Preview
FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022
August 2, 2022
LITCHFIELD CAVO LLP
420 Lexington Avenue, Suite 2104
New York, New York 10170
Attn: Andrew Sapon, Esq.
Re: N.S. and S.S., infants under the age of 14 years, by their Father and Natural
Guardian IRAKLI SHARADZE v. G.M.D. PROPERTIES, INC. and LAMI
REALTY LLC
Index No.: 515167/2021
Dear Counselor:
In response to your letter dated July 27, 2022, please see our responses below:
1. With respect to your demands dated December 7, 2021, Plaintiff(s) has provided their Bill
of Particulars and Reply to Defendant(s)’ Demand for Discovery and Inspection on March
22, 2022;
2. With respect to your letter dated April 1, 2022 and May 16, 2022, enclosed, please find the
following documents:
a. Plaintiff(s)’ Amended and Supplemental Bill of Particulars
b. Plaintiff(s)’ Supplemental Reply to Defendant(s)’ Demand for Discovery and
Inspection as well as the corresponding records for such
3. With respect to your letter dated June 23, 2022, see response to number 2 above.
4. With respect to the Case Scheduling Order dated April 27, 2022:
a. Paragraph 3a, damages: See enclosed Amended and Supplemental Bill of
Particulars;
b. Paragraph 4a, medical authorizations: See enclosed Supplemental Reply to
Defendant(s)’ Demand for Discovery and Inspection;
c. Paragraph 4f, collateral source: Plaintiff(s) already provided authorizations for
United Healthcare.
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d. Paragraph 4g, school records: See enclosed Supplemental Reply to Defendant(s)’
Demand for Discovery and Inspection;
e. Paragraph 7a, discovery demand: See response to number 2 above.
Please note that the e-filed version of the documents will be redacted and an unredacted version is
mailed out on the same day. If you have any questions, please feel free to contact my office. Thank
you for your cooperation.
Very Truly Yours,
LESCH & LESCH, P.C.
_______________________
DAVID P. LESCH, ESQ.
DPL/ml
Enc.
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FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------------------------------------X
N.S. and S.S., infants under the age of 14 years, by their
Father and Natural Guardian IRAKLI SHARADZE,
AMENDED AND
SUPPLEMENTAL BILL OF
PARTICULARS
Plaintiff(s), Index No.: 515167/2021
-against-
G.M.D. PROPERTIES, INC. and LAMI REALTY LLC,
Defendant(s).
------------------------------------------------------------------------------------------X
Plaintiff(s), N.S. and S.S., infants under the age of 14 years, by their Father and Natural
Guardian IRAKLI SHARADZE, by their attorneys, LESCH & LESCH, P.C hereby Amends
and Supplements Plaintiff(s)’ Verified Bill of Particulars dated March 22, 2022, as follows:
1. Plaintiff(s) amends paragraph 6g of Plaintiff(s)’ Verified Bill of Particulars
removing the Blood Lead Level of 8.9 µg/dl on January 25, 2021 of infant Plaintiff(s), S.S., in
that the blood lead level result was for their mother Nato Shavishvili and was inadvertently
included in the infant Plaintiff(s), S.S.’ injuries.
2. Plaintiff(s) supplements Paragraph 5 to indicate that actual notice was given to
both Defendant(s), G.M.D. PROPERTIES, INC. and LAMI REALTY LLC on numerous
occasions. With respect to the specific individuals as to whom the notices were given to,
Plaintiff(s)’ counsel does not have that information at this time however, Plaintiff(s) repeats and
reiterates their response in that such information is in possession of the Defendant(s).
3. Plaintiff(s) supplements Paragraph 6 to add that as a result of the infant
Plaintiff(s)’ exposure to lead, infant Plaintiff(s) sustained the following additional injuries:
a. Plaintiff(s), N.S.: exacerbation of asthma and upper respiratory infection;
b. Plaintiff(s), S.S.: exacerbation of upper respiratory infection;
Plaintiff(s) reserves the right to amend and/or supplement this portion of the Bill of
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Particulars until discovery is completed.
4. Plaintiff(s)’ supplements Paragraph 9 of the Plaintiff(s) Verified Bill of
Particulars regarding special damages to state that upon information and belief, Plaintiff(s)
incurred the following amounts at BioReference Laboratories Inc.:
a. Plaintiff(s) S.S.: $1,523.8
b. Plaintiff(s) N.S.: $1,223.8
Plaintiff(s) reserves the right to amend and/or supplement this portion of the Bill of
Particulars until discovery is completed.
5. Plaintiff(s)’ supplements Paragraph 13 of Plaintiff(s)’ Verified Bill of Particulars
to state that Plaintiff(s) were seen by Dr. Michael Hanan, M.D. located at 2401 Avenue X, 1st
Floor, Brooklyn, New York 11235.
Dated: Bronx, New York
August 2, 2022
Yours, etc.
LESCH & LESCH, P.C.
By: ____________________________
DAVID P. LESCH, ESQ.
Attorneys for Plaintiff(s)
860 Grand Concourse, Suite 2M
Bronx, New York 10451
(718) 292-1131
TO:
LITCHFIELD CAVO LLP
By: Andrew Sapon, Esq.
Attorneys for Defendant(s)
LAMI REALTY LLC
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
sapon@litchfieldcavo.com
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------------------------------------X
N.S. and S.S., infants under the age of 14 years, by their
Father and Natural Guardian IRAKLI SHARADZE, SUPPLEMENTAL REPLY
TO DEFENDANT(S)’
DEMAND FOR DISCOVERY
Plaintiff(s), AND INSPECTION
Index No.: 515167/2021
-against-
G.M.D. PROPERTIES, INC. and LAMI REALTY LLC,
Defendant(s).
