Preview
FILED: NASSAU COUNTY CLERK 10/12/2022 03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 109 RECEIVED NYSCEF: 10/12/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
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DINO BONAVITA, Index No.: 611506/2018
Plaintiffs,
-against- NOTICE OF MOTION
SYED MUJAHID SAYEED, M.D., PRECISION REFER TO:
SURGERY OF NEW YORK, P.C., NORTH SHORE HON. THOMAS RADEMAKER
UNIVERSITY HOSPITAL, and NORTHWELL
HEALTH, IAS PART: 21
Defendants. RETURN DATE: NOVEMBER 1, 2022
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COUNSELORS:
PLEASE TAKE NOTICE, that upon the annexed Affirmation of Kerrianne Russo, Esq.,
dated October 12, 2022, the exhibits annexed thereto, including Defendants’ Statement of
Undisputed Material Facts, the Affirmation of Emergency Medicine Physician Robert Meyer,
M.D., the Affirmation of Radiologist Kevin Mennitt, M.D., and upon all of the pleadings, and
proceedings heretofore had herein, defendants NORTH SHORE UNIVERSITY HOSPITAL,
(“defendant”) will move this Court before the Honorable Thomas Rademaker at the courthouse
located at 100 Supreme Court Drive, Mineola New York 11501 on November 1, 2022 at 9:30 a.m.,
or as soon thereafter as counsel can be heard, for an Order:
(a) pursuant to CPLR § 3212 granting summary judgment as to defendants
NORTH SHORE UNIVERSITY HOSPITAL dismissing the Complaint in
its entirety on the merits with prejudice; and
(b) directing the Clerk of the Court to enter judgment against plaintiff and in
favor of the moving defendant, accordingly; and
(c) for such other and further relief that this Court deems just and proper.
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FILED: NASSAU COUNTY CLERK 10/12/2022 03:55 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 109 RECEIVED NYSCEF: 10/12/2022
This is an action to recover monetary damages for alleged personal injuries. There has been
no prior request for the relief demanded herein.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 2214(b), answering
papers, and any notice of cross motion, with supporting papers, if any, must be served upon the
undersigned no later than seven (7) days before the return date of this motion.
Dated: October 12, 2022
Garden City, New York
RUBIN PATERNITI GONZALEZ
RIZZO KAUFMAN, LLP
_______________________________
Kerrianne Russo
Attorneys for Defendants
NORTH SHORE UNIVERSITY HOSPITAL
1225 Franklin Avenue, Suite 200
Garden City, New York 11530
(516) 344-6376
VIA NYSCEF
To: CAITLIN ROBIN & ASSOCIATES PLLC
Attorneys for Plaintiff
30 Broad Street. Suite 702
New York, NY 10004
(646) 524-6026
DORF & NELSON, LLP
Attorneys for Defendants
SYED MUJAHID SAYEED, M.D
PRECISION SURGERY OF NEW YORK, P.C.
The International Corporate Center
555 Theodore Fremd Avenue
Rye, New York, 10580
(914) 381-7600
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Preview
FILED: NASSAU COUNTY CLERK 10/12/2022 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 109 RECEIVED NYSCEF: 10/12/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ---------------------------------------------------------------------X DINO BONAVITA, Index No.: 611506/2018 Plaintiffs, -against- NOTICE OF MOTION SYED MUJAHID SAYEED, M.D., PRECISION REFER TO: SURGERY OF NEW YORK, P.C., NORTH SHORE HON. THOMAS RADEMAKER UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, IAS PART: 21 Defendants. RETURN DATE: NOVEMBER 1, 2022 --------------------------------------------------------------------X COUNSELORS: PLEASE TAKE NOTICE, that upon the annexed Affirmation of Kerrianne Russo, Esq., dated October 12, 2022, the exhibits annexed thereto, including Defendants’ Statement of Undisputed Material Facts, the Affirmation of Emergency Medicine Physician Robert Meyer, M.D., the Affirmation of Radiologist Kevin Mennitt, M.D., and upon all of the pleadings, and proceedings heretofore had herein, defendants NORTH SHORE UNIVERSITY HOSPITAL, (“defendant”) will move this Court before the Honorable Thomas Rademaker at the courthouse located at 100 Supreme Court Drive, Mineola New York 11501 on November 1, 2022 at 9:30 a.m., or as soon thereafter as counsel can be heard, for an Order: (a) pursuant to CPLR § 3212 granting summary judgment as to defendants NORTH SHORE UNIVERSITY HOSPITAL dismissing the Complaint in its entirety on the merits with prejudice; and (b) directing the Clerk of the Court to enter judgment against plaintiff and in favor of the moving defendant, accordingly; and (c) for such other and further relief that this Court deems just and proper. 1 of 2 FILED: NASSAU COUNTY CLERK 10/12/2022 03:55 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 109 RECEIVED NYSCEF: 10/12/2022 This is an action to recover monetary damages for alleged personal injuries. There has been no prior request for the relief demanded herein. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 2214(b), answering papers, and any notice of cross motion, with supporting papers, if any, must be served upon the undersigned no later than seven (7) days before the return date of this motion. Dated: October 12, 2022 Garden City, New York RUBIN PATERNITI GONZALEZ RIZZO KAUFMAN, LLP _______________________________ Kerrianne Russo Attorneys for Defendants NORTH SHORE UNIVERSITY HOSPITAL 1225 Franklin Avenue, Suite 200 Garden City, New York 11530 (516) 344-6376 VIA NYSCEF To: CAITLIN ROBIN & ASSOCIATES PLLC Attorneys for Plaintiff 30 Broad Street. Suite 702 New York, NY 10004 (646) 524-6026 DORF & NELSON, LLP Attorneys for Defendants SYED MUJAHID SAYEED, M.D PRECISION SURGERY OF NEW YORK, P.C. The International Corporate Center 555 Theodore Fremd Avenue Rye, New York, 10580 (914) 381-7600 2 of 2