On December 17, 2013 a
Exhibit,Appendix
was filed
involving a dispute between
Nathaniel Grayton,
Sherri Skidmore,
and
Calixto Cazano Md,
Fernando Ginebra Md,
Rajendra Bhayani Md,
Sony Loiseau Md,
Vasudha Viswanathan Md,
Wyckoff Heights Medical Center,
for Medical Malpractice
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021
EXHIBIT B
FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021
(FILED : KINGS COUNTY LERK INDEX NO. 508009/2013
07/10/2014)
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 04/10/2014
TODAY'S CAL.# RJI DATEÓ/ / INTAKE PART
PRELIMINARY CONFERENCE ORDER
PURSUANT TO PART 202 OF THE UNIFORM CIVIL RULES
FOR THE SUPREME COURT KINGS COUNTY
HON. ÙÓ Å DATE: /20
di†t Gc unE7 e
B3
Index# () U !
Plaintiff(s)
Compliance Conference shall be held in
- against- IAS Part CCP on f 2,D , 20
at 9:30 a.m.
Žffý FAILURE OF COUNSEL TO ATTEND THE
COMPLIANCE CONFERENCE MAY RESULT
Defendant(s) IN THE IMPOSITION OF SANCTIONS
)f f
) f) D \Å/V d"d¥ /f
PRINT ALL INFORMATION CLEARLY
ATTORNEY FIRM L/)/VC by FOR PLAINTIFF
ATTORNEY FIRM rs e)t'nhbeA by Ù . FOR DEFENDANT
ATTORNEY FIRMŸ7mb c y to p by TWz FOR DEFENDANT f3
ATTORNEY FIRM by 2-, FOR DEFENDANT
o . a cc LAPL C.
DEFAULTS: DEFENDANT
HAS NOT BEEN SERVED/ HAS BEEN SERVED, NOT ANSWERED, AND TIME TO DO SO HAS EXPIRED.
DEFAULT JUDGMENT GRANTED / PENDING
THE DISCOVERY END DATE/ NOTE OF ISSUE DUE DATE IS / / 20Ó_
IT IS HEREBY ORDERED THAT THIS ACTION IS ASSIGNED TO THE:
EXPEDITED STANDARD PLEX TRACK
AND DISCLOSURE SHALL PROCEED AS FOLLOWS:
I. WRITE PLAINTTFF'S MOST SEVERE INJURY: N S vt( 2 C/ WS b / /) e u nde /t/
II. TYPE OF CASE: MOTOR VEHICLE
PREMISES LIABILITY
OFESSIONAL MALPRACTICE (MED. MAL. ETC.)
OTHER. BRIEFLY DESCRIBE:
_ CONTRACT
LABOR LAW
III. O CPLR 325 (D) eligible,upon furtherorder.
IV. INSURANCE COVERAGE (INCLUDING EXCESS AND/ OR UMBRELLA COVERAGE)
DEF NDANT DEFENDANT
F NOT FURNISHED, PLAINTIFF TO BE ADVISED IN WRITING BY 20 (/
'
IF NO EXCESS COVERAGE, PROVIDE AFFIDAVIT TO THAT EFFEC BY / / 20 /ff ,
FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021
Y N ERENCE ORD .R
dd
PRELIMIN C
V. BILL PARTICULARS: - S-eA c t
. SUBMITTED..................0J B. NOT SUBMITTED - TO BE SERVED BY
SUPPL MENT/ AMEND BILL OF PARTICULARS TO pE SERVER BY
O 3. DEFENDANT TO PROVE . A VERI IE BILL OF PARTICULARS AS TO
AFFIRMATIVE DEFENSES WITHIN DAYS.
VI. MEDICAL AND HOSPITAL AUTHORIZATIONS TO THE EXTENT NOT PREVIOUSLY PROVIDED:
C
O L FURNISHED
HIPAA COMPLIANT
AUTHORIZATIONS
MEDICAL
TO BE
Y¼.n.Ackdft
AUTHORIZATI
SERVED BY ,
NS
/
FOR
uJt.