------------------------------------------------------------------------------------------X
Plaintiff(s), N.S. and S.S., infants under the age of 14 years, by their Father and Natural
Guardian IRAKLI SHARADZE, by their attorneys, LESCH & LESCH, P.C., hereby
supplements Plaintiff(s)’ Response to Defendant(s) Demands for Discovery and inspection as
follows:
1. Demand for School Records: Upon information and belief, infant Plaintiff(s)
attended the following schools:
a. BAMBI-III DAY CARE CENTER; 2114 Brown Street, Brooklyn, NY 11229;
b. P.S. 193 GIL HODGES; 2515 Avenue L, Brooklyn, NY 11210;
Served simultaneously with this reply are authorizations for the abovementioned
schools.
2. Demand for Photographs: Plaintiff(s) is not in possession of any photographs.
3. Demand Pursuant to 3101 (d):
a. Dr. Michael Hanan, M.D., Pediatrician associated with Michael Hanan
Medical PC;
The aforesaid expert is duly licensed to practice Medicine within the State of New
York and will testify that the injuries sustained by Plaintiff(s) as a result of the lead exposure
that occurred on or about August 01, 2014, until the present are permanent in nature and
duration. The physician will rely on his physical examination of the Plaintiff(s) and on the
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medical records of the aforementioned institutions. His testimony can be found in the
reports/records attached hereto, including history, diagnosis, prognosis, and treatment.
Plaintiff(s) reserves the right to amend and/or supplement this portion of the reply
until discovery is completed.
Dated: Bronx, New York
August 2, 2022
Yours, etc.
LESCH & LESCH, P.C.
By: ____________________________
DAVID P. LESCH, ESQ.
Attorneys for Plaintiff(s)
860 Grand Concourse, Suite 2M
Bronx, New York 10451
(718) 292-1131
TO:
LITCHFIELD CAVO LLP
By: Andrew Sapon, Esq.
Attorneys for Defendant(s)
LAMI REALTY LLC
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
sapon@litchfieldcavo.com
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NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------------------------------------x
N.S. and S.S., infants under the age of 14 years, by their
Father and Natural Guardian IRAKLI SHARADZE,
AFFIDAVIT OF SERVICE
Index No.: 515167/2021
Plaintiff(s),
-against-
G.M.D. PROPERTIES, INC. and LAMI REALTY LLC,
Defendant(s).
------------------------------------------------------------------------------------------x
STATE OF NEW YORK }
ss.:
COUNTY OF BRONX }
I, EILEEN ACEVEDO, being sworn, say:
I am not a party to the action, am over 18 years of age and reside at Bronx, New York.
On August 2, 2022, I served the within AMENDED AND SUPPLEMENTAL BILL OF
PARTICULARS AND SUPPLEMENTAL REPLY TO DEFENDANT(S)’ DEMAND
FOR DISCOVERY AND INSPECTION, by depositing a true copy thereof enclosed in a
post-paid wrapper, return receipt requested, in an official depository under the exclusive care
and custody of the U.S. Postal Service within New York State, addressed to each of the
following persons at the last known address set forth after each name:
TO: LITCHFIELD CAVO LLP
420 Lexington Avenue, Suite 2104
New York, New York 10170
___________________
EILEEN ACEVEDO
Sworn to before me this
2nd day of August 2022
__________________________
NOTARYPUBLIC
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NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
N.S. and S.S., infants under the age of 14 years, by their
Father and Natural Guardian IRAKLI SHARADZE,
Index No.: 515167/2021
Plaintiff(s),
-against-
G.M.D. PROPERTIES, INC. and LAMI REALTY LLC,
Defendant(s).
AMENDED AND SUPPLEMENTAL BILL OF PARTICULARS AND
SUPPLEMENTAL REPLY TO DEFENDANT(S)’ DEMAND FOR DISCOVERY AND
INSPECTION
LESCH & LESCH, P.C.
Attorneys for Plaintiff(s)
Office & P.O. Address
860 Grand Concourse, Suite 2M
Bronx, New York 10451
(718) 292-1131
TO: LITCHFIELD CAVO LLP
8 of 36
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DocuSign EnvelopeID: AEFE0882-7E4A-4766-AE07-8BB21EFDF3DC
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022
. OCA Official
Form No.:960
AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA
[This form has been approved by the New York StateDepartment ofHealth]
PatientName Date ofBirth SocialSecurityNumber
S 2014
PatientAddress
BROOKLYN, NEW YORK 11230
I,or my authorized request
representative, thathealth informationregarding my careand treatmentbe releasedas set forth
on thisform:
In accordancewith New York StateLaw and the PrivacyRule of the HealthInsurancePortabilityand AccountabilityAct of1996
(HIPAA), I understandthat:
1. This authorization may include disclosureof information relatingto ALCOHOL and DRUG ABUSE, MENTAL HEALTH
except and CONFIDENTIAL HIV* RELATED INFORMATION ifI place initials
on
TREATMENT, psychotherapy notes, only my
the appropriatelineinItem 9(a). In theevent thehealth informanon described below includes any ofthese typesof information,and I
initial
theline on the boxinItem 9(a),I specifically
authorizereleaseofsuch informanon to the person(s)
indicatedinItem 8.
2. IfI am authorizingthe releaseof HIV-related,alcohol or drug treatment,or mental healthtreatment information,the recipientis
prohibited from redisclosing such information without my authorizationunless permitted to do so under federalor statelaw. I
understand thatI havethe righttorequesta list
of people who may receiveor use my HIV-related informationwithout authorization.If
I experiencediscriminationbecause of thereleaseor disclosureofHIV-related informanon, I may contact the New York StateDivision
of Human Rights at(212) 480-2493 or the New York City Commission of Human Rights at(212) 306-7450. These agencies are
responsibleforprotectingmy rights.
