On May 24, 2017 a
Party Notice
was filed
involving a dispute between
Unitrin Advantage Insurance Company,
and
Aba Chiropractic, P.C.,
Angela Salguedo,
Apple Acupuncture, P.C.,
Auto Rx, L.C.,
Citimedical I, Pllc,
Corona Medical Plaza, P.C.,
Dwayne Corwise,
Elmont Rehab Pt, P.C.,
Ema Medical Equipment Corp.,
Fast Care Medical Diagnostics, Pllc,
Frank S. Segreto, M.D.,
Health Balance Medical, P.C.,
Satya Drug Corp. D B A Farmacia Central,
Ugp Acupuncture, P.C.,
for Torts - Other (Declaratory Judgment)
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 08/06/2018 04:31 PM INDEX NO. 154804/2017
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 08/06/2018
SUPREME COURTOF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----------------- ----------------------------- X
UNITRIN ADVANTAGE INSURANCE COMPANY,
Index No.: 154804/17
Plaintiff(s),
NOTICE FOR
-against- DISCOVERY
AND INSPECTION
ABA CHIROPRACTIC, P.C., APPLE ACUPUNCTURE, P.C.,
AUTO RX, L.C., CITIMEDICAL I, PLLC, CORONA
MEDICAL PLAZA, P.C., ELMONT REHAB PT, P.C., EMA
MEDICAL EQUIPMENT CORP., FAST CARE MEDICAL
DIAGNOSTICS, PLLC, FRANK S. SEGRETO, M.D.,
HEALTH BALANCE MEDICAL, P.C., SATYA DRUG CORP.
d/b/ a FARMACIA CENTRAL, UGP ACUPUNCTURE, P.C.,
DWAYNE CORWISE and ANGELA SALGUEDO,
Defendant(s).
_ ---..--_ _ _--- _ _ _--- _ _ _- _- _ _ _----... .------ --- ---X
S I R S:
PLEASE TAKE NOTICE, that pursuant to CPLR 3120(a), defendants, ABA
CHIROPRACTIC, P.C., APPLE ACUPUNCTURE, P.C., CORONA MEDICAL PLAZA, P.C.
and ELMONT REHAB PT, P.C., hereby requested to produce at the offices of RUBIN,
3rd
FIORELLA & FRIEDMAN LLP, 630 Third Avenue, Floor, New York, New York 10017,
6th
on the day of September, 2018 the for inspection the plaintiff(s), or its
following by
attorneys:
1. All medicalreportsregardingtreatmentrenderedtotheinjuredparty;
2. All physician referrals regarding treatment rendered to the injured
party;
3. All patient referrals treatment rendered to the injured
regarding
party;
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FILED: NEW YORK COUNTY CLERK 08/06/2018 04:31 PM INDEX NO. 154804/2017
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 08/06/2018
4. All letters of medical necessity regarding treatment rendered to the
injured party;
5. All attendance records regarding treatment rendered to the injured
party;
6. All verification of treatment forms regarding treatment rendered to
the injured party;
7. All questionnaires administered to the injured party;
8. All test manuals used in conjunction with any testing administered to
the injured party;
9. All forms given to injured party;
10. All doctors and/or treating logs and/or notes with regard to the care
rendered to the injured party;
11. All assignment of benefit forms in conjunction with this claim;
12. All fee schedules associated with treatment rendered to the injured
party;
13. All application for benefit forms associated with treatment rendered
to the injured party;
14. All bills associated for treatment rendered to the injured party;
15. All description of benefit forms associated with treatment rendered
to the injured party;
16. A list of all medical supplies and their respective costs associated with
treatment rendered to the injured party;
17. The date any and all medical supplies were issued to the injured
party;
18. All forms signed by the injured party with respect to the issuance of
medical supplies; and
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FILED: NEW YORK COUNTY CLERK 08/06/2018 04:31 PM INDEX NO. 154804/2017
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 08/06/2018
19. The dates and all sign in logs or other forms concerning
transportation given to the injured party to receive the medical
treatment alleged.
20. All employment agreements between the defendant and its alleged
treating physicians.
21. Tax forms for defendant(s) for the year that alleged services were
rendered as well as previous two years.
22. Any agreements between defendant(s) and any company.
managing
23. Any financing agreements between the defendant(s) and any
financing companies.
defendant(s)'
24. That article of incorporation and certificate of
any
incorporation.
PLEASE TAKE FURTHER NOTICE, that mailing to the undersigned attorneys of
the items requested for production at least seven (7) days prior to the aforementioned date
will be deemed sufficient compliance.
DATED: New York, New York
August 6, 2018
Yours, etc.
Harlan R. Schreiber, Esq.
RUBIN, FIORELLA & FRIEDMAN LLP
Attorneys for Plaintiff(s)
3rd
630 Third Avenue, FlOOr
New York, New York 10017
(212) 953-2381
Our FileNo.: 0575.33620
TO: FULD and KARP, P.C.
