On January 16, 2019 a
No Value
was filed
involving a dispute between
Carmen Romero,
and
And The New York City Department Of Education,
Consolidated Edison Company Of New York, Inc.,
Consolidated Edison, Inc.,
The City Of New York,
The New York City Department Of Transportation,
for Torts - Other Negligence (Trip and Fall)
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 06/29/2021 04:17 PM INDEX NO. 150436/2019
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/29/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
---------------------------------------------------------------------x
CARMEN ROMERO,
DEMAND FOR MEDICAL
Plaintiff, AUTHORIZATION
-against- Index No.: 150436/2019
File No.: 2019-006431
THE CITY OF NEW YORK, THE NEW YORK CITY
DEPARTMENT OF TRANSPORTATION, THE NEW
YORK CITY DEPARTMENT OF EDUCATION,
CONSOLIDATED EDISON COMPANY OF NEW
YORK, INC. and CONSOLIDATED EDISON, INC.,
Defendants.
---------------------------------------------------------------------x
PLEASE TAKE NOTICE, that pursuant to CPLR 2305 and 3120 Defendants
THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF
TRANSPORTATION, and THE NEW YORK CITY DEPARTMENT OF EDUCATION hereby
demands that Plaintiff CARMEN ROMERO produce within twenty (20) days, the following:
1. A duly executed and acknowledged authorization, pursuant to CPLR 2305 and 3120 and
pursuant to HIPPA 164.508, permitting the City to obtain the ambulance call report from
July 25, 2018, the date of the alleged injury.
PLESAE TAKE FURTHER NOTICE, that appropriate motions will be made
to preclude the offering of said proof or introducing testimony on said proof for those items not
produced in accordance with this demand.
PLEASE TAKE FURTHER NOTICE, that this demand is a continuing demand
through the time of trial.
1
1 of 2
FILED: NEW YORK COUNTY CLERK 06/29/2021 04:17 PM INDEX NO. 150436/2019
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/29/2021
Dated: New York, New York
June 29, 2021
Hunter Digitally signed by Hunter Igoe
DN: cn=Hunter Igoe, o=Law
Department, ou=MBU,
Igoe email=higoe@law.nyc.gov, c=US
Date: 2021.06.29 16:15:22 -04'00'
________________________________
GEORGIA M. PESTANA
Acting Corporation Counsel
Attorney for the Municipal Defendant
THE CITY OF NEW YORK
100 Church Street
New York, New York 10007
By: Hunter Igoe
(212) 356-2772
higoe@law.nyc.gov
TO:
Steven Adam Rubin & Associates PLLC
Attorney for the Plaintiff
71 West 23rd Street, Suite 1623
New York, New York 10010
Nadine Rivellese
Attorney for Defendants
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
CONSOLIDATED EDISON, INC.
4 Irving Place, Room 1800
New York, New York 10003
2
2 of 2
Document Filed Date
June 29, 2021
Case Filing Date
January 16, 2019
Category
Torts - Other Negligence (Trip and Fall)
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FILED: NEW YORK COUNTY CLERK 06/29/2021 04:17 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/29/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------------------------------------x CARMEN ROMERO, DEMAND FOR MEDICAL Plaintiff, AUTHORIZATION -against- Index No.: 150436/2019 File No.: 2019-006431 THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION, THE NEW YORK CITY DEPARTMENT OF EDUCATION, CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. and CONSOLIDATED EDISON, INC., Defendants. ---------------------------------------------------------------------x PLEASE TAKE NOTICE, that pursuant to CPLR 2305 and 3120 Defendants THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION, and THE NEW YORK CITY DEPARTMENT OF EDUCATION hereby demands that Plaintiff CARMEN ROMERO produce within twenty (20) days, the following: 1. A duly executed and acknowledged authorization, pursuant to CPLR 2305 and 3120 and pursuant to HIPPA 164.508, permitting the City to obtain the ambulance call report from July 25, 2018, the date of the alleged injury. PLESAE TAKE FURTHER NOTICE, that appropriate motions will be made to preclude the offering of said proof or introducing testimony on said proof for those items not produced in accordance with this demand. PLEASE TAKE FURTHER NOTICE, that this demand is a continuing demand through the time of trial. 1 1 of 2 FILED: NEW YORK COUNTY CLERK 06/29/2021 04:17 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/29/2021 Dated: New York, New York June 29, 2021 Hunter Digitally signed by Hunter Igoe DN: cn=Hunter Igoe, o=Law Department, ou=MBU, Igoe email=higoe@law.nyc.gov, c=US Date: 2021.06.29 16:15:22 -04'00' ________________________________ GEORGIA M. PESTANA Acting Corporation Counsel Attorney for the Municipal Defendant THE CITY OF NEW YORK 100 Church Street New York, New York 10007 By: Hunter Igoe (212) 356-2772 higoe@law.nyc.gov TO: Steven Adam Rubin & Associates PLLC Attorney for the Plaintiff 71 West 23rd Street, Suite 1623 New York, New York 10010 Nadine Rivellese Attorney for Defendants CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. CONSOLIDATED EDISON, INC. 4 Irving Place, Room 1800 New York, New York 10003 2 2 of 2