On January 06, 2016 a
Party Discovery
was filed
involving a dispute between
Glenis Espinal,
Mariam Rodriguez,
and
Christopher Bynoe,
Ryder Truck Rental,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 11/07/2022 05:32 PM INDEX NO. 88/2016
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 11/07/2022
McCARTHY & ASSOCIATES
Attorneys at Law
ONE HUNTINGTON QUADRANGLE
SUITE 2C18
MELVILLE, NEW YORK 11747-4412
JAMES P. McCARTHY TELEPHONE
PATRICK J. MORALE (631) 756-2024
JOHN A. CANTON -----------
MARIANNE ARCIERI
MICHAEL D. KERN
EDWIN A. OSSA
November 7, 2022
LIAKAS LAW, P.C.
65 Broadway, Suite1101
New York, NY 10006
RE: Espinal, Glenis v. Ryder Truck Rental, et. al.
Our File No.: 15-00655354
Index No.: 88/16
Dear Counselors:
Pursuant to CPLR 3122-a, the Defendant intends to offer at trial the plaintiff’s certified
medical records from First Aid Medical/Joy PT/Corona Chiropractic Health Service located at
100-05 Roosevelt Avenue, Ste. 202, Corona, New York. The defendant plans to admit these
records into evidence SUBJECT TO REDACTION, RERSERVING ALL RIGHTS TO
REDACT ANY/ALL HEARSAY MATERIAL OR MATERIAL OTHERWISE
INADMISSIBLE.
Defendant is also serving a subpoena for the certified medical records for this facility
directing that the certified records be provided to the subpoenaed records room of the Supreme
Court, Kings County.
Very truly yours,
PATRICK J. MORALE
pmorale@hanover.com
PJM/ds
Not a Partnership - Staff Counsel, The Hanover Insurance Company/Citizens Insurance Company of America
1 of 1
Document Filed Date
November 07, 2022
Case Filing Date
January 06, 2016
Category
Torts - Motor Vehicle
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FILED: KINGS COUNTY CLERK 11/07/2022 05:32 PM INDEX NO. 88/2016 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 11/07/2022 McCARTHY & ASSOCIATES Attorneys at Law ONE HUNTINGTON QUADRANGLE SUITE 2C18 MELVILLE, NEW YORK 11747-4412 JAMES P. McCARTHY TELEPHONE PATRICK J. MORALE (631) 756-2024 JOHN A. CANTON ----------- MARIANNE ARCIERI MICHAEL D. KERN EDWIN A. OSSA November 7, 2022 LIAKAS LAW, P.C. 65 Broadway, Suite1101 New York, NY 10006 RE: Espinal, Glenis v. Ryder Truck Rental, et. al. Our File No.: 15-00655354 Index No.: 88/16 Dear Counselors: Pursuant to CPLR 3122-a, the Defendant intends to offer at trial the plaintiff’s certified medical records from First Aid Medical/Joy PT/Corona Chiropractic Health Service located at 100-05 Roosevelt Avenue, Ste. 202, Corona, New York. The defendant plans to admit these records into evidence SUBJECT TO REDACTION, RERSERVING ALL RIGHTS TO REDACT ANY/ALL HEARSAY MATERIAL OR MATERIAL OTHERWISE INADMISSIBLE. Defendant is also serving a subpoena for the certified medical records for this facility directing that the certified records be provided to the subpoenaed records room of the Supreme Court, Kings County. Very truly yours, PATRICK J. MORALE pmorale@hanover.com PJM/ds Not a Partnership - Staff Counsel, The Hanover Insurance Company/Citizens Insurance Company of America 1 of 1