No Value: Kevin Lynch as Administrator of the Estate of Rose Bouknight v. Montefiore Medical Center, Glen Island Center For Nursing And Rehabilitation And, Jopal Bronx Llc d/b/a Workmen's Circle Multicare Center

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                                FILED:         WESTCHESTER              COUNTY         CLERK       03/15/2022             12:09        PM            INDEX    NO.   64205/2020
   NYSCEF     DOC.   NO.   64                                                                                 RECEIVED      NYSCEF:     03/15/2022




                       SUPREME COURT OF THE STATE OF NEW YORK
                       COUNTY OF WESTCHESTER
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                       KEVIN LYNCH as Administrator of the Estate
                       OF ROSE BOUKNIGHT,                                                            Index # 64205/2020

                                                    Plaintiff,                                          DEFENDANT’S
                                                                                                    SECOND POST-EBT
                                      -against-                                                            DEMANDS

                       MONTEFIORE MEDICAL CENTER, GLEN ISLAND
                       CENTER FOR NURSING AND REHABILITATION
                       AND JOPAL BRONX LLC D/B/A WORKMEN’S
                       CIRCLE MULTICARE CENTER,

                                                    Defendants.
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                       C O U N S E L O R S:

                                  PLEASE        TAKE      NOTICE        that   defendant,      MONTEFIORE            MEDICAL

                       CENTER,        by   and   through     its  attorneys,     Turken,     Heath    and    McCauley,       LLP,

                       hereby    demands       that,  pursuant     to Article   31  of  the  CPLR,     plaintiff  serve   HIPAA

                       compliant      authorizations       with    section    9(a)    initialed   for   the   release     of   the

                       decedent’s medical records from the following medical providers:

                                1.       All home health care aides that provided services to the decedent.

                                2.       All visiting nurse services that provided services to the decedent.

                                3.       All  home     health   aides    identified   by   plaintiff at  his  deposition      who

                       provided care to the decedent in 2017 and/or 2018.

                                PLEASE       TAKE     FURTHER         NOTICE      that  this  is an   ongoing    demand,      and

                       that  MONTEFIORE            MEDICAL        CENTER       reserves     the   right  to  supplement       this

                       demand up to and until the time of trial.




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   FILED:         WESTCHESTER              COUNTY         CLERK       03/15/2022             12:09        PM            INDEX    NO.   64205/2020
   NYSCEF     DOC.   NO.   64                                                                                 RECEIVED      NYSCEF:     03/15/2022




                       Dated:            Armonk, NY        10504
                                         March 15, 2022

                                                                    Yours, etc.

                                                                    TURKEN, HEATH & MCCAULEY LLP

                                                                    By: /s Kyle B. Epstein
                                                                    Kyle B. Epstein, Esq.
                                                                    Attorneys for Defendant
                                                                    MONTEFIORE MEDICAL CENTER
                                                                    84 Business Park Drive
                                                                    Suite 307
                                                                    Armonk, NY        10504
                                                                    (914) 357-8600

                       TO:

                       Sinel & Olesen, PLLC
                       Attorneys to Plaintiff
                       7 Penn Plaza, 8th Floor
                       New York, New York 10001
                       (212) 465-1000

                       Gonzalo G. Suraez, Esq.
                       Kaufman Borgeest & Ryan LLP
                       Attorneys for Defendant
                       Jopal Bronx LLC d/b/a Workmen’s Circle Multicare Center
                       1205 Franklin Avenue, Suite 200
                       Garden City, NY 11530
                       (516) 248-6000

                       Nicole Atlas, Esq.
                       Sheeley LLP
                       Attorneys for Defendant
                       Glen Island Center for Nursing and Rehabilitation
                       100 Wall Street, 19th Floor
                       New York, NY 10005
                       (646) 650-5952




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