RECORDS
/ 20 / l/
AND HOSPITAL
PLAINTIFF(S) SHALL PROVIDE AUTHORIZATIONS TO OBTAIN COPIES OF THE ACTUAL
RECORDS OF ALL TREATING AND EXAMENING HEALTH CARE PROVIDERS, INCLUDING
D[AGNOSTIC TESTS, X-RAYS, MRIs, EMGs, CT SCANS, FOR INJURIES SPECIFIED IN THE BILL
OF PARTICULARS WITHIN l/ ( DAYS.
. PLAINTIFF(S), WITHIN 60 DAYS EFTER FIL{NG NOTE OF ISSUE, MUST SERVE DEFENDANT (S)
WITH FRESH HIPAA COMPLIANT AUTHORIZATIONS FOR ALL KNOWN HEALTH CARE
PROVIDERS.
VII. PHYSICAL EXAMINATION:
O 1A. HELD O 1B. WAIVED ..EXAM OF THE PLAINTIFF TO BE HELD WITIUN J DAYS
FOLLOWING THE CONCLUSION OF PLAINTlFF'S EBT.
PHYSICIANS'
O 2 . REPORTS FURNISHED
PHYSICIANS'
B. COPY OF REPORTS TO BE FURNISHED TO PLAINTIFF WrrHIN DAYS OF
EXAMINATION.
VIII. EXAMINATIONS BEFORE TRIAL: NINTIFF(S) haBTENDANT(S O INFANT )
o.c 60 \Ó3 AT O COURT REPORTER
AT O OFFICE OF
AT Q..K1OCATION TO BE AGREED UPON LATER
O HELD (EXCEPT:
o WAfVED
o EXCEPT fNFANT AT THIS TIME
DEPOSITIONS TO COMMENCE WITHIN 30 DAYS OF JUDICIAL DETERMINATION OF INFANT
COMPETENCE TESTIFY AT A "SWEAR-ABILITY"
PLAINTIFF'S TO HEARING.
IX. OTHER DISCLOSURE: O l. NONE P p t@ / y(
ALL PARTIES TO EXCHANGE NAMES AND ADDRESSES OF ALL
PARTIES'
WITNESSES, OPPOSING STATEMENTS,
PHOTOGRAPHS, SURVEILLANCE TAPES, AND ACCIDENT
REPORTS PREPARED IN THE ORDINARY COURSE OF
BUSINESS. IF NONE, AN AFFIRMATION TO THAT EFFECT
SHALL BE PROVIDED.
O 3. AUTHORIZATION FOR PLAINTIFF(S) FOR YEAR BEFORE, YEAR
OF, AND YEAR AFTER:
O EMPLOYMENT ATTENDANCE RECORDS
O IRS, IF SELF EMPLOYED OR W-2
dPLAINTIFF TO PROVIDE NO-FAULT/ COLLATERAL SOURCE
'
AUTHORIZATIONS. .
ABO E TO BE COMPLETED WITHIN ) DAYS.
. ALL PARTIES SHALL SUPPLY EXPERT WITNESS DISCLOSURE
PURSUANT TO CPLR.
FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021
--
INDEX# 5b Roo cr /b5 DATE Od/So
PLAINTIFFSravfon vs DEFENDANT V4 3 toa n r)
TF-13 -4 s r-nt sh 5-c.(‰ g b 16
8hay n S ‰ c_c- As o
zo c s rÂPC
ecom* wa B \ c9 ‰A¬cu9a s cxs
- yex>ich se9emse c&oa‰s cacera a uns
ecda A moo cAcc /Crha< t Mr7
- mha c ev½ms c %~fch Å 2ds nod c a an d tamseke
-lamA, creumanoa3 \taL h mAt (n&ùah le ,
voge *s .w c-uan43.ewplesvens wAn us^chws s+è-s12
/ Aef ed nks c TFB cor tw enord ba }/ est
crÇ r d99 C t c O arrCL5CS
Q a½ca e s FrAAes dar ex 4 A( u/ota4ec
w / n VS cAhw s pps+ GBT s
po ecc -e Phys 1cu
pec a c.(at;Ÿ5
ENTERED/SOORDERED
JSC
latake 001 11/07
FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021
INDEX# 50 3 0c8 --
DOt2 DATE OG†30
faer(t-|
PLAINTIFF vs DEFENDANT Dv \|
- & 9c C c \ | 9 aedc
A cr\ of aes
-A DAgchdd ‰Â H eÄ al r- e>r LAø f%2/D3/2"W5
La o ¬ûk sar
-As àÄxe aÁV‰ L x A4 m;e)
r-‰
ENTERED/SO ORDERED
JSC
Intake 001 1I/07 .
FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021
SS
PRELIMINARY CONFERENCE ORDER
X. IMPLEADER ACTIONS: o l. NONE
o 2 ALREADY COMMENCED
TO BE COMMENCED WITHIN DAYS AFTER COMPLETION
OF EBTs.
XI. ADDITIONAL DIRECTIVES: SEE ATTACHED PAGE FOR ADDITIONAL DIRECTIVES
IN THE EVENT OF UNJUSTIFIED NON-COMPLIANCE WITH THE TERMS OF THIS ORDER,
COSTS OR OTHER SANCTIONS MAY BE IMPOSED.
NOTWITHSTANDING ANY DIRECTIVE CONTAINED HEREIN, ALL PARTIES ARE
REQUIRED TO ABIDE BY THE JUSTICE'S INDIVIDUAL PART RULES LOCATED AT:
HTTP://WWW.NYCOURTS.GOV/COURTS/2JD/KINGS/CIVIL/JUDGESRULES.SHTML
ALL DATES CONTAINED HEREIN RELATING TO THE COMPLETION OF ITEMS IN THIS
PRELIMINARY CONFERENCE ORDER MUST BE ADHERED TO.
THE PARTIES HAVING APPEARED FOR A PRELIMINARY CONFERENCE ON THIS DATE HAVE
'
REVlEWED THE IV S CONDITIONS OF THIS ORDER AND HEREBY CONSENT TO SAME.
ATTORNEY: FOR PLAfNTIFF:
's signature)
(Attorney
ATTORNEY: l.udf . FOR DEFENDANT: Des , 'N/le-agema, a. a7_¼c
s signatu
(Attorney . 1 e.,
ATTORNEY: Ch signature)·
FOR DEFENDANT: \Ah CRftC Ct5 MQcÚ( û.t Gu
(Attorney's
ATTORNEY: e (3 .Ó FOR DEFENDANT:
(Attorney's
signature)
COURT ATTORNEY:
THIS CONSTITUTES THE DECISION AND ORDER OF THE COURT.
DATED: / 20 ENTER:
60 J.S.C./ JAO.
6 PU 7
Document Filed Date
September 13, 2021
Case Filing Date
December 17, 2013
Category
Medical Malpractice
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FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021 EXHIBIT B FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021 (FILED : KINGS COUNTY LERK INDEX NO. 508009/2013 07/10/2014) NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 04/10/2014 TODAY'S CAL.# RJI DATEÓ/ / INTAKE PART PRELIMINARY CONFERENCE ORDER PURSUANT TO PART 202 OF THE UNIFORM CIVIL RULES FOR THE SUPREME COURT KINGS COUNTY HON. ÙÓ Å DATE: /20 di†t Gc unE7 e B3 Index# () U ! Plaintiff(s) Compliance Conference shall be held in - against- IAS Part CCP on f 2,D , 20 at 9:30 a.m. Žffý FAILURE OF COUNSEL TO ATTEND THE COMPLIANCE CONFERENCE MAY RESULT Defendant(s) IN THE IMPOSITION OF SANCTIONS )f f ) f) D \Å/V d"d¥ /f PRINT ALL INFORMATION CLEARLY ATTORNEY FIRM L/)/VC by FOR PLAINTIFF ATTORNEY FIRM rs e)t'nhbeA by Ù . FOR DEFENDANT ATTORNEY FIRMŸ7mb c y to p by TWz FOR DEFENDANT f3 ATTORNEY FIRM by 2-, FOR DEFENDANT o . a cc LAPL C. DEFAULTS: DEFENDANT HAS NOT BEEN SERVED/ HAS BEEN SERVED, NOT ANSWERED, AND TIME TO DO SO HAS EXPIRED. DEFAULT JUDGMENT GRANTED / PENDING THE DISCOVERY END DATE/ NOTE OF ISSUE DUE DATE IS / / 20Ó_ IT IS HEREBY