On April 09, 2021 a
Party Discovery
was filed
involving a dispute between
Robert P Clark As Administrator Of The Estate Of,
Robert P Clark
As Administrator Of The Estate Of,
Sharon M Clark Deceased,
Sharon M Clark
Deceased,
and
Autumn View Health Care Facility,
Autumn View Health Care Facility, Llc,
Buffalo General Medical Center,
Kaleida Health,
The Mcguire Group, Inc.,
Vestra Spv2, Llc,
Vestra Spvl, Llc,
for Torts - Other Negligence (Nursing Home)
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 05/18/2021 03:24 PM INDEX NO. 804695/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 05/18/2021
STATE OF NEW YORK
SUPREME COURT :: COUNTY OF ERIE
____________________________________________
ROBERT P. CLARK, as Administrator NOTICE FOR
of the Estate of SHARON M. CLARK, EXAMINATION BEFORE
TRIAL
Plaintiff,
vs. Index No.: 804695/2021
AUTUMN VIEW HEALTH CARE FACILITY,
AUTUMN VIEW HEALTH CARE FACILITY, LLC,
THE MCGUIRE GROUP, INC.,
VESTRA SPV1, LLC,
VESTRA SPV2, LLC,
BUFFALO GENERAL MEDICAL CENTER,
KALEIDA HEALTH,
Defendants.
____________________________________________
PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and Rules
the testimony of ROBERT P. CLARK will be taken before a notary public, or another person
authorized to administer oaths under the laws of the state of New York, on a date to be
determined by all parties at 10:00 o’clock in the forenoon of that day at Main Place Tower, 350
Main Street, Suite 1105, Buffalo, New York 14220.
That the matters upon which such person or persons are to be examined are all the relevant
facts and circumstances in connection with the accident alleged in the complaint herein, including
negligence, liability and damages.
PLEASE TAKE FURTHER NOTICE that the parties to be examined are requested to
produce upon said examination any and all records, memoranda and data in their possession
relating to the matters upon which the examination is sought herein for the purpose of refreshing
the witness’s recollection.
DATED: Buffalo, New York
May 17, 2021 BARGNESI BRITT PLLC
By:___________________________
Julie M. Bargnesi, Esq.
Attorneys for Defendants
Autumn View Health Care Facility,
Autumn View Health Care Facility, LLC,
The McGuire Group, Inc.,
VESTRA SPV1, LLC and
VESTRA SPV2, LLC
Main Place Tower
350 Main Street, Suite 1105
Buffalo, New York 14220
(716) 343-7830
1 of 2
FILED: ERIE COUNTY CLERK 05/18/2021 03:24 PM INDEX NO. 804695/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 05/18/2021
TO: JOHN J. FROMEN, ATTORNEYS AT LAW, P.C.
Michael A. Iacono, Esq.
Attorneys for Plaintiff
4367 Harlem Road
Snyder, New York 14226
(716) 855-1222
v.1
2 of 2 2
Document Filed Date
May 18, 2021
Case Filing Date
April 09, 2021
Category
Torts - Other Negligence (Nursing Home)
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Preview
FILED: ERIE COUNTY CLERK 05/18/2021 03:24 PM INDEX NO. 804695/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 05/18/2021 STATE OF NEW YORK SUPREME COURT :: COUNTY OF ERIE ____________________________________________ ROBERT P. CLARK, as Administrator NOTICE FOR of the Estate of SHARON M. CLARK, EXAMINATION BEFORE TRIAL Plaintiff, vs. Index No.: 804695/2021 AUTUMN VIEW HEALTH CARE FACILITY, AUTUMN VIEW HEALTH CARE FACILITY, LLC, THE MCGUIRE GROUP, INC., VESTRA SPV1, LLC, VESTRA SPV2, LLC, BUFFALO GENERAL MEDICAL CENTER, KALEIDA HEALTH, Defendants. ____________________________________________ PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and Rules the testimony of ROBERT P. CLARK will be taken before a notary public, or another person authorized to administer oaths under the laws of the state of New York, on a date to be determined by all parties at 10:00 o’clock in the forenoon of that day at Main Place Tower, 350 Main Street, Suite 1105, Buffalo, New York 14220. That the matters upon which such person or persons are to be examined are all the relevant facts and circumstances in connection with the accident alleged in the complaint herein, including negligence, liability and damages. PLEASE TAKE FURTHER NOTICE that the parties to be examined are requested to produce upon said examination any and all records, memoranda and data in their possession relating to the matters upon which the examination is sought herein for the purpose of refreshing the witness’s recollection. DATED: Buffalo, New York May 17, 2021 BARGNESI BRITT PLLC By:___________________________ Julie M. Bargnesi, Esq. Attorneys for Defendants Autumn View Health Care Facility, Autumn View Health Care Facility, LLC, The McGuire Group, Inc., VESTRA SPV1, LLC and VESTRA SPV2, LLC Main Place Tower 350 Main Street, Suite 1105 Buffalo, New York 14220 (716) 343-7830 1 of 2 FILED: ERIE COUNTY CLERK 05/18/2021 03:24 PM INDEX NO. 804695/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 05/18/2021 TO: JOHN J. FROMEN, ATTORNEYS AT LAW, P.C. Michael A. Iacono, Esq. Attorneys for Plaintiff 4367 Harlem Road Snyder, New York 14226 (716) 855-1222 v.1 2 of 2 2