On August 11, 2020 a
Party Discovery
was filed
involving a dispute between
Barbara Sackaroff,
and
Advanced Spine On Park Avenue Mso, Llc,
Fifth Avenue Surgery Center, Llc,
Igor Amigud M.D.,
Igor Amigud Physician P.C.,
Jande Weeks Crna,
Manhattan Spine And Pain Management, Pllc,
Sudhir Diwan M.D.,
Sudhir Diwan, Md Llc,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 09/11/2020 02:02 PM INDEX NO. 514577/2020
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 09/11/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------------X
BARBARA SACKAROFF, Index No.: 514577/2020
Plaintiff, NOTICE TO TAKE
DEPOSITION UPON
ORAL EXAMINATION
-against-
SUDHIR DIWWAN, M.D., SUDHIR DIWAN. MD LLC,
ADVANCED SPIINE ON PARK AVENUE MSO, LLC,
MANHATTAN SPINE AND PAIN MANAGEMENT, PLLC,
IGOR AMIGUD, M.D., JANDE WEEKS, CRNA,
IGOR AMIGUD PHYSICAN P.C. and
FIFTH AVENUE SURGERY CENTER, LLC
Defendants.
-------------------------------------------------------------------------X
COUNSELORS:
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and
Rules, the testimony, upon oral examination of PLAINTIFF, CO-DEFENDANTS AND ALL
ADVERSE PARTIES, 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 120
Broadway ~ 14 Floor, New York, New York, within thirty (30) days of this notice 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 Complaint.
6688575
1 of 2
FILED: KINGS COUNTY CLERK 09/11/2020 02:02 PM INDEX NO. 514577/2020
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 09/11/2020
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: New York, New York
September 11, 2020
Yours, etc.,
KAUFMAN BORGEEST & RYAN LLP
Rocco P. Matra
By:_______________________________
Rocco P. Matra
Attorneys for Defendants
SUDHIR DIWWAN, M.D. and SUDHIR
DIWAN. MD LLC
120 Broadway – 14th Floor
New York, New York 10271
Tel. No.: (212) 980–9600
Fax No.: (212) 980-9291
KBR File No.: 703.911
TO: THE SLEVIN LAW FIRM, PLLC
Attorneys for Plaintiff
3956 Merrick Road
Seaford, New York 11783
(516) 992-0805
2
6688575
2 of 2
Document Filed Date
September 11, 2020
Case Filing Date
August 11, 2020
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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Preview
FILED: KINGS COUNTY CLERK 09/11/2020 02:02 PM INDEX NO. 514577/2020 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 09/11/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------------X BARBARA SACKAROFF, Index No.: 514577/2020 Plaintiff, NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION -against- SUDHIR DIWWAN, M.D., SUDHIR DIWAN. MD LLC, ADVANCED SPIINE ON PARK AVENUE MSO, LLC, MANHATTAN SPINE AND PAIN MANAGEMENT, PLLC, IGOR AMIGUD, M.D., JANDE WEEKS, CRNA, IGOR AMIGUD PHYSICAN P.C. and FIFTH AVENUE SURGERY CENTER, LLC Defendants. -------------------------------------------------------------------------X COUNSELORS: PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony, upon oral examination of PLAINTIFF, CO-DEFENDANTS AND ALL ADVERSE PARTIES, 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 120 Broadway ~ 14 Floor, New York, New York, within thirty (30) days of this notice 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 Complaint. 6688575 1 of 2 FILED: KINGS COUNTY CLERK 09/11/2020 02:02 PM INDEX NO. 514577/2020 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 09/11/2020 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: New York, New York September 11, 2020 Yours, etc., KAUFMAN BORGEEST & RYAN LLP Rocco P. Matra By:_______________________________ Rocco P. Matra Attorneys for Defendants SUDHIR DIWWAN, M.D. and SUDHIR DIWAN. MD LLC 120 Broadway – 14th Floor New York, New York 10271 Tel. No.: (212) 980–9600 Fax No.: (212) 980-9291 KBR File No.: 703.911 TO: THE SLEVIN LAW FIRM, PLLC Attorneys for Plaintiff 3956 Merrick Road Seaford, New York 11783 (516) 992-0805 2 6688575 2 of 2