3. I have therightto revoke thisauthorization
at anytime by writing tothe healthcareprovider listed
below. I understand thatI may
revoke thisauthorization
except to the
extent thatactionhas alreadybeen taken based on this
authorization.
4. I understand that signingthis authorizationis voluntary.My treatment,payment, enrollment in a healthplan, or for
eligibility
benefitswillnot be condinoned upon my authorizanonof thisdisclosure.
5. Information disclosedunder this authorizationmight be redisclosedby the recipient(except as noted above in Item 2),and this
redisclosure
may no longerbe protectedby federalor state law.
6. THIS AUTHORIZATION DOES NOT AUTHORIZE YOU TO DISCUSS MY HEALTH INFORMATION OR MEDICAL
CARE WITH ANYONE OTHER THAN THE ATTORNEY OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9 (b).
7. Name and address ofhealth provideror entity
to releasethisinformation:
MICHAEL HANAN MEDICAL PC; 2401 Avenue X, 1st Floor, Brooklyn, New York 1125
8. Name and address ofperson(s)or categoryofperson to whom thisinformanon will be sent:
LITCHFIELD CAVO LLP; 420 Lexington Avenue, Suite 2104, New York, New York 10170
9(a).Specificinformation to be released:
Medical Record from (insertdate) August 1 2014 to (insert
date) present
O Entire Medical Record, includingpatient office
histories, notes(except psychotherapy test
notes), results,
radiologystudies,films,
referrals,
consults, records,
billing insurance records,and recordssent to youby otherhealthcare providers.
M Other: diagnostic mporls Include:(Indicateby Initialing)
including
Alcohol/Drug Treatment
Mental Health Information
Authorization toDiscuss Health Information HIV-Related Information
(b)O By here
initialing I authorize
Initials Name of individual
health care provider
to discussmy healthinformation with my attorney,or a governmentalagency, listed
here:
(Attorney/Firm
Name or GovernmentalAgency Name)
10. Reason for releaseofinformation: 11.Date or event on which thisauthorizanon willexpire:
O At request ofindividual
El Other: Litigation Purposes Upon Completion of Litigation
12. Ifnot the patient,
name of personsigning form: 13. Authoritytosign on behalfof panent:
IRAKLI SHARADZE FATHER OF S
All itemson this GreMSS IRye my questionsabout thisformhave been answered. In I have
addition, been provided a
copy of the form.
Date: 7.28.2022
Signature ofpa ent or y law.
* Human Virus thatcauses AIDS.The New York Health
State Public Law protectsinformationwhich could
Immunodeficiency reasonably
someone as having
identify HIV symptoms or infection
and informationregarding a person's
contacts.
9 of 36
FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021
DocuSign EnvelopeID: AEFE0882-7E4A-4766-AE07-8BB21EFDF3DC
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022
. OCA Official
Form No.:960
AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA
[This form has been approved by the New York StateDepartment ofHealth]
PatientName Date ofBirth SocialSecurityNumber
PatientAddress
, BROOKLYN, NEW YORK 11230
I,or my authorized request
representative, thathealth informationregarding my careand treatmentbe releasedas set forth
on thisform:
In accordancewith New York StateLaw and the PrivacyRule of the HealthInsurancePortabilityand AccountabilityAct of1996
(HIPAA), I understandthat:
1. This authorization may include disclosureof information relatingto ALCOHOL and DRUG ABUSE, MENTAL HEALTH
except and CONFIDENTIAL HIV* RELATED INFORMATION ifI place initials
on
TREATMENT, psychotherapy notes, only my
the appropriatelineinItem 9(a). In theevent thehealth informanon described below includes any ofthese typesof information,and I
initial
theline on the boxinItem 9(a),I specifically
authorizereleaseofsuch informanon to the person(s)
indicatedinItem 8.
2. IfI am authorizingthe releaseof HIV-related,alcohol or drug treatment,or mental healthtreatment information,the recipientis
prohibited from redisclosing such information without my authorizationunless permitted to do so under federalor statelaw. I
understand thatI havethe righttorequesta list
of people who may receiveor use my HIV-related informationwithout authorization.If
I experiencediscriminationbecause of thereleaseor disclosureofHIV-related informanon, I may contact the New York StateDivision
of Human Rights at(212) 480-2493 or the New York City Commission of Human Rights at(212) 306-7450. These agencies are
responsibleforprotectingmy rights.
3. I have therightto revoke thisauthorization
at anytime by writing tothe healthcareprovider listed
below. I understand thatI may
revoke thisauthorization
except to the
extent thatactionhas alreadybeen taken based on this
authorization.
4. I understand that signingthis authorizationis voluntary.My treatment,payment, enrollment in a healthplan, or for
eligibility
benefitswillnot be condinoned upon my authorizanonof thisdisclosure.
5. Information disclosedunder this authorizationmight be redisclosedby the recipient(except as noted above in Item 2),and this
redisclosure
may no longerbe protectedby federalor state law.
6. THIS AUTHORIZATION DOES NOT AUTHORIZE YOU TO DISCUSS MY HEALTH INFORMATION OR MEDICAL
CARE WITH ANYONE OTHER THAN THE ATTORNEY OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9 (b).
