On April 29, 2022 a
Party Discovery
was filed
involving a dispute between
Joseph Chan
As Administrator Of The Estate Of Yuk Chu Chan And Joseph Chan, Individually,
and
Gotham Health Gouverneur,
New York City Health And Hospitals Corporation,
Nyc Health And Hospitals Gotham Health Gouverneur,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 10/17/2022 03:43 PM INDEX NO. 805145/2022
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/17/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------------------X
JOSEPH CHAN as Administrator of the Estate of
YUK CHU CHAN and JOSEPH CHAN, Individually, Index No.: 805145/2022
NOTICE TO TAKE
Plaintiff,
DEPOSITION UPON
ORAL EXAMINATION
-against-
NYC HEALTH AND HOSPITALS/GOTHAM HEALTH
GOUVERNEUR, GOTHAM HEALTH GOUVERNEUR and
NEW YORK CITY HEALTH AND HOSPITALS
CORPORATION,
Defendants.
--------------------------------------------------------------------------X
COUNSELORS:
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and
Rules, the testimony, upon oral examination of the plaintiff, will be taken before a Notary Public
who is not an attorney, or employee of an attorney, for any party or prospective party herein and
is not a person who would be disqualified to act as a juror because of interest or because of
consanguinity or affinity to any party herein, at the office of KAUFMAN BORGEEST &
RYAN LLP, located at 1205 Franklin Avenue, Garden City, New York 11530 within ninety
(90) days at 10:00 o'clock in the forenoon of that day with respect to evidence and material
necessary in the defense of this action.
That the said person to be examined is required to produce at such examination any and
all documents relative to the claims in the plaintiff's Verified Amended Complaint, including
diaries, notes, summaries, calendars, bills and invoices, pertaining to the care rendered to the
plaintiff.
8537727
1 of 3
FILED: NEW YORK COUNTY CLERK 10/17/2022 03:43 PM INDEX NO. 805145/2022
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/17/2022
To the best of my knowledge, information and belief, formed after an inquiry reasonable under
the circumstances, the presentation of this paper or the contentions herein are not frivolous, as
that term is defined in Part 130 of the Court Rules.
Dated: Garden City, New York
October 17, 2022
Yours, etc.,
KAUFMAN BORGEEST & RYAN LLP
By:
Christine E. F. Rockwell
Attorneys for Defendant
NEW YORK CITY HEALTH + HOSPITALS
CORPORATION s/h/a NYC HEALTH AND
HOSPITALS/GOTHAM HEALTH
GOUVERNEUR, GOTHAM HEALTH
GOUVERNEUR and NEW YORK CITY
HEALTH AND HOSPITALS CORPORATION
1205 Franklin Avenue – 2nd Floor
Garden City, New York 11530
(516) 248-6000
KBR File No.: 961-110
TO: SINEL & OLESEN, PLLC
Attorneys for Plaintiff
330 7th Avenue, 10th Floor
New York, New York 10001
(212) 465-1000
2
8537727
2 of 3
FILED: NEW YORK COUNTY CLERK 10/17/2022 03:43 PM INDEX NO. 805145/2022
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/17/2022
Index No.: 805145/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
JOSEPH CHAN as Administrator of the Estate of YUK CHU CHAN and JOSEPH CHAN,
Individually,
Plaintiff(s),
-against-
NYC HEALTH AND HOSPITALS/GOTHAM HEALTH GOUVERNEUR, GOTHAM
HEALTH GOUVERNEUR and NEW YORK CITY HEALTH AND HOSPITALS
CORPORATION,
Defendants.
