On November 22, 2018 a
Motion,Ex Parte
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 06/15/2021 06:03 PM INDEX NO. 717964/2018
NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 06/15/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
---------------------------------------------------------------------x
THERESA ROBINSON and DEREK ROBINSON,
Index No.: 717964/2018
Plaintiffs,
NOTICE OF MOTION
-against-
NORTHWELL HEALTH, INC, LONG ISLAND
JEWISH MEDICAL CENTER, DEEPAK NANDA,
MD, PC, DEEPAK NANDA M.D., EMMANUEL
M. PAFOS, M.D.
Defendants.
---------------------------------------------------------------------x
PLEASE TAKE NOTICE that, upon the annexed affirmation of Anthony Xanthakis Esq.,
dated June 15, 2021, together with the exhibits annexed hereto, and upon all pleadings and
proceedings heretofore had herein, defendant, EMMANUEL M. PAFOS , MD will move this
Court located at 88-11 Sutphin Boulevard, Jamaica, New York 11501, on July 14, 2021, at 9:30
a.m., or as soon thereafter as counsel can be heard, for an Order:
(a) pursuant to CPLR § 3212, granting summary judgment in favor of the moving
defendant and dismissing plaintiffs’ complaint in its entirety on the merits, with prejudice; and
(b) directing the Clerk of the Court to enter Judgment against plaintiff and in favor of
defendant, accordingly; and
(c) for such other and further relief as this Court deems just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR Rule 2214(b), answering
papers, if any, are required to be served upon the undersigned at least seven (7) days prior to the
return date of this motion.
Dated: Staten Island, New York
June 15, 2021
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FILED: QUEENS COUNTY CLERK 06/15/2021 06:03 PM INDEX NO. 717964/2018
NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 06/15/2021
Yours, etc.,
GALVANO & XANTHAKIS, P.C.
Attorneys for Defendant
EMMANUEL M. PAFOS, M.D.
358 St. Marks Place–Suite 202
Staten Island, New York 10301
(212) 349-5150
Anthony Xanthakis
By: ANTHONY XANTHAKIS
TO: THE PAGLINAWAN FIRM, P.C.
Counsel for Plaintiffs
THERESA ROBINSON and
DEREK ROBINSON
118-21 Queens Blvd., Ste.501
Forest Hills, NY 11375
(718)576-2544
AARONSON RAPPAPORT FEINSTEIN & DEUTSCH, LLP
Attorneys for Defendants
Northwell Health, Inc. and
Long Island Jewish Medical Center
600 Third Avenue
New York, New York 10016
RUBIN PATERNITI GONZALEZ RIZZO KAUFMAN LLP
Attorneys for Defendants
DEEPAK NANDA,MD, PC, DEEPAK NANDA, MD
555 Fifth Avenue, 6th Floor
New York, New York 10017
(646) 809-3370
2 of 2
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FILED: QUEENS COUNTY CLERK 06/15/2021 06:03 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 06/15/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ---------------------------------------------------------------------x THERESA ROBINSON and DEREK ROBINSON, Index No.: 717964/2018 Plaintiffs, NOTICE OF MOTION -against- NORTHWELL HEALTH, INC, LONG ISLAND JEWISH MEDICAL CENTER, DEEPAK NANDA, MD, PC, DEEPAK NANDA M.D., EMMANUEL M. PAFOS, M.D. Defendants. ---------------------------------------------------------------------x PLEASE TAKE NOTICE that, upon the annexed affirmation of Anthony Xanthakis Esq., dated June 15, 2021, together with the exhibits annexed hereto, and upon all pleadings and proceedings heretofore had herein, defendant, EMMANUEL M. PAFOS , MD will move this Court located at 88-11 Sutphin Boulevard, Jamaica, New York 11501, on July 14, 2021, at 9:30 a.m., or as soon thereafter as counsel can be heard, for an Order: (a) pursuant to CPLR § 3212, granting summary judgment in favor of the moving defendant and dismissing plaintiffs’ complaint in its entirety on the merits, with prejudice; and (b) directing the Clerk of the Court to enter Judgment against plaintiff and in favor of defendant, accordingly; and (c) for such other and further relief as this Court deems just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR Rule 2214(b), answering papers, if any, are required to be served upon the undersigned at least seven (7) days prior to the return date of this motion. Dated: Staten Island, New York June 15, 2021 1 of 2 FILED: QUEENS COUNTY CLERK 06/15/2021 06:03 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 06/15/2021 Yours, etc., GALVANO & XANTHAKIS, P.C. Attorneys for Defendant EMMANUEL M. PAFOS, M.D. 358 St. Marks Place–Suite 202 Staten Island, New York 10301 (212) 349-5150 Anthony Xanthakis By: ANTHONY XANTHAKIS TO: THE PAGLINAWAN FIRM, P.C. Counsel for Plaintiffs THERESA ROBINSON and DEREK ROBINSON 118-21 Queens Blvd., Ste.501 Forest Hills, NY 11375 (718)576-2544 AARONSON RAPPAPORT FEINSTEIN & DEUTSCH, LLP Attorneys for Defendants Northwell Health, Inc. and Long Island Jewish Medical Center 600 Third Avenue New York, New York 10016 RUBIN PATERNITI GONZALEZ RIZZO KAUFMAN LLP Attorneys for Defendants DEEPAK NANDA,MD, PC, DEEPAK NANDA, MD 555 Fifth Avenue, 6th Floor New York, New York 10017 (646) 809-3370 2 of 2