7. Name and address ofhealth provideror entity
to releasethisinformation:
MICHAEL HANAN MEDICAL PC; 2401 Avenue X, 1st Floor, Brooklyn, New York 1125
8. Name and address ofperson(s)or categoryofperson to whom thisinformanon will be sent:
LITCHFIELD CAVO LLP; 420 Lexington Avenue, Suite 2104, New York, New York 10170
9(a).Specificinformation to be released:
Medical Record from (insertdate) August 1 2014 to (insert
date) present
O Entire Medical Record, includingpatient office
histories, notes(except psychotherapy test
notes), results,
radiologystudies,films,
referrals,
consults, records,
billing insurance records,and recordssent to youby otherhealthcare providers.
M Other: diagnostic mporls Include:(Indicateby Initialing)
including
Alcohol/Drug Treatment
Mental Health Information
Authorization toDiscuss Health Information HIV-Related Information
(b)O By here
initialing I authorize
Initials Name of individual
health care provider
to discussmy healthinformation with my attorney,or a governmentalagency, listed
here:
(Attorney/Firm
Name or GovernmentalAgency Name)
10. Reason for releaseofinformation: 11.Date or event on which thisauthorizanon willexpire:
O At request ofindividual
El Other: Litigation Purposes Upon Completion of Litigation
12. Ifnot the patient,
name of personsigning form: 13. Authoritytosign on behalfof panent:
IRAKLI SHARADZE FATHER OF I S
All itemson this GreMSS IRye my questionsabout thisformhave been answered. In I have
addition, been provided a
copy of the form.
Date: 7.28.2022
Signature ofpa ent or y law.
* Human Virus thatcauses AIDS.The New York Health
State Public Law protectsinformationwhich could
Immunodeficiency reasonably
someone as having
identify HIV symptoms or infection
and informationregarding a person's
contacts.
10 of 36
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NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022
AUTHORIZATION FOR SCHOOL RECORDS
TO: P.S. 193 Gil Hodges
2515 Avenue L
Brooklyn, NY 11210
THIS AUTHORIZATION IS LIMITED TO OBTAINING SCHOOL RECORDS ONLY.
IT EXPRESSLY PROHIBITS ANY CONVERSATION AND/OR DISCUSSION
You are hereby authorized to furnish to:
LITCHFIELD CAVO LLP
Andrew Sapon, Esq.
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
a complete copy of any records in your possession, custody or control pertaining to the education,
attendance and medical history pertaining to my son, Plaintiff(s) S S who was
injured in an occurrence on August 1, 2014 until the present.
Dated: Bronx, New York
August 1, 2022
IRAKLI SHARADZE
STATE OF NEW YORK }
SS.:
COUNTY OF BRONX }
On the 1st day of August 2022, before me personally came and appeared IRAKLI SHARADZE
to me known and known to me to be the individual described herein and who executed the
foregoing instrument, and who duly acknowledged to me the execution of same.
_________________________________
NOTARY PUBLIC
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AUTHORIZATION FOR SCHOOL RECORDS
TO: P.S. 193 Gil Hodges
2515 Avenue L
Brooklyn, NY 11210
THIS AUTHORIZATION IS LIMITED TO OBTAINING SCHOOL RECORDS ONLY.
IT EXPRESSLY PROHIBITS ANY CONVERSATION AND/OR DISCUSSION
You are hereby authorized to furnish to:
LITCHFIELD CAVO LLP
Andrew Sapon, Esq.
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
a complete copy of any records in your possession, custody or control pertaining to the education,
attendance and medical history pertaining to my son, Plaintiff(s) N S who was
injured in an occurrence on August 1, 2014 until the present.
Dated: Bronx, New York
August 1, 2022
IRAKLI SHARADZE
STATE OF NEW YORK }
SS.:
COUNTY OF BRONX }
On the 1st day of August 2022, before me personally came and appeared IRAKLI SHARADZE
to me known and known to me to be the individual described herein and who executed the
foregoing instrument, and who duly acknowledged to me the execution of same.
_________________________________
NOTARY PUBLIC
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AUTHORIZATION FOR SCHOOL RECORDS
TO: BAMBI-III DAY CARE CENTER
2114 Brown Street
Brooklyn, NY 11229
THIS AUTHORIZATION IS LIMITED TO OBTAINING SCHOOL RECORDS ONLY.
IT EXPRESSLY PROHIBITS ANY CONVERSATION AND/OR DISCUSSION
You are hereby authorized to furnish to:
LITCHFIELD CAVO LLP
Andrew Sapon, Esq.
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
a complete copy of any records in your possession, custody or control pertaining to the education,
attendance and medical history pertaining to my son, Plaintiff(s) S S who was
injured in an occurrence on August 1, 2014 until the present.
Dated: Bronx, New York
August 1, 2022
IRAKLI SHARADZE
STATE OF NEW YORK }
SS.:
COUNTY OF BRONX }
On the 1st day of August 2022, before me personally came and appeared IRAKLI SHARADZE
to me known and known to me to be the individual described herein and who executed the
foregoing instrument, and who duly acknowledged to me the execution of same.
_________________________________
NOTARY PUBLIC
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AUTHORIZATION FOR SCHOOL RECORDS
TO: BAMBI-III DAY CARE CENTER
2114 Brown Street
Brooklyn, NY 11229
THIS AUTHORIZATION IS LIMITED TO OBTAINING SCHOOL RECORDS ONLY.
IT EXPRESSLY PROHIBITS ANY CONVERSATION AND/OR DISCUSSION
You are hereby authorized to furnish to:
LITCHFIELD CAVO LLP
Andrew Sapon, Esq.
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
a complete copy of any records in your possession, custody or control pertaining to the education,
attendance and medical history pertaining to my son, Plaintiff(s) N S who was
injured in an occurrence on August 1, 2014 until the present.
