Party Notice: Jose L. Perez v. Alan K. Kaypour, Koresh Alan Kaypour As Executor Of The Estate Of Nina Kaypour

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                                FILED:         NASSAU        COUNTY         CLERK        11/03/2022             02:35       PM                      INDEX    NO.   601520/2019
   NYSCEF     DOC.   NO.   32                                                                                 RECEIVED      NYSCEF:     11/03/2022




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF NASSAU
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                  JOSE L. PEREZ,                                                           Index No.:    601520/2019

                                                               Plaintiff,                 NOTICE FOR DISCOVERY
                                                                                          AND INSPECTION
                  -against-

                  KORESH ALAN KAYPOUR, as Executor of the
                  Estate of NINA KAYPOUR              and ALAN K. KAPOUR,

                                                               Defendants,
                  -------------------------------------------------------------------X
                  TO:      Plaintiff,


                           PLEASE TAKE NOTICE, that pursuant to CPLR 3101 et seq. and the applicable case law, you

                  are hereby required to produce for discovery and supply to the undersigned attorneys within thirty (30)

                  days from the date of service of this demand, the following information, documents and items requested

                  for the purpose of inspection and/or copying:

                           PLEASE TAKE FURTHER NOTICE, that submission to the undersigned of true and

                  conformed certified copies of the documents and/or items demanded herein on or before the aforesaid

                  return date will be deemed compliance with this demand notice.

                           Kindly provide original, duly executed HIPAA compliant authorizations for plaintiff’s records

                  from the following providers:

                  1.       Northwell Health, North Shore Manhasset Hospital:               ER records, per plaintiff’s
                           deposition testimony.
                  2.       Dr. Checo, Central Orthopedic Group;
                  3.       Stand Up MRI, all films;
                  4.       North Shore 3T MRI, Great Neck, films for brain MRI;
                  5.       NYSI Imaging Center, all films;
                  6.       Neurologoical Specialties of Long Island, Dr. Haimovic, neurologist;
                  7.       Operative reports for “Carpal Tunnel Release” of December 2018 and January 2019 and
                           records of physician who performed these surgeries;
                  8.       NYSI, Dr. DeMoura;
                  9.       NYSI, Dr.     Venturo, regarding treatment for hand pain; and
                  10.      Dr. Johnston (Florida) regarding treatment for hand pain.




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   FILED:         NASSAU        COUNTY         CLERK        11/03/2022             02:35       PM                      INDEX    NO.   601520/2019
   NYSCEF     DOC.   NO.   32                                                                                 RECEIVED      NYSCEF:     11/03/2022




                           PLEASE TAKE FURTHER NOTICE that in the event any of the requested documents and/or

                  items do not exist, a verified statement to that effect is to be served on the undersigned on or before the

                  aforesaid return date.

                           PLEASE TAKE FURTHER NOTICE that this is a continuing demand notice and in the event

                  any of the requested documents and/or items are obtained after the aforesaid return date, same are to be

                  furnished to the undersigned within thirty (30) days after receipt.

                           PLEASE TAKE FURTHER NOTICE that upon the failure to produce the requested documents

                  and/or items on the date and at the time and place demanded, a Motion will be made for the appropriate

                  relief.

                  Dated:   November 3, 2022
                           Melville, New York
                                                                        Yours, etc.
                                                                        LAW OFFICES OF ERIC D. FELDMAN

                                                                        ____________________________
                                                                        LORRAINE H. SPARAGO
                                                                        Attorney for Defendants
                                                                        ALAN K. KAYPOUR and NINA KAYPOUR
                                                                        Mailing Address:1
                                                                        P.O. Box 2903
                                                                        Hartford, CT 06104-2903
                                                                        (631) 501-3007 Direct
                                                                        Matter No.: 2019058285 LHS


                  TO:
                  SILBERSTEIN AWAD MIKLOS, P.C.
                  Attorneys for Plaintiff
                  600 Old Country Road
                  Garden City, New York 11530
                  (516) 832-7777




                  1
                   OFFICE ADDRESS:    2 Corporate Center Drive Suite 300 Melville NY 11747


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