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  • Juan M. Castillo v. Xiangyng HeTorts - Motor Vehicle document preview
  • Juan M. Castillo v. Xiangyng HeTorts - Motor Vehicle document preview
  • Juan M. Castillo v. Xiangyng HeTorts - Motor Vehicle document preview
  • Juan M. Castillo v. Xiangyng HeTorts - Motor Vehicle document preview
  • Juan M. Castillo v. Xiangyng HeTorts - Motor Vehicle document preview
  • Juan M. Castillo v. Xiangyng HeTorts - Motor Vehicle document preview
  • Juan M. Castillo v. Xiangyng HeTorts - Motor Vehicle document preview
  • Juan M. Castillo v. Xiangyng HeTorts - Motor Vehicle document preview
						
                                

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FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE -~~~---~~~-~~-~~~~~---~~~-~~~~~~----X Index No.: EF003832-2021 JUAN CASTILLO, PLAINTIFFS EXPERT Plaintiff(s), EXCHANGE PURSUANT TO C.P.L.R. 3101(d) -against- XIANGYNG HE, Defendant(s). ~~~~~-~~~~-~~~~~~~~~~~-~~ ~ ~~~~-~Ç Plaintiff, JUAN CASTILLO, by his attorneys, MAINETTI, & MAINETTI, P.C., as and for Defendant(s)' his response to demand for expert witness information, states as follows: Plaintiff expects to call as an expert witness and treating physician in the trial of the above matter Dr.YINGGANG ZHENG, with his principal place of business at Middletown Medical, P.C., 111 Maltese Drive, Middletown, NY 10940. The substance of the facts and opinions upon which the expert is expected to testify is that on December 11, 2018, the Plaintiff was involved in a motor vehicle accident and that as a result of the accident, the Plaintiff was caused to suffer: Broad-based central disc protrusion at C7-T1; Left paracentral disc protrusion at Central disc extrusion with superior migration of disc at T8- T6-T7; T9; Straightening of the normal lordotic curvature lumbar spine; Loss of range of motion of the thoracolumbar spine; Medial Branch Block Injections at T7, T8, T9 and T10 (7/18/2019; and 1/31/2020); Facet athropathy of the thoracic spine; Left rib pain; Chest pain; Right thigh pain; Inflamation of the aforementioned areas; Swelling of the aforementioned areas; Muscle spasms of the aforementioned areas; Loss of range of motion; Loss of circulation; Loss of muscle / muscle weakness; Need for physical therapy; Need for pain management treatment; Inability to perform activities of daily living unassisted; Difficulty sitting, standing, bending, and lifting; Difficulty 1 of 10 FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022 sleeping / sleep disruption; Emotional upset and shock; Lost and decreased quahty of life;and Lost enjoyment of pre-collision social endeavors, allwith an overlay of emotional distress and anguish. Dr. Zheng will further testify that the accident of December 11, 2018 was the competent producing cause of said injuries and related conditions, and that the foregoing injuries and conditions are permanent except those deemed to be superficial. Dr. Zheng will also testify consistently with his records of plaintiff's treatment and that allof the aforementioned injuries, resulting disabilities, aggravations, exacerbations and involvements are associated with further soft tissue injuries to the areas traumatically affected, including: fracture, tearing, derangement and damage to the associated muscle groups, ligaments, tendons, cartilage, blood, tissue, epithelial tissue, allconcomitant to the specific injuries and related to the specific portions of the body mentioned herein above, with resultant scars, hemorrhage, pain, ecchymosis, deformity and disability; stiffness, tenderness, weakness and partial restriction and limitation of motion, pain on motion and loss of use of the abovementioned parts; atrophy, anxiety and mental anguish; all of which have substantially prevented the Plaintiff from the normal fruits of social and activities. The expert enjoying family will further testify that allof the injuries and conditions caused and/or contributed to the Plaintiff living a lesser quality of life,including loss of enjoyment of lifethan the Plaintiff would otherwise have experienced, but for the injuries and conditions alleged herein and that the Plaintiff suffered, stillsuffers, and upon information and belief will continue to permanently suffer pain, discomfort and limited movement of the injured portions of body, including the adjacent and surrounding muscles, tendons, nerves, joints, fascia, vessels and soft tissues. The Plaintiff reserves the right to prove any and all further consequences and any and all further medical expenses up to and including the time of trial. The qualifications of this expert are that he is Board Certified in the area of Physical Medicine and Rehabilitation, licensed to practice medicine in the State of New York, has maintained 2 of 10 FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022 an active practice in for a number of years, and is a graduate of an accredited medical college. A copy