Preview
FILED: NEW YORK COUNTY CLERK 05/12/2022 02:06 PM INDEX NO. 154863/2018
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 05/12/2022
3UPREME COURT OF THE STATE OF NEW YORK
30UNTY OF NEW YORK
.______________________________________________________________________Ç
ROBERTO RODRIGUEZ, Index No: 154863/18E
Plaintiff, STIPULATION
- against -
/ILLAGEFH, LLC and SMI CONSTRUCTION
-
VIANAGEMENT, INC.,
Defendant.
._____________________________________________________________________Ç
ILLAGEFH LLC,
Third-Party Plaintiff,
- against -
JOVIN DEMO NEW YORK, INC.,
Third-Party Defendant.
_____________________________________________________________________Ç
ILLAGEFH LLC, and SMI CONSTRUCTION
VIANAGEMENT, INC.,
Second Third-Party Plaintiffs,
- against -
)ONATO, INC. and INTERIOR ROCK, INC.
Second Third-Party Defendants.
._____________________________________________________________________Ç
T IS HEREBY STIPULATED AND AGREED:
1. Defendants to respond to plaintiff'sNovember 11, 2021 post-EBT demand on
or before June 1, 2022;
2. Plaintiff to provide a response to all outstanding discovery demands outlined in
defendants'
letter dated February 22, 2021 or before June 1, 2022;
15
3. Plaintiff within ---
30 days of this Order to provide to defendants updated
authorizations for release of allmedical records and films for treatment received
since his deposition of February 21, 2020;
15
4. Plaintiff within ---
30 days of this Order to provide authorizations for release of al
medical records and films for treatment Received from Union Family Medicine
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FILED: NEW YORK COUNTY CLERK 05/12/2022 02:06 PM INDEX NO. 154863/2018
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 05/12/2022
office of Dr. Pranay Bhatt, M.D, referable to a prior accident/injury sustained on
or about June 21, 2016;
15
5. Plaintiff within ---
30 days of this Order to provide authorization for release of all
medical records and film referable to accident/injury sustained on or about June
"clinic"
21, 2016, including, but,not necessarily limited to the referenced by Dr.
Bhatt in his treatment records;
6. Plaintiff to be produced for a further deposition before August 1, 2022;
7. Third Party Defendant to conduct further IME's of plaintiff by September 15,
2022; (designate by 8/15/22)
8. Should plaintiffundergo a further surgery after the date of this Order, plaintifftc
provide authorization for release of the related records and film within 30 days
of that procedure;
15
9. Plaintiff, within ----
30 days of this Order, to provide fresh, properly executed
authorizations to defendants for release of allWorkers Compensations records
from the States of New Jersey and New York.
15
10. Plaintiff within ---
30 days of this Order to provide authorizations allowing release
of records from Social Security Disability;
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FILED: NEW YORK COUNTY CLERK 05/12/2022 02:06 PM INDEX NO. 154863/2018
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 05/12/2022
Dated:
Port Chester, NY
oseòfrÝ
STAVROS E. SITINAS, LLC O'CONNOR REDD ORLANDO LLP
Attorney for Plaintiffs Attorne)/s for Second Third-Party Defendant
444 Madison Avenue, 4th Floor INTER OR ROCK, INC.
K·
New York, NY 10022 242 g Street|P.O. BOX 1000
(212)539-1800 . Port hester NY 10573
(91 686-1700
Michael Gleason, EsqP
RAVEN & KOLBE, LLP
Attorneys for Defendants and Third Party
Plaintiffs So Ordered
VILLAGEFH, LLC and SMI
!ONSTRUCTION MANAGEMENT, INC. 5/12/22
126 56th Street, Suite 202
New York, NY 10022
(212) 759-7466
Next conference 8/4/22
By July 28, 2022, please e-file to NYSCEF one of the following:
1.A fully executed discovery stipulation. If you timely e-file this, it will be reviewed; if the court finds it
satisfactory, then it will be so ordered and uploaded. There will be no need for you to attend the
above-scheduled conference and we will set the date for the next conference. If it is not satisfactory
(such as being a repeat of the prior conference order), then the conference may be held or adjourned, as
the Court deems appropriate.
2. A stipulation of partial agreement. Parties must stipulate to what they can agree and leave blanks for
what they cannot. Parties must then e-file a written explanation as to the disagreed portions. The Court
will either decide the issue based on your written explanations, hold the conference, or approve what you
have agreed and instruct you to make a motion as to the disputed matters.
3. A letter indicating why you cannot agree to anything and identifying the areas in dispute.
If nothing is timely e-filed, then the conference will be adjourned.
