D., Ext, Ext, 4048 4048 Reports Reports and and images Images are available on the Physicians Physicians portal. Portal. This fax was sent with GFI F-axMaker sstver.. For FaxMaksr fax server. For more information, visit Visit- http:/Mrww.gfixorn http://www.gfi.carn c'd e-d d88:666. 'z 0 FILED: NASSAU COUNTY CLERK 08/29/2022 10/12/2022 05:34 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 92 123 RECEIVED NYSCEF: 08/29/2022 10/12/2022 "Woo bm Syed M. Sayeed M.D. p* Precision Surgery of New York PC PC 139 Plandome Rd Manhasset, NY 11030 139 1 1030 P: (516)-439-5160 (516)-439-5160F: F: (516)-439-5161 (516)-439-5161 Ms. Jordan, This letter responds to your letter of February 6, 2018, and April 10th 2018 2018 wherein asserted that you asserted wherein you that patient D.B.'s claim "was processed and paid in error" because the "operations performed performed did not meet did not meet the standard of care as reviewed by an independent review organization." organization." Ihave reviewed the "expert I have reviewed the "expert reviewer report" enclosed with your letter, and found that none of the reviewer's findings findings are are supported by the medical records. Set forthbelow are detailed explanations of the errorsmade made by the by the "expert reviewer" excerpts of which II have included for clarity. clarity. This patient sustained a laceration to the right hand Slowing procedures! ' following procedures: '° *** ^ °n 7/2'/R °" 7/21/1 7- « performed the on 7/21/17. On 7/21/17, Dr. Sayeed performed the I. I.wound exploration exploration 2. tendon repair extensor tendon extensor ring finger right ring repair rightfinger 3. 3, (MCP) joint capsule repair right ring finger Metacarpophalangeal (MCP)