Dated: Bronx, New York
August 1, 2022
IRAKLI SHARADZE
STATE OF NEW YORK }
SS.:
COUNTY OF BRONX }
On the 1st day of August 2022, before me personally came and appeared IRAKLI SHARADZE
to me known and known to me to be the individual described herein and who executed the
foregoing instrument, and who duly acknowledged to me the execution of same.
_________________________________
NOTARY PUBLIC
Preview
FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 August 2, 2022 LITCHFIELD CAVO LLP 420 Lexington Avenue, Suite 2104 New York, New York 10170 Attn: Andrew Sapon, Esq. Re: N.S. and S.S., infants under the age of 14 years, by their Father and Natural Guardian IRAKLI SHARADZE v. G.M.D. PROPERTIES, INC. and LAMI REALTY LLC Index No.: 515167/2021 Dear Counselor: In response to your letter dated July 27, 2022, please see our responses below: 1. With respect to your demands dated December 7, 2021, Plaintiff(s) has provided their Bill of Particulars and Reply to Defendant(s)’ Demand for Discovery and Inspection on March 22, 2022; 2. With respect to your letter dated April 1, 2022 and May 16, 2022, enclosed, please find the following documents: a. Plaintiff(s)’ Amended and Supplemental Bill of Particulars b. Plaintiff(s)’ Supplemental Reply to Defendant(s)’ Demand for Discovery and Inspection as well as the corresponding records for such 3. With respect to your letter dated June 23, 2022, see response to number 2 above. 4. With respect to the Case Scheduling Order dated April 27, 2022: a. Paragraph 3a, damages: See enclosed Amended and Supplemental Bill of Particulars; b. Paragraph 4a, medical authorizations: See enclosed Supplemental Reply to Defendant(s)’ Demand for Discovery and Inspection; c. Paragraph 4f, collateral source: Plaintiff(s) already provided authorizations for United Healthcare. 1 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 d. Paragraph 4g, school records: See enclosed Supplemental Reply to Defendant(s)’ Demand for Discovery and Inspection; e. Paragraph 7a, discovery demand: See response to number 2 above. Please note that the e-filed version of the documents will be redacted and an unredacted version is mailed out on the same day. If you have any questions, please feel free to contact my office. Thank you for your cooperation. Very Truly Yours, LESCH & LESCH, P.C. _______________________ DAVID P. LESCH, ESQ. DPL/ml Enc. 2 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------------------------------------------------------------X N.S. and S.S., infants under the age of 14 years, by their Father and Natural Guardian IRAKLI SHARADZE, AMENDED AND SUPPLEMENTAL BILL OF PARTICULARS Plaintiff(s), Index No.: 515167/2021 -against- G.M.D. PROPERTIES, INC. and LAMI REALTY LLC, Defendant(s). ------------------------------------------------------------------------------------------X Plaintiff(s), N.S. and S.S., infants under the age of 14 years, by their Father and Natural Guardian IRAKLI SHARADZE, by their attorneys, LESCH & LESCH, P.C hereby Amends and Supplements Plaintiff(s)’ Verified Bill of Particulars dated March 22, 2022, as follows: 1. Plaintiff(s) amends paragraph 6g of Plaintiff(s)’ Verified Bill of Particulars removing the Blood Lead Level of 8.9 µg/dl on January 25, 2021 of infant Plaintiff(s), S.S., in that the blood lead level result was for their mother Nato Shavishvili and was inadvertently included in the infant Plaintiff(s), S.S.’ injuries. 2. Plaintiff(s) supplements Paragraph 5 to indicate that actual notice was given to both Defendant(s), G.M.D. PROPERTIES, INC. and LAMI REALTY LLC on numerous occasions. With respect to the specific individuals as to whom the notices were given to, Plaintiff(s)’ counsel does not have that information at this time however, Plaintiff(s) repeats and reiterates their response in that such information is in possession of the Defendant(s). 3. Plaintiff(s) supplements Paragraph 6 to add that as a result of the infant Plaintiff(s)’ exposure to lead, infant Plaintiff(s) sustained the following additional injuries: a. Plaintiff(s), N.S.: exacerbation of asthma and upper respiratory infection; b. Plaintiff(s), S.S.: exacerbation of upper respiratory infection; Plaintiff(s) reserves the right to amend and/or supplement this portion of the Bill of 3 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 Particulars until discovery is completed. 4. Plaintiff(s)’ supplements Paragraph 9 of the Plaintiff(s) Verified Bill of Particulars regarding special damages to state that upon information and belief, Plaintiff(s) incurred the following amounts at BioReference Laboratories Inc.: a. Plaintiff(s) S.S.: $1,523.8 b. Plaintiff(s) N.S.: $1,223.8 Plaintiff(s) reserves the right to amend and/or supplement this portion of the Bill of Particulars until discovery is completed. 5. Plaintiff(s)’ supplements Paragraph 13 of Plaintiff(s)’ Verified Bill of Particulars to state that Plaintiff(s) were seen by Dr. Michael Hanan, M.D. located at 2401 Avenue X, 1st Floor, Brooklyn, New York 11235. Dated: Bronx, New York August 2, 2022 Yours, etc. LESCH & LESCH, P.C. By: ____________________________ DAVID P. LESCH, ESQ. Attorneys for Plaintiff(s) 860 Grand Concourse, Suite 2M Bronx, New York 10451 (718) 292-1131 TO: LITCHFIELD CAVO LLP By: Andrew Sapon, Esq. Attorneys for Defendant(s) LAMI REALTY LLC 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 sapon@litchfieldcavo.com 4 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------------------------------------------------------------X N.S. and S.S., infants under the age of 14 years, by their Father and Natural Guardian IRAKLI SHARADZE, SUPPLEMENTAL REPLY TO DEFENDANT(S)’ DEMAND FOR DISCOVERY Plaintiff(s), AND INSPECTION Index No.: 515167/2021 -against- G.M.D. PROPERTIES, INC. and LAMI REALTY LLC, Defendant(s). ------------------------------------------------------------------------------------------X Plaintiff(s), N.S. and S.S., infants under the age of 14 years, by their Father and Natural Guardian IRAKLI SHARADZE, by their attorneys, LESCH & LESCH, P.C., hereby supplements Plaintiff(s)’ Response to Defendant(s) Demands for Discovery and inspection as follows: 1. Demand for School Records: Upon information and belief, infant Plaintiff(s) attended the following schools: a. BAMBI-III DAY CARE CENTER; 2114 Brown Street, Brooklyn, NY 11229; b. P.S. 193 GIL HODGES; 2515 Avenue L, Brooklyn, NY 11210; Served simultaneously with this reply are authorizations for the abovementioned schools. 