On November 22, 2018 a
Party Discovery
was filed
involving a dispute between
Derek Robinson,
Theresa Robinson,
and
Deepak Nanda M.D.,
Deepak Nanda, M.D., P.C.,
Emmanuel M. Pafos M.D.,
Long Island Jewish Medical Center,
Northwell Health, Inc.,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 03/20/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
THERESA ROBINSON and DEREK ROBINSON,
Index #: 717964/2018
Plaintiff,
NOTICE FOR
-against- EXAMINATION
BEFORE TRIAL
NORTHWELL HEALTH, INC., LONG ISLAND JEWISH
MEDICAL CENTER, DEEPAK NANDA, M.D., P.C. and
DEEPAK NANDA, M.D.,
Defendants
=-------_____------=----=--------===------
PLEASE TAKE NOTICE that pursuant to Article 31 of the CPLR, the testimony .
of plaintiffs, THERESA ROB1NSON and DEREK ROBINSON, will be taken before a
public, or another person authorized to administer oaths under the laws of the State
notary
of New York at a date, time and place to be agreed upon.
That the matters upon which such person or persons are to be examined are
all the relevant facts and circumstances in connection with the accident alleged in the
complaint herein, including negligence, liability and damages.
PLEASE TAKE FURTHER NOTICE that the parties to be examined
must produce upon said examination and allrecords, memoranda and data in their
any
1 of 2
FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 03/20/2019
possession relating to the matters upon which the examinnfion is sought herein, or read or
reviewed by the deponents prior to their deposition.
Dated: White Plains, New York
March 20, 2019
Yours, etc.,
BROWN, GAUJEAN, KRAUS & SASTOW,
PLLC
By: ette M. Portera
Attor for Defendant
DEEPAK NANDA M.D. P.C. s/h/a
DEEPAK NANDA, M.D., P.C.
One North Broadway Suite 1010
White Plains, New York 10601
(914) 949-5300
TO: Munawar & Andrews-Santillo, LLP
Attorneys for Plaintiffs
420 Lexington Avenue - Suite 2601
New York, New York 10170
212- 400-4000
Law Offices of Benvenuto & Slattery
Attorneys for Defendants
Long Island Jewish Medical Center
& Northwell Health, Inc.
1800 Northern Boulevard
Roslyn, New York 11576
516-775-2236
2 of 2
Document Filed Date
March 20, 2019
Case Filing Date
November 22, 2018
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 03/20/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS THERESA ROBINSON and DEREK ROBINSON, Index #: 717964/2018 Plaintiff, NOTICE FOR -against- EXAMINATION BEFORE TRIAL NORTHWELL HEALTH, INC., LONG ISLAND JEWISH MEDICAL CENTER, DEEPAK NANDA, M.D., P.C. and DEEPAK NANDA, M.D., Defendants =-------_____------=----=--------===------ PLEASE TAKE NOTICE that pursuant to Article 31 of the CPLR, the testimony . of plaintiffs, THERESA ROB1NSON and DEREK ROBINSON, will be taken before a public, or another person authorized to administer oaths under the laws of the State notary of New York at a date, time and place to be agreed upon. That the matters upon which such person or persons are to be examined are all the relevant facts and circumstances in connection with the accident alleged in the complaint herein, including negligence, liability and damages. PLEASE TAKE FURTHER NOTICE that the parties to be examined must produce upon said examination and allrecords, memoranda and data in their any 1 of 2 FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 03/20/2019 possession relating to the matters upon which the examinnfion is sought herein, or read or reviewed by the deponents prior to their deposition. Dated: White Plains, New York March 20, 2019 Yours, etc., BROWN, GAUJEAN, KRAUS & SASTOW, PLLC By: ette M. Portera Attor for Defendant DEEPAK NANDA M.D. P.C. s/h/a DEEPAK NANDA, M.D., P.C. One North Broadway Suite 1010 White Plains, New York 10601 (914) 949-5300 TO: Munawar & Andrews-Santillo, LLP Attorneys for Plaintiffs 420 Lexington Avenue - Suite 2601 New York, New York 10170 212- 400-4000 Law Offices of Benvenuto & Slattery Attorneys for Defendants Long Island Jewish Medical Center & Northwell Health, Inc. 1800 Northern Boulevard Roslyn, New York 11576 516-775-2236 2 of 2