On May 24, 2017 a
DEMAND FOR:
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 01/16/2019 11:19 AM INDEX NO. 154804/2017
NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 01/16/2019
The Rybak Firm, PLLC
3rd
1810 Voorhies Avenue, Floor, Suite 7
Brooklyn, New York 11235
Telephone: 718 - 975 - 2035
Facsimile: 718 - 975 - 2037
Email: orybak@rybakfirm.com
January 10, 2019
Goldberg Miller & Rubin
HARLAN R. SCHREIBER, ESQ.
767 Third Avenue, 24th Floor
New York, New York 10017
R_e: UNITRIN ADVANTAGE INSURANCE COMPANY v. ABA CHIROPRACTIC, P.C., et al.
Index No.: 154804/17
Dear Mr. Schreiber:
This letter is regarding the outstanding combined discovery demands served on behalf of
Defendants, UGP ACUPUNCTURE, P.C., for the above-mentioned matter. Discovery demands
~
must be responded to within twenty (20) days from date of receipt of such demands. Please be
advised that to this day, we have not received a response regarding such demands, although
ample time has passed since such demands were served.
Discovery is an important aspect of this action and in order to properly adjudicate this
matter we must obtain the information requested. Pursuant to 22 NYCRR §202.7, this letter is
an attempt to resolve this matter in good faith.
Kindly provide the information reqüêsted for the above-mentioned matter within ten (10)
days from the date of this letter. We would like to resolve this matter amicably; however, a
failure to respond to this request will leave us no choice, but to seek judicial intervention and
unnecessary motion practice.
Thank you in advance for your prompt attention in this matter. Please do not hesitate to
contact me atany time.
Sinc rel ,
Ole . ybak, Esq.
1 of 1
Document Filed Date
January 16, 2019
Case Filing Date
May 24, 2017
Category
Torts - Other (Declaratory Judgment)
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FILED: NEW YORK COUNTY CLERK 01/16/2019 11:19 AM INDEX NO. 154804/2017 NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 01/16/2019 The Rybak Firm, PLLC 3rd 1810 Voorhies Avenue, Floor, Suite 7 Brooklyn, New York 11235 Telephone: 718 - 975 - 2035 Facsimile: 718 - 975 - 2037 Email: orybak@rybakfirm.com January 10, 2019 Goldberg Miller & Rubin HARLAN R. SCHREIBER, ESQ. 767 Third Avenue, 24th Floor New York, New York 10017 R_e: UNITRIN ADVANTAGE INSURANCE COMPANY v. ABA CHIROPRACTIC, P.C., et al. Index No.: 154804/17 Dear Mr. Schreiber: This letter is regarding the outstanding combined discovery demands served on behalf of Defendants, UGP ACUPUNCTURE, P.C., for the above-mentioned matter. Discovery demands ~ must be responded to within twenty (20) days from date of receipt of such demands. Please be advised that to this day, we have not received a response regarding such demands, although ample time has passed since such demands were served. Discovery is an important aspect of this action and in order to properly adjudicate this matter we must obtain the information requested. Pursuant to 22 NYCRR §202.7, this letter is an attempt to resolve this matter in good faith. Kindly provide the information reqüêsted for the above-mentioned matter within ten (10) days from the date of this letter. We would like to resolve this matter amicably; however, a failure to respond to this request will leave us no choice, but to seek judicial intervention and unnecessary motion practice. Thank you in advance for your prompt attention in this matter. Please do not hesitate to contact me atany time. Sinc rel , Ole . ybak, Esq. 1 of 1