2. Demand for Photographs: Plaintiff(s) is not in possession of any photographs. 3. Demand Pursuant to 3101 (d): a. Dr. Michael Hanan, M.D., Pediatrician associated with Michael Hanan Medical PC; The aforesaid expert is duly licensed to practice Medicine within the State of New York and will testify that the injuries sustained by Plaintiff(s) as a result of the lead exposure that occurred on or about August 01, 2014, until the present are permanent in nature and duration. The physician will rely on his physical examination of the Plaintiff(s) and on the 5 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 medical records of the aforementioned institutions. His testimony can be found in the reports/records attached hereto, including history, diagnosis, prognosis, and treatment. Plaintiff(s) reserves the right to amend and/or supplement this portion of the reply until discovery is completed. Dated: Bronx, New York August 2, 2022 Yours, etc. LESCH & LESCH, P.C. By: ____________________________ DAVID P. LESCH, ESQ. Attorneys for Plaintiff(s) 860 Grand Concourse, Suite 2M Bronx, New York 10451 (718) 292-1131 TO: LITCHFIELD CAVO LLP By: Andrew Sapon, Esq. Attorneys for Defendant(s) LAMI REALTY LLC 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 sapon@litchfieldcavo.com 6 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------------------------------------------------------------x N.S. and S.S., infants under the age of 14 years, by their Father and Natural Guardian IRAKLI SHARADZE, AFFIDAVIT OF SERVICE Index No.: 515167/2021 Plaintiff(s), -against- G.M.D. PROPERTIES, INC. and LAMI REALTY LLC, Defendant(s). ------------------------------------------------------------------------------------------x STATE OF NEW YORK } ss.: COUNTY OF BRONX } I, EILEEN ACEVEDO, being sworn, say: I am not a party to the action, am over 18 years of age and reside at Bronx, New York. On August 2, 2022, I served the within AMENDED AND SUPPLEMENTAL BILL OF PARTICULARS AND SUPPLEMENTAL REPLY TO DEFENDANT(S)’ DEMAND FOR DISCOVERY AND INSPECTION, by depositing a true copy thereof enclosed in a post-paid wrapper, return receipt requested, in an official depository under the exclusive care and custody of the U.S. Postal Service within New York State, addressed to each of the following persons at the last known address set forth after each name: TO: LITCHFIELD CAVO LLP 420 Lexington Avenue, Suite 2104 New York, New York 10170 ___________________ EILEEN ACEVEDO Sworn to before me this 2nd day of August 2022 __________________________ NOTARYPUBLIC 7 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS N.S. and S.S., infants under the age of 14 years, by their Father and Natural Guardian IRAKLI SHARADZE, Index No.: 515167/2021 Plaintiff(s), -against- G.M.D. PROPERTIES, INC. and LAMI REALTY LLC, Defendant(s). AMENDED AND SUPPLEMENTAL BILL OF PARTICULARS AND SUPPLEMENTAL REPLY TO DEFENDANT(S)’ DEMAND FOR DISCOVERY AND INSPECTION LESCH & LESCH, P.C. Attorneys for Plaintiff(s) Office & P.O. Address 860 Grand Concourse, Suite 2M Bronx, New York 10451 (718) 292-1131 TO: LITCHFIELD CAVO LLP 8 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 DocuSign EnvelopeID: AEFE0882-7E4A-4766-AE07-8BB21EFDF3DC NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 . OCA Official Form No.:960 AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA [This form has been approved by the New York StateDepartment ofHealth] PatientName Date ofBirth SocialSecurityNumber S 2014 PatientAddress BROOKLYN, NEW YORK 11230 I,or my authorized request representative, thathealth informationregarding my careand treatmentbe releasedas set forth on thisform: In accordancewith New York StateLaw and the PrivacyRule of the HealthInsurancePortabilityand AccountabilityAct of1996 (HIPAA), I understandthat: 1. This authorization may include disclosureof information relatingto ALCOHOL and DRUG ABUSE, MENTAL HEALTH except and CONFIDENTIAL HIV* RELATED INFORMATION ifI place initials on TREATMENT, psychotherapy notes, only my the appropriatelineinItem 9(a). In theevent thehealth informanon described below includes any ofthese typesof information,and I initial theline on the boxinItem 9(a),I specifically authorizereleaseofsuch informanon to the person(s) indicatedinItem 8. 2. IfI am authorizingthe releaseof HIV-related,alcohol or drug treatment,or mental healthtreatment information,the recipientis prohibited from redisclosing such information without my authorizationunless permitted to do so under federalor statelaw. I understand thatI havethe righttorequesta list of people who may receiveor use my HIV-related informationwithout authorization.If I experiencediscriminationbecause of thereleaseor disclosureofHIV-related informanon, I may contact the New York StateDivision of Human Rights at(212) 480-2493 or the New York City Commission of Human Rights at(212) 306-7450. These agencies are responsibleforprotectingmy rights. 