If you fail to timely e-file one of the above for three consecutive conferences, your case may be
dismissed.
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Preview
FILED: NEW YORK COUNTY CLERK 05/12/2022 02:06 PM INDEX NO. 154863/2018 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 05/12/2022 3UPREME COURT OF THE STATE OF NEW YORK 30UNTY OF NEW YORK .______________________________________________________________________Ç ROBERTO RODRIGUEZ, Index No: 154863/18E Plaintiff, STIPULATION - against - /ILLAGEFH, LLC and SMI CONSTRUCTION - VIANAGEMENT, INC., Defendant. ._____________________________________________________________________Ç ILLAGEFH LLC, Third-Party Plaintiff, - against - JOVIN DEMO NEW YORK, INC., Third-Party Defendant. _____________________________________________________________________Ç ILLAGEFH LLC, and SMI CONSTRUCTION VIANAGEMENT, INC., Second Third-Party Plaintiffs, - against - )ONATO, INC. and INTERIOR ROCK, INC. Second Third-Party Defendants. ._____________________________________________________________________Ç T IS HEREBY STIPULATED AND AGREED: 1. Defendants to respond to plaintiff'sNovember 11, 2021 post-EBT demand on or before June 1, 2022; 2. Plaintiff to provide a response to all outstanding discovery demands outlined in defendants' letter dated February 22, 2021 or before June 1, 2022; 15 3. Plaintiff within --- 30 days of this Order to provide to defendants updated authorizations for release of allmedical records and films for treatment received since his deposition of February 21, 2020; 15 4. Plaintiff within --- 30 days of this Order to provide authorizations for release of al medical records and films for treatment Received from Union Family Medicine 1 1 of 3 FILED: NEW YORK COUNTY CLERK 05/12/2022 02:06 PM INDEX NO. 154863/2018 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 05/12/2022 office of Dr. Pranay Bhatt, M.D, referable to a prior accident/injury sustained on or about June 21, 2016; 15 5. Plaintiff within --- 30 days of this Order to provide authorization for release of all medical records and film referable to accident/injury sustained on or about June "clinic" 21, 2016, including, but,not necessarily limited to the referenced by Dr. Bhatt in his treatment records; 6. Plaintiff to be produced for a further deposition before August 1, 2022; 7. Third Party Defendant to conduct further IME's of plaintiff by September 15, 2022; (designate by 8/15/22) 8. Should plaintiffundergo a further surgery after the date of this Order, plaintifftc provide authorization for release of the related records and film within 30 days of that procedure; 15 9. Plaintiff, within ---- 30 days of this Order, to provide fresh, properly executed authorizations to defendants for release of allWorkers Compensations records from the States of New Jersey and New York. 15 10. Plaintiff within --- 30 days of this Order to provide authorizations allowing release of records from Social Security Disability; 2 2 of 3 FILED: NEW YORK COUNTY CLERK 05/12/2022 02:06 PM INDEX NO. 154863/2018 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 05/12/2022 Dated: Port Chester, NY oseòfrÝ STAVROS E. SITINAS, LLC O'CONNOR REDD ORLANDO LLP Attorney for Plaintiffs Attorne)/s for Second Third-Party Defendant 444 Madison Avenue, 4th Floor INTER OR ROCK, INC. K· New York, NY 10022 242 g Street|P.O. BOX 1000 (212)539-1800 . Port hester NY 10573 (91 686-1700 Michael Gleason, EsqP RAVEN & KOLBE, LLP Attorneys for Defendants and Third Party Plaintiffs So Ordered VILLAGEFH, LLC and SMI !ONSTRUCTION MANAGEMENT, INC. 5/12/22 126 56th Street, Suite 202 New York, NY 10022 (212) 759-7466 Next conference 8/4/22 By July 28, 2022, please e-file to NYSCEF one of the following: 1.A fully executed discovery stipulation. If you timely e-file this, it will be reviewed; if the court finds it satisfactory, then it will be so ordered and uploaded. There will be no need for you to attend the above-scheduled conference and we will set the date for the next conference. If it is not satisfactory (such as being a repeat of the prior conference order), then the conference may be held or adjourned, as the Court deems appropriate. 2. A stipulation of partial agreement. Parties must stipulate to what they can agree and leave blanks for what they cannot. Parties must then e-file a written explanation as to the disagreed portions. The Court will either decide the issue based on your written explanations, hold the conference, or approve what you have agreed and instruct you to make a motion as to the disputed matters. 3. A letter indicating why you cannot agree to anything and identifying the areas in dispute. If nothing is timely e-filed, then the conference will be adjourned. If you fail to timely e-file one of the above for three consecutive conferences, your case may be dismissed. 3 3 of 3