On September 12, 2016 a
Exhibit,Appendix
was filed
involving a dispute between
Cheryl Kausner,
Thomas Kausner,
and
Andrew Cappuccino M.D.,
Buffalo Spine Surgery, Pllc,
Eastern Niagara Hospital, Inc.,
Eastern Niagara Radiology And Nuclear Medicine Associates Pc,
Eric Dean Rpa-C,
Harnath B. Clerk M.D.,
Harnath B. Clerk, M.D., P.C.,
Robert E. Lutnick M.D.,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Niagara County.
Preview
FILED: NIAGARA COUNTY CLERK 12/02/2020 04:49 PM INDEX NO. E159518/2016
NYSCEF DOC. NO. 162 RECEIVED NYSCEF: 12/02/2020
Exhibit G
FILED: NIAGARA COUNTY CLERK 12/02/2020 04:49 PM INDEX NO. E159518/2016
NYSCEF DOC. NO. 162 RECEIVED NYSCEF: 12/02/2020
Brian Fitzgerald
From: Brian Fitzgerald < brian@fitzgeraldroller.com >
Sent: Thursday, July 2, 2020 12:08 PM
To: 'Brian J. Weidner'
Cc: 'jvmccarthy@roachbrown.com'; 'mjr@connorsllp.com'
Subject: Kausner v. Cappuccino, et al.
Attachments: 042519 Fourth Notice to Produce to Cappuccino et al.pdf
Re: Kausner v. Cappuccino, et al.
Index No. E159518/2016
Our File No. 6646
Brian:
I attach a copy of Plaintiffs' Fourth Notice to Produce, served back in April, 2019, regarding the
plaintiffs request for flight records. Please produce these immediately.
Also, please accept this email for you to produce telephone records of both Dr. Cappuccino and
Mr. Dean which reflect calls made to or from my clients and anyone at Eastern Niagara Hospital
regarding Thomas Kausner's case. These phone records should include both Dr. Cappuccino's ce11
phone, home phone and office phone and the same with respect to Mr. Dean.
Thanks for your attention in this regard and your hoped for cooperation. Please stay safe and
well.
Brian P. Fitzgerald, Esq.
Fitzgerald & Roller, P.C.
424 Main Street
509 Liberty Building
Buffalo, New York 14202
Tel. (716) 852-2000
Fax: (716) 852-2002
Brian(@ FitzgeraldRoller.com
Document Filed Date
December 02, 2020
Case Filing Date
September 12, 2016
Category
Torts - Medical, Dental, or Podiatrist Malpractice
Status
Disposed-Court Date/Application Pending
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