3. I have therightto revoke thisauthorization at anytime by writing tothe healthcareprovider listed below. I understand thatI may revoke thisauthorization except to the extent thatactionhas alreadybeen taken based on this authorization. 4. I understand that signingthis authorizationis voluntary.My treatment,payment, enrollment in a healthplan, or for eligibility benefitswillnot be condinoned upon my authorizanonof thisdisclosure. 5. Information disclosedunder this authorizationmight be redisclosedby the recipient(except as noted above in Item 2),and this redisclosure may no longerbe protectedby federalor state law. 6. THIS AUTHORIZATION DOES NOT AUTHORIZE YOU TO DISCUSS MY HEALTH INFORMATION OR MEDICAL CARE WITH ANYONE OTHER THAN THE ATTORNEY OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9 (b). 7. Name and address ofhealth provideror entity to releasethisinformation: MICHAEL HANAN MEDICAL PC; 2401 Avenue X, 1st Floor, Brooklyn, New York 1125 8. Name and address ofperson(s)or categoryofperson to whom thisinformanon will be sent: LITCHFIELD CAVO LLP; 420 Lexington Avenue, Suite 2104, New York, New York 10170 9(a).Specificinformation to be released: Medical Record from (insertdate) August 1 2014 to (insert date) present O Entire Medical Record, includingpatient office histories, notes(except psychotherapy test notes), results, radiologystudies,films, referrals, consults, records, billing insurance records,and recordssent to youby otherhealthcare providers. M Other: diagnostic mporls Include:(Indicateby Initialing) including Alcohol/Drug Treatment Mental Health Information Authorization toDiscuss Health Information HIV-Related Information (b)O By here initialing I authorize Initials Name of individual health care provider to discussmy healthinformation with my attorney,or a governmentalagency, listed here: (Attorney/Firm Name or GovernmentalAgency Name) 10. Reason for releaseofinformation: 11.Date or event on which thisauthorizanon willexpire: O At request ofindividual El Other: Litigation Purposes Upon Completion of Litigation 12. Ifnot the patient, name of personsigning form: 13. Authoritytosign on behalfof panent: IRAKLI SHARADZE FATHER OF S All itemson this GreMSS IRye my questionsabout thisformhave been answered. In I have addition, been provided a copy of the form. Date: 7.28.2022 Signature ofpa ent or y law. * Human Virus thatcauses AIDS.The New York Health State Public Law protectsinformationwhich could Immunodeficiency reasonably someone as having identify HIV symptoms or infection and informationregarding a person's contacts. 9 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 DocuSign EnvelopeID: AEFE0882-7E4A-4766-AE07-8BB21EFDF3DC NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 . OCA Official Form No.:960 AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA [This form has been approved by the New York StateDepartment ofHealth] PatientName Date ofBirth SocialSecurityNumber PatientAddress , BROOKLYN, NEW YORK 11230 I,or my authorized request representative, thathealth informationregarding my careand treatmentbe releasedas set forth on thisform: In accordancewith New York StateLaw and the PrivacyRule of the HealthInsurancePortabilityand AccountabilityAct of1996 (HIPAA), I understandthat: 1. This authorization may include disclosureof information relatingto ALCOHOL and DRUG ABUSE, MENTAL HEALTH except and CONFIDENTIAL HIV* RELATED INFORMATION ifI place initials on TREATMENT, psychotherapy notes, only my the appropriatelineinItem 9(a). In theevent thehealth informanon described below includes any ofthese typesof information,and I initial theline on the boxinItem 9(a),I specifically authorizereleaseofsuch informanon to the person(s) indicatedinItem 8. 2. IfI am authorizingthe releaseof HIV-related,alcohol or drug treatment,or mental healthtreatment information,the recipientis prohibited from redisclosing such information without my authorizationunless permitted to do so under federalor statelaw. I understand thatI havethe righttorequesta list of people who may receiveor use my HIV-related informationwithout authorization.If I experiencediscriminationbecause of thereleaseor disclosureofHIV-related informanon, I may contact the New York StateDivision of Human Rights at(212) 480-2493 or the New York City Commission of Human Rights at(212) 306-7450. These agencies are responsibleforprotectingmy rights. 3. I have therightto revoke thisauthorization at anytime by writing tothe healthcareprovider listed below. I understand thatI may revoke thisauthorization except to the extent thatactionhas alreadybeen taken based on this authorization. 4. I understand that signingthis authorizationis voluntary.My treatment,payment, enrollment in a healthplan, or for eligibility benefitswillnot be condinoned upon my authorizanonof thisdisclosure. 5. Information disclosedunder this authorizationmight be redisclosedby the recipient(except as noted above in Item 2),and this redisclosure may no longerbe protectedby federalor state law. 6. THIS AUTHORIZATION DOES NOT AUTHORIZE YOU TO DISCUSS MY HEALTH INFORMATION OR MEDICAL CARE WITH ANYONE OTHER THAN THE ATTORNEY OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9 (b). 