ORDERED THAT THIS ACTION IS ASSIGNED TO THE: EXPEDITED STANDARD PLEX TRACK AND DISCLOSURE SHALL PROCEED AS FOLLOWS: I. WRITE PLAINTTFF'S MOST SEVERE INJURY: N S vt( 2 C/ WS b / /) e u nde /t/ II. TYPE OF CASE: MOTOR VEHICLE PREMISES LIABILITY OFESSIONAL MALPRACTICE (MED. MAL. ETC.) OTHER. BRIEFLY DESCRIBE: _ CONTRACT LABOR LAW III. O CPLR 325 (D) eligible,upon furtherorder. IV. INSURANCE COVERAGE (INCLUDING EXCESS AND/ OR UMBRELLA COVERAGE) DEF NDANT DEFENDANT F NOT FURNISHED, PLAINTIFF TO BE ADVISED IN WRITING BY 20 (/ ' IF NO EXCESS COVERAGE, PROVIDE AFFIDAVIT TO THAT EFFEC BY / / 20 /ff , FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021 Y N ERENCE ORD .R dd PRELIMIN C V. BILL PARTICULARS: - S-eA c t . SUBMITTED..................0J B. NOT SUBMITTED - TO BE SERVED BY SUPPL MENT/ AMEND BILL OF PARTICULARS TO pE SERVER BY O 3. DEFENDANT TO PROVE . A VERI IE BILL OF PARTICULARS AS TO AFFIRMATIVE DEFENSES WITHIN DAYS. VI. MEDICAL AND HOSPITAL AUTHORIZATIONS TO THE EXTENT NOT PREVIOUSLY PROVIDED: C O L FURNISHED HIPAA COMPLIANT AUTHORIZATIONS MEDICAL TO BE Y¼.n.Ackdft AUTHORIZATI SERVED BY , NS / FOR uJt. RECORDS / 20 / l/ AND HOSPITAL PLAINTIFF(S) SHALL PROVIDE AUTHORIZATIONS TO OBTAIN COPIES OF THE ACTUAL RECORDS OF ALL TREATING AND EXAMENING HEALTH CARE PROVIDERS, INCLUDING D[AGNOSTIC TESTS, X-RAYS, MRIs, EMGs, CT SCANS, FOR INJURIES SPECIFIED IN THE BILL OF PARTICULARS WITHIN l/ ( DAYS. . PLAINTIFF(S), WITHIN 60 DAYS EFTER FIL{NG NOTE OF ISSUE, MUST SERVE DEFENDANT (S) WITH FRESH HIPAA COMPLIANT AUTHORIZATIONS FOR ALL KNOWN HEALTH CARE PROVIDERS. VII. PHYSICAL EXAMINATION: O 1A. HELD O 1B. WAIVED ..EXAM OF THE PLAINTIFF TO BE HELD WITIUN J DAYS FOLLOWING THE CONCLUSION OF PLAINTlFF'S EBT. PHYSICIANS' O 2 . REPORTS FURNISHED PHYSICIANS' B. COPY OF REPORTS TO BE FURNISHED TO PLAINTIFF WrrHIN DAYS OF EXAMINATION. VIII. EXAMINATIONS BEFORE TRIAL: NINTIFF(S) haBTENDANT(S O INFANT ) o.c 60 \Ó3 AT O COURT REPORTER AT O OFFICE OF AT Q..K1OCATION TO BE AGREED UPON LATER O HELD (EXCEPT: o WAfVED o EXCEPT fNFANT AT THIS TIME DEPOSITIONS TO COMMENCE WITHIN 30 DAYS OF JUDICIAL DETERMINATION OF INFANT COMPETENCE TESTIFY AT A "SWEAR-ABILITY" PLAINTIFF'S TO HEARING. IX. OTHER DISCLOSURE: O l. NONE P p t@ / y( ALL PARTIES TO EXCHANGE NAMES AND ADDRESSES OF ALL PARTIES' WITNESSES, OPPOSING STATEMENTS, PHOTOGRAPHS, SURVEILLANCE TAPES, AND ACCIDENT REPORTS PREPARED IN THE ORDINARY COURSE OF BUSINESS. IF NONE, AN AFFIRMATION TO THAT EFFECT SHALL BE PROVIDED. O 3. AUTHORIZATION FOR PLAINTIFF(S) FOR YEAR BEFORE, YEAR OF, AND YEAR AFTER: O EMPLOYMENT ATTENDANCE RECORDS O IRS, IF SELF EMPLOYED OR W-2 dPLAINTIFF TO PROVIDE NO-FAULT/ COLLATERAL SOURCE ' AUTHORIZATIONS. . ABO E TO BE COMPLETED WITHIN ) DAYS. . ALL PARTIES SHALL SUPPLY EXPERT WITNESS DISCLOSURE PURSUANT TO CPLR. FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021 -- INDEX# 5b Roo cr /b5 DATE Od/So PLAINTIFFSravfon vs DEFENDANT V4 3 toa n r) TF-13 -4 s r-nt sh 5-c.(‰ g b 16 8hay n S ‰ c_c- As o zo c s rÂPC ecom* wa B \ c9 ‰A¬cu9a s cxs - yex>ich se9emse c&oa‰s cacera a uns ecda A moo cAcc /Crha< t Mr7 - mha c ev½ms c %~fch Å 2ds nod c a an d tamseke -lamA, creumanoa3 \taL h mAt (n&ùah le , voge *s .w c-uan43.ewplesvens wAn us^chws s+è-s12 / Aef ed nks c TFB cor tw enord ba }/ est crÇ r d99 C t c O arrCL5CS Q a½ca e s FrAAes dar ex 4 A( u/ota4ec w / n VS cAhw s pps+ GBT s po ecc -e Phys 1cu pec a c.(at;Ÿ5 ENTERED/SOORDERED JSC latake 001 11/07 FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021 INDEX# 50 3 0c8 -- DOt2 DATE OG†30 faer(t-| PLAINTIFF vs DEFENDANT Dv \| - & 9c C c \ | 9 aedc A cr\ of aes -A DAgchdd ‰Â H eÄ al r- e>r LAø f%2/D3/2"W5 La o ¬ûk sar -As àÄxe aÁV‰ L x A4 m;e) r-‰ ENTERED/SO ORDERED JSC Intake 001 1I/07 . FILED: KINGS COUNTY CLERK 09/13/2021 04:32 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 09/13/2021 SS PRELIMINARY CONFERENCE ORDER X. IMPLEADER ACTIONS: o l. NONE o 2 ALREADY COMMENCED TO BE COMMENCED WITHIN DAYS AFTER COMPLETION OF EBTs. XI. ADDITIONAL DIRECTIVES: SEE ATTACHED PAGE FOR ADDITIONAL DIRECTIVES IN THE EVENT OF UNJUSTIFIED NON-COMPLIANCE WITH THE TERMS OF THIS ORDER, COSTS OR OTHER SANCTIONS MAY BE IMPOSED. NOTWITHSTANDING ANY DIRECTIVE CONTAINED HEREIN, ALL PARTIES ARE REQUIRED TO ABIDE BY THE JUSTICE'S INDIVIDUAL PART RULES LOCATED AT: HTTP://WWW.NYCOURTS.GOV/COURTS/2JD/KINGS/CIVIL/JUDGESRULES.SHTML ALL DATES CONTAINED HEREIN RELATING TO THE COMPLETION OF ITEMS IN THIS PRELIMINARY CONFERENCE ORDER MUST BE ADHERED TO. THE PARTIES HAVING APPEARED FOR A PRELIMINARY CONFERENCE ON THIS DATE HAVE ' REVlEWED THE IV S CONDITIONS OF THIS ORDER AND HEREBY CONSENT TO SAME. ATTORNEY: FOR PLAfNTIFF: 's signature) (Attorney ATTORNEY: l.udf . FOR DEFENDANT: Des , 'N/le-agema, a. a7_¼c s signatu (Attorney . 1 e., ATTORNEY: Ch signature)· FOR DEFENDANT: \Ah CRftC Ct5 MQcÚ( û.t Gu (Attorney's ATTORNEY: e (3 .Ó FOR DEFENDANT: (Attorney's signature) COURT ATTORNEY: THIS CONSTITUTES THE DECISION AND ORDER OF THE COURT. DATED: / 20 ENTER: 60 J.S.C./ JAO. 6 PU 7