NOTICE TO TAKE DEPOSITION
KAUFMAN BORGEEST & RYAN LLP
ATTORNEYS AT LAW
1205 FRANKLIN AVENUE
2nd FLOOR
GARDEN CITY, NEW YORK 11530
(516) 248-6000
ATTORNEYS FOR DEFENDANT
NEW YORK CITY HEALTH + HOSPITALS CORPORATION s/h/a NYC HEALTH
AND HOSPITALS/GOTHAM HEALTH GOUVERNEUR, GOTHAM HEALTH
GOUVERNEUR and NEW YORK CITY HEALTH AND HOSPITALS CORPORATION
3
8537727
3 of 3
Document Filed Date
October 17, 2022
Case Filing Date
April 29, 2022
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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Preview
FILED: NEW YORK COUNTY CLERK 10/17/2022 03:43 PM INDEX NO. 805145/2022 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/17/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------------X JOSEPH CHAN as Administrator of the Estate of YUK CHU CHAN and JOSEPH CHAN, Individually, Index No.: 805145/2022 NOTICE TO TAKE Plaintiff, DEPOSITION UPON ORAL EXAMINATION -against- NYC HEALTH AND HOSPITALS/GOTHAM HEALTH GOUVERNEUR, GOTHAM HEALTH GOUVERNEUR and NEW YORK CITY HEALTH AND HOSPITALS CORPORATION, Defendants. --------------------------------------------------------------------------X COUNSELORS: PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony, upon oral examination of the plaintiff, will be taken before a Notary Public who is not an attorney, or employee of an attorney, for any party or prospective party herein and is not a person who would be disqualified to act as a juror because of interest or because of consanguinity or affinity to any party herein, at the office of KAUFMAN BORGEEST & RYAN LLP, located at 1205 Franklin Avenue, Garden City, New York 11530 within ninety (90) days at 10:00 o'clock in the forenoon of that day with respect to evidence and material necessary in the defense of this action. That the said person to be examined is required to produce at such examination any and all documents relative to the claims in the plaintiff's Verified Amended Complaint, including diaries, notes, summaries, calendars, bills and invoices, pertaining to the care rendered to the plaintiff. 8537727 1 of 3 FILED: NEW YORK COUNTY CLERK 10/17/2022 03:43 PM INDEX NO. 805145/2022 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/17/2022 To the best of my knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of this paper or the contentions herein are not frivolous, as that term is defined in Part 130 of the Court Rules. Dated: Garden City, New York October 17, 2022 Yours, etc., KAUFMAN BORGEEST & RYAN LLP By: Christine E. F. Rockwell Attorneys for Defendant NEW YORK CITY HEALTH + HOSPITALS CORPORATION s/h/a NYC HEALTH AND HOSPITALS/GOTHAM HEALTH GOUVERNEUR, GOTHAM HEALTH GOUVERNEUR and NEW YORK CITY HEALTH AND HOSPITALS CORPORATION 1205 Franklin Avenue – 2nd Floor Garden City, New York 11530 (516) 248-6000 KBR File No.: 961-110 TO: SINEL & OLESEN, PLLC Attorneys for Plaintiff 330 7th Avenue, 10th Floor New York, New York 10001 (212) 465-1000 2 8537727 2 of 3 FILED: NEW YORK COUNTY CLERK 10/17/2022 03:43 PM INDEX NO. 805145/2022 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/17/2022 Index No.: 805145/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK JOSEPH CHAN as Administrator of the Estate of YUK CHU CHAN and JOSEPH CHAN, Individually, Plaintiff(s), -against- NYC HEALTH AND HOSPITALS/GOTHAM HEALTH GOUVERNEUR, GOTHAM HEALTH GOUVERNEUR and NEW YORK CITY HEALTH AND HOSPITALS CORPORATION, Defendants. NOTICE TO TAKE DEPOSITION KAUFMAN BORGEEST & RYAN LLP ATTORNEYS AT LAW 1205 FRANKLIN AVENUE 2nd FLOOR GARDEN CITY, NEW YORK 11530 (516) 248-6000 ATTORNEYS FOR DEFENDANT NEW YORK CITY HEALTH + HOSPITALS CORPORATION s/h/a NYC HEALTH AND HOSPITALS/GOTHAM HEALTH GOUVERNEUR, GOTHAM HEALTH GOUVERNEUR and NEW YORK CITY HEALTH AND HOSPITALS CORPORATION 3 8537727 3 of 3