7. Name and address ofhealth provideror entity to releasethisinformation: MICHAEL HANAN MEDICAL PC; 2401 Avenue X, 1st Floor, Brooklyn, New York 1125 8. Name and address ofperson(s)or categoryofperson to whom thisinformanon will be sent: LITCHFIELD CAVO LLP; 420 Lexington Avenue, Suite 2104, New York, New York 10170 9(a).Specificinformation to be released: Medical Record from (insertdate) August 1 2014 to (insert date) present O Entire Medical Record, includingpatient office histories, notes(except psychotherapy test notes), results, radiologystudies,films, referrals, consults, records, billing insurance records,and recordssent to youby otherhealthcare providers. M Other: diagnostic mporls Include:(Indicateby Initialing) including Alcohol/Drug Treatment Mental Health Information Authorization toDiscuss Health Information HIV-Related Information (b)O By here initialing I authorize Initials Name of individual health care provider to discussmy healthinformation with my attorney,or a governmentalagency, listed here: (Attorney/Firm Name or GovernmentalAgency Name) 10. Reason for releaseofinformation: 11.Date or event on which thisauthorizanon willexpire: O At request ofindividual El Other: Litigation Purposes Upon Completion of Litigation 12. Ifnot the patient, name of personsigning form: 13. Authoritytosign on behalfof panent: IRAKLI SHARADZE FATHER OF I S All itemson this GreMSS IRye my questionsabout thisformhave been answered. In I have addition, been provided a copy of the form. Date: 7.28.2022 Signature ofpa ent or y law. * Human Virus thatcauses AIDS.The New York Health State Public Law protectsinformationwhich could Immunodeficiency reasonably someone as having identify HIV symptoms or infection and informationregarding a person's contacts. 10 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 AUTHORIZATION FOR SCHOOL RECORDS TO: P.S. 193 Gil Hodges 2515 Avenue L Brooklyn, NY 11210 THIS AUTHORIZATION IS LIMITED TO OBTAINING SCHOOL RECORDS ONLY. IT EXPRESSLY PROHIBITS ANY CONVERSATION AND/OR DISCUSSION You are hereby authorized to furnish to: LITCHFIELD CAVO LLP Andrew Sapon, Esq. 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 a complete copy of any records in your possession, custody or control pertaining to the education, attendance and medical history pertaining to my son, Plaintiff(s) S S who was injured in an occurrence on August 1, 2014 until the present. Dated: Bronx, New York August 1, 2022 IRAKLI SHARADZE STATE OF NEW YORK } SS.: COUNTY OF BRONX } On the 1st day of August 2022, before me personally came and appeared IRAKLI SHARADZE to me known and known to me to be the individual described herein and who executed the foregoing instrument, and who duly acknowledged to me the execution of same. _________________________________ NOTARY PUBLIC 11 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 AUTHORIZATION FOR SCHOOL RECORDS TO: P.S. 193 Gil Hodges 2515 Avenue L Brooklyn, NY 11210 THIS AUTHORIZATION IS LIMITED TO OBTAINING SCHOOL RECORDS ONLY. IT EXPRESSLY PROHIBITS ANY CONVERSATION AND/OR DISCUSSION You are hereby authorized to furnish to: LITCHFIELD CAVO LLP Andrew Sapon, Esq. 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 a complete copy of any records in your possession, custody or control pertaining to the education, attendance and medical history pertaining to my son, Plaintiff(s) N S who was injured in an occurrence on August 1, 2014 until the present. Dated: Bronx, New York August 1, 2022 IRAKLI SHARADZE STATE OF NEW YORK } SS.: COUNTY OF BRONX } On the 1st day of August 2022, before me personally came and appeared IRAKLI SHARADZE to me known and known to me to be the individual described herein and who executed the foregoing instrument, and who duly acknowledged to me the execution of same. _________________________________ NOTARY PUBLIC 12 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 AUTHORIZATION FOR SCHOOL RECORDS TO: BAMBI-III DAY CARE CENTER 2114 Brown Street Brooklyn, NY 11229 THIS AUTHORIZATION IS LIMITED TO OBTAINING SCHOOL RECORDS ONLY. IT EXPRESSLY PROHIBITS ANY CONVERSATION AND/OR DISCUSSION You are hereby authorized to furnish to: LITCHFIELD CAVO LLP Andrew Sapon, Esq. 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 a complete copy of any records in your possession, custody or control pertaining to the education, attendance and medical history pertaining to my son, Plaintiff(s) S S who was injured in an occurrence on August 1, 2014 until the present. Dated: Bronx, New York August 1, 2022 IRAKLI SHARADZE STATE OF NEW YORK } SS.: COUNTY OF BRONX } On the 1st day of August 2022, before me personally came and appeared IRAKLI SHARADZE to me known and known to me to be the individual described herein and who executed the foregoing instrument, and who duly acknowledged to me the execution of same. _________________________________ NOTARY PUBLIC 13 of 36 FILED: KINGS COUNTY CLERK 08/02/2022 10:53 AM INDEX NO. 515167/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/02/2022 AUTHORIZATION FOR SCHOOL RECORDS TO: BAMBI-III DAY CARE CENTER 2114 Brown Street Brooklyn, NY 11229 THIS AUTHORIZATION IS LIMITED TO OBTAINING SCHOOL RECORDS ONLY. IT EXPRESSLY PROHIBITS ANY CONVERSATION AND/OR DISCUSSION You are hereby authorized to furnish to: LITCHFIELD CAVO LLP Andrew Sapon, Esq. 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 a complete copy of any records in your possession, custody or control pertaining to the education, attendance and medical history pertaining to my son, Plaintiff(s) N S who was injured in an occurrence on August 1, 2014 until the present. Dated: Bronx, New York August 1, 2022 IRAKLI SHARADZE STATE OF NEW YORK } SS.: COUNTY OF BRONX } On the 1st day of August 2022, before me personally came and appeared IRAKLI SHARADZE to me known and known to me to be the individual described herein and who executed the foregoing instrument, and who duly acknowledged to me the execution of same. _________________________________ NOTARY PUBLIC