his CurriculumVitae is attached and incorporated into this exchange. The grounds for his opinions and the admission of same are all ofthe discovery in the instant case, his medical and experience and his knowledge and familiarity with applicable training medical texts, and information statedin his reports,histestings and his examinations and treatment of the Plaintiff. The expert will further rely upon his review of medical reports and records of the Plaintiff's health providers and of other evaluators who have reported on theconditions suffered by the Plaintiff as a resultofthe said incident. Finally, it is anticipated that the doctor will comment and give opinions relative to any expert exchange performed the defendant as well as comment on the findings and testimony by offered by defendants fact witness(es) and/or expert witness(es). Dated: Kingston, New York September 27, 2022 Yours etc., jISSEPH M. P GLIESE, ESQ. MAINETTI 82 MAINETTI, P.C. Attorneys for Plaintiff(s) 130 N. Front Street Kingston, New York 12401 (845) 600-0000 To: Law Office of Bryan R. Kaplan Attorneys for Defendant(s) PO Box 1000 Rock Hill, NY 12775 3 of 10 FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022 THIS PAGE WAS INTENTIONALLY LEFT BLANK 4 of 10 FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 9/27/22,12:49 PM https://www.nydoctorprofile.com/NYPublic/dispatch NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022 Physician 4 Back sarch to a-uit. 0-7 cm Selectitems to print wmm sten OfficeLocations: Yinggang Zheng Goshen, NY NYS License Number: 252239 Date of NYS Licensure: 03-06-2009 updated 01-06-2022 Profilelast by physician: National Provider ID: 1346471786 "Education " Practice Info " Legal Actions " Professional Activities " Statement SchooP Grgduate Medica{ Education "Board Certifications nal Niembe¾ships Medical School To Top QINGDAO MEDICAL COLLEGE, QINGDAO, SHANDONG, CHINA, 1982 Note: This information cannot be used by healthcare organizations to meet their credentialing requirements as set forth by accrediting bodies such as the Joint Commission or National Committee for Quality Assurance (NCQA). Graduate Medical EducatioI $ TO TOP Completion Sponsor Start Date Completed Specialty NEW YORK PHYSICAL MEDICAL 07-01-2006 06-30-2009 Yes MEDICINE AND COLLEGE REHABILITATION SUNY HEALTH SCIENCE CENTER 07-01-2005 06-30-2006 Yes GENERAL SURGERY AT BROOKLYN Note: This information cannot be used by healthcare organizations to meet their credentialing requirements as set forth by accrediting bodies such as the Joint Commission or National Committee for Quality Assurance (NCQA). Board Certifications D TO TOP Name of Board Certification Date Expiration Date *AM BRD OF PHYSICAL MEDICINE AND 07-01-2010 REHABILITATION *AM BRD OF PHYSICAL MEDICINE AND 01-01-2021 REHABILITATION 1. Note: The state of New York recognizes the specialty boards that are members or components of the ABMS, AOA or RCPSC. Certification by member boards or components of these umbrella organizations is the responsibility of the member organization. https://www.nydoctorprofile.com/NYPublic/dispatch 1/2 5 of 10 FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 9/27/22,12:49PM https://www.nydoctorprofile.com/NYPublic/dispatch NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022 "01" 2. Note:For certification dates, a default value of appears in the month field ifthe specific month was not provided by ABMS. *ABMS Copyright 2022 American Board of Medical Specialties. All rights reserved. Memberships Professional Last Updated 01-06-2022 (optional) $ TO TOP Organizations Member of North American Spine SocietyAmerican Board of Physical Medicine & RehabilitationAmerican Academy of Physical Medicine & Rehabilitation Note: Professional Memberships information continues to be collected and reviewed. You should check periodically to see if information has been added or updated. Go back to previous page The New York State Department of Health would like your feedback! Please click here to take a brief survey Physician Profile Survey Disclaimer: The data collected by the department is accurate to the best of the knowledge of the department, based on the information supplied by the physician who is the subject of the data. While the department utilizes a variety of sources of information in checking the accuracy of the data reported, we cannot be sure that all of the information on this website is right, complete, or up-to-date, and cannot be responsible for any information that is wrong or has been left out. Consumers are encouraged to consult other sources to verify or obtain additional information about a physician. parties' Pending legal actions do not in any way indicate guilt, liability or culpability. Cases may be dismissed, withdrawn, or settled without payments to plaintiffs. Any disposition to a case may be subject to appeal. Home | Search | About the Physician Profile | Physicians: Update your Profile Search Tip-s_|Dictionary.| Disclaimers | Contact Us | Give Us Your Feedback | Privacy. Policy. Department of Health Home Page | Center for Consumer Health Care Information New York State Education Office of the Professions On-line Verification Searches New York State Hospital Profile |New York State Unified Court System Ver 11.0 https://www.nydoctorprofile.com/NYPublic/dispatch 2/2 6 of 10 FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 12:49 9/27/22, DOC. NYSCEF PM NO. 23 https://www.nydoctorprofile.com/NYPublic/dispatch RECEIVED NYSCEF: 09/29/2022 W . Back to Selectitems Physician s..rch a.suits cm to print .... OfficeLocations: Yinggang Zheng Goshen, NY NYS License Number: 252239 Date of NYS Licensure: 03-06-2009 Profilelastupdated by physician:01-06-2022 National Provider ID: 1346471786 Education "PracticeInfo "LegalActions "ProfessionalActivities "Statement Mediclhe *HIVSendees "Offices "LanguagesAvailable "HealthPlans I d erþovernmentInsurancePrograms "HospitalPrivieges Field of Medicine Last Updated 01-06-2022 $ To Toe Primary Field of Field Practice Physical Medicine and Rehabilitation/Pain Management Yes HIV Services (optional) Last Updated 01-06-2022 $ TO TOP Services Provided HIV Services and/or care for patients on ARV No HIV Referral Services Accepted for new patients No HIV Certified by AAHIVM and/or member of HIVMA No Note: Contact the physician's office for more information. Offices (optional) TO TOP . Last Updated 01-06-2022 Office Doctors in Practice Goshen Physical medicine Yinggang Zheng 2004 Rt 17M GOSHEN, NY 10924 County: Orange (845)232-0798 Accessible to persons with disabilities: Yes Languages Available Last Updated 01-06-2022 $ TO TOP Chinese-Mandarin Spanish Note: Contact the physician's office for more information. Medicaid and Other Government Insurance Programs yoyop Last Updated 01-06-2022 https://www.nydoctorprofile.com/NYPublic/dispatch 1/2 7 of 10 FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 9/27/22,12:49 PM https://www.nydoctorprofile.com/NYPublic/dispatch NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022 Program Does the doctor accept this insurance? Medicaid At alllocations Medicare At alllocations Child Health Plus At no locations Tri Care Note:Contact the doctor's office to see if thisinformation has changed. Health Plans (optional) The physician did not supply this information Hospital Privileges TO TOP Last Updated 01-06-2022 BON SECOURS COMMUNITY HOSPITAL PORT JERVIS ELLENVILLE REGIONAL HOSPITAL ELLENVILLE Note:Call your health plan to see which hospitals you can use. 4gig Go back to previous p_gge The New York State Department of Health would like your feedback! Please click here to take a brief survey Physician Profile Survey Disclaimer: The data collected by the department is accurate to the best of the knowledge of the department, based on the information supplied by the physician who is the subject of the data. While the department utilizes a variety of sources of information in checking the accuracy of the data reported, we cannot be sure that all of the information on this website Is right, complete, or up-to-date, and cannot be responsible for any information that is wrong or has been left out. Consumers are encouraged to consult other sources to verify or obtain additional information about a physician. parties' Pending legal actions do not in any way indicate guilt, liability or culpability. Cases may be dismissed, withdrawn, or settled without payments to plaintiffs. Any disposition to a case may be subject to appeal. Home | Search| A.b_out the Physician Profile |_P_hysicians: Update your Profile Search Tipa | Dictionary | Disclaimers | Contact Us | Give Us Your Feedback | Privacy. Policy. Department of Health Home Page | Center for Consumer Health Care Information New York State Education Office of the Professions On-line Verification Searches New York State Hospital Profile | New York State Unified Court System Ver 11.0 https://www.nydoctorprofile.com/NYPublic/dispatch 2/2 8 of 10 FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022 AFFIDAVIT OF SERVICE STATE OF NEW YORK, COUNTY OF ULSTER ss.: LARRY CRUZ, being duly sworn, deposes and says: 1. I am over 18 years of age, I am not a party to the action, and I reside in Dutchess County in the State of New York. 2. I served a true copy of the annexed PLAIN FFS EXPERT EXCHANGE PURSUANT TO C.P.L.R. 3101(d) on September 2022, by mailing the same in a sealed envelope, with postage prepaid thereon, in a post office or officialdepository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressee as indicated below: Law Office of Bryan R. Kaplan PO Box 1000 Rock Hill, NY 12775 RY CRUZ S orn to before me this day of September, 2022 Notary P lic MARYELLEN 5CHNEPF c' : Notary Pub ic.8:25 w York Commason Expires June d 9 of 10 FILED: ORANGE COUNTY CLERK 09/29/2022 10:53 AM INDEX NO. EF003832-2021 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022 Index No.EF003832-2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE JUAN M. CASTILLO, Plