On January 31, 2018 a
Party Discovery
was filed
involving a dispute between
Gerald M. Pittner
As Executor Of The Estate Of Rosemarie Pittner,
and
Erie County Medical Center,
Erie County Medical Center Corporation,
Mareena S. Zachariah, M.D.,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Erie County.
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FILED: ERIE COUNTY CLERK 03/27/2018 04:12 PM INDEX NO. 801430/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 03/27/2018
STATE OF NEW YORK
SUPREME COURT: COUNTY OF ERIE
GERALD M. PITTNER, as Executor of the Estate of
ROSEMARIE PITTNER,
NOTICE OF
Plaintiff, EXAMINATION
BEFORE TRIAL
vs. Index No. 801430/2018
ERIE COUNTY MEDICAL CENTER; ERIE COUNTY
MEDICAL CENTER CORPORATION; MAREENA S.
ZACHARIAH, M.D.
Defendants.
PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and
Rules, the testimony of the Plaintiff, will be taken before a notary public, or another person
authorized to administer oaths under the laws of the State of New York, at a mutually agreeable
date, time, and place.
That the matters upon which such person or persons are to be examined are all the
relevant facts and circumstances in connection with the accident alleged in the Complaint herein,
including negligence, liability and damages.
PLEASE TAKE FURTHER NOTICE, that the parties to be examined are requested to
produce upon said examination any and all records, memoranda and data in their possession
relating to the matters upon which the examination is sought herein for the purpose of refreshing
witnesses'
the recollection.
Dated: Buffalo, New York
March 26, 2018
FELDMAN KIEFFER, LLP
gz, '
Ci<
mes E. Eagan, Ed.
TELDMAN KIEFFER, LLP
Attorneys for Defendant
Mareena S. Zachariah, M.D.
110 Pearl Street, Suite 400
Buffalo, New York 14202
(716) 852-5875
1 of 2
FILED: ERIE COUNTY CLERK 03/27/2018 04:12 PM INDEX NO. 801430/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 03/27/2018
To: Theresa M. Walsh, Esq.
Brown Chiari, LLP
2470 Walden Avenue
Buffalo, New York 14225
(716) 681-7190
Cc: Kevin A. Ricotta, Esq.
RICOTTA & VISCO
Attorneys & Counselors At Law
Attorneys for Defendants
Erie County Medical Center
Erie County Medical Center Corporation
496 Main Street
Buffalo, New York 14202
2 of 2
Document Filed Date
March 27, 2018
Case Filing Date
January 31, 2018
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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FILED: ERIE COUNTY CLERK 03/27/2018 04:12 PM INDEX NO. 801430/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 03/27/2018 STATE OF NEW YORK SUPREME COURT: COUNTY OF ERIE GERALD M. PITTNER, as Executor of the Estate of ROSEMARIE PITTNER, NOTICE OF Plaintiff, EXAMINATION BEFORE TRIAL vs. Index No. 801430/2018 ERIE COUNTY MEDICAL CENTER; ERIE COUNTY MEDICAL CENTER CORPORATION; MAREENA S. ZACHARIAH, M.D. Defendants. PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony of the Plaintiff, will be taken before a notary public, or another person authorized to administer oaths under the laws of the State of New York, at a mutually agreeable date, time, and place. That the matters upon which such person or persons are to be examined are all the relevant facts and circumstances in connection with the accident alleged in the Complaint herein, including negligence, liability and damages. PLEASE TAKE FURTHER NOTICE, that the parties to be examined are requested to produce upon said examination any and all records, memoranda and data in their possession relating to the matters upon which the examination is sought herein for the purpose of refreshing witnesses' the recollection. Dated: Buffalo, New York March 26, 2018 FELDMAN KIEFFER, LLP gz, ' Ci< mes E. Eagan, Ed. TELDMAN KIEFFER, LLP Attorneys for Defendant Mareena S. Zachariah, M.D. 110 Pearl Street, Suite 400 Buffalo, New York 14202 (716) 852-5875 1 of 2 FILED: ERIE COUNTY CLERK 03/27/2018 04:12 PM INDEX NO. 801430/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 03/27/2018 To: Theresa M. Walsh, Esq. Brown Chiari, LLP 2470 Walden Avenue Buffalo, New York 14225 (716) 681-7190 Cc: Kevin A. Ricotta, Esq. RICOTTA & VISCO Attorneys & Counselors At Law Attorneys for Defendants Erie County Medical Center Erie County Medical Center Corporation 496 Main Street Buffalo, New York 14202 2 of 2