No Value: Nathaniel Grayton, Sherri Skidmore v. Vasudha Viswanathan Md, Calixto Cazano Md, Rajendra Bhayani Md, Fernando Ginebra Md, Sony Loiseau Md, Wyckoff Heights Medical Center

• 
• 
• 
• 

						
                                
Preview
                                FILED:         KINGS       COUNTY         CLERK        02/03/2021             03:46       PM                        INDEX    NO.   508009/2013
   NYSCEF     DOC.   NO.   110                                                                                RECEIVED      NYSCEF:     02/03/2021




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF KINGS
                  -----------------------------------------------------------------------X         Index No.: 508009/2013
                  NATHANIEL GRAYTON, an Infant, by his mother
                  and natural guardian, SHERRI SKIDMORE,
                                                                                                   AFFIRMATION
                                                               Plaintiffs,                         OF GOOD FAITH

                                    – against –

                  VASUDHA VISWANATHAN, M.D,. CALIXTO
                  CAZONO, M.D., RAJENDRA BHAYANI, M.D.,
                  FERNANDO GINEBRA, M.D., SONY LOISEAU, M.D.,
                  And WYCKOFF HEIGHTS MEDICAL CENTER

                                                               Defendants.
                  -----------------------------------------------------------------------X
                           MATTHEW REISMAN, an attorney duly licensed to practice law before the Courts of

                  the State of New York, affirms the following under the penalties of perjury:

                  1.        I am an associate of the firm of ARSHACK HAJEK & LEHRMAN, PLLC., attorneys

                            for  defendants     SONY      LOISEAU,        M.D.    and   WYCKOFF          HEIGHTS         MEDICAL

                            CENTER, and I am familiar with the facts and circumstances heretofore had herein from

                            the file maintained in my office. I make this Affirmation of Good Faith in support of the

                            instant Motion to Dismiss plaintiff’s Complaint.

                  2.        On October 8, 2020, counsel for DR. LOISEAU and WYCKOFF sent plaintiff a good

                            faith   letter  joining   codefendant      CALIXTO         CAZANO,         M.D.     and   FERNANDO

                            GINEBRA, M.D.’s demand for all outstanding discovery.                     See Letter dated October 8,

                            2020, annexed hereto as Exhibit A.          Plaintiff has yet to respond to this letter.

                  3.        Based on the motion practice and the nature of the relief requested in the within motion

                            and the lack of response from plaintiff’s office, it is clear that the issues herein cannot be

                            resolved without court intervention. The instant motion practice was therefore necessary.




                                                                        1  of   2
   FILED:         KINGS       COUNTY         CLERK        02/03/2021             03:46       PM                        INDEX    NO.   508009/2013
   NYSCEF     DOC.   NO.   110                                                                                RECEIVED      NYSCEF:     02/03/2021




                  Dated: New York, New York
                           February 3, 2021




                                                                        Matthew Reisman




                                                                        2  of   2