Attorneys for Defendant: ABA CHIROPRACTIC, P.C., APPLE ACUPUNCTURE,
P.C., CORONA MEDICAL PLAZA, P.C. and ELMONT REHAB PT, P.C.
1963 Coney Island Avenue
Brooklyn, New York 11223
(212) 714-0421
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FILED: NEW YORK COUNTY CLERK 08/06/2018 04:31 PM INDEX NO. 154804/2017 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 08/06/2018 SUPREME COURTOF THE STATE OF NEW YORK COUNTY OF NEW YORK ----------------- ----------------------------- X UNITRIN ADVANTAGE INSURANCE COMPANY, Index No.: 154804/17 Plaintiff(s), NOTICE FOR -against- DISCOVERY AND INSPECTION ABA CHIROPRACTIC, P.C., APPLE ACUPUNCTURE, P.C., AUTO RX, L.C., CITIMEDICAL I, PLLC, CORONA MEDICAL PLAZA, P.C., ELMONT REHAB PT, P.C., EMA MEDICAL EQUIPMENT CORP., FAST CARE MEDICAL DIAGNOSTICS, PLLC, FRANK S. SEGRETO, M.D., HEALTH BALANCE MEDICAL, P.C., SATYA DRUG CORP. d/b/ a FARMACIA CENTRAL, UGP ACUPUNCTURE, P.C., DWAYNE CORWISE and ANGELA SALGUEDO, Defendant(s). _ ---..--_ _ _--- _ _ _--- _ _ _- _- _ _ _----... .------ --- ---X S I R S: PLEASE TAKE NOTICE, that pursuant to CPLR 3120(a), defendants, ABA CHIROPRACTIC, P.C., APPLE ACUPUNCTURE, P.C., CORONA MEDICAL PLAZA, P.C. and ELMONT REHAB PT, P.C., hereby requested to produce at the offices of RUBIN, 3rd FIORELLA & FRIEDMAN LLP, 630 Third Avenue, Floor, New York, New York 10017, 6th on the day of September, 2018 the for inspection the plaintiff(s), or its following by attorneys: 1. All medicalreportsregardingtreatmentrenderedtotheinjuredparty; 2. All physician referrals regarding treatment rendered to the injured party; 3. All patient referrals treatment rendered to the injured regarding party; 1 of 3 FILED: NEW YORK COUNTY CLERK 08/06/2018 04:31 PM INDEX NO. 154804/2017 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 08/06/2018 4. All letters of medical necessity regarding treatment rendered to the injured party; 5. All attendance records regarding treatment rendered to the injured party; 6. All verification of treatment forms regarding treatment rendered to the injured party; 7. All questionnaires administered to the injured party; 8. All test manuals used in conjunction with any testing administered to the injured party; 9. All forms given to injured party; 10. All doctors and/or treating logs and/or notes with regard to the care rendered to the injured party; 11. All assignment of benefit forms in conjunction with this claim; 12. All fee schedules associated with treatment rendered to the injured party; 13. All application for benefit forms associated with treatment rendered to the injured party; 14. All bills associated for treatment rendered to the injured party; 15. All description of benefit forms associated with treatment rendered to the injured party; 16. A list of all medical supplies and their respective costs associated with treatment rendered to the injured party; 17. The date any and all medical supplies were issued to the injured party; 18. All forms signed by the injured party with respect to the issuance of medical supplies; and 2 2 of 3 FILED: NEW YORK COUNTY CLERK 08/06/2018 04:31 PM INDEX NO. 154804/2017 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 08/06/2018 19. The dates and all sign in logs or other forms concerning transportation given to the injured party to receive the medical treatment alleged. 20. All employment agreements between the defendant and its alleged treating physicians. 21. Tax forms for defendant(s) for the year that alleged services were rendered as well as previous two years. 22. Any agreements between defendant(s) and any company. managing 23. Any financing agreements between the defendant(s) and any financing companies. defendant(s)' 24. That article of incorporation and certificate of any incorporation. PLEASE TAKE FURTHER NOTICE, that mailing to the undersigned attorneys of the items requested for production at least seven (7) days prior to the aforementioned date will be deemed sufficient compliance. DATED: New York, New York August 6, 2018 Yours, etc. Harlan R. Schreiber, Esq. RUBIN, FIORELLA & FRIEDMAN LLP Attorneys for Plaintiff(s) 3rd 630 Third Avenue, FlOOr New York, New York 10017 (212) 953-2381 Our FileNo.: 0575.33620 TO: FULD and KARP, P.C. Attorneys for Defendant: ABA CHIROPRACTIC, P.C., APPLE ACUPUNCTURE, P.C., CORONA MEDICAL PLAZA, P.C. and ELMONT REHAB PT, P.C. 1963 Coney Island Avenue Brooklyn, New York 11223 (212) 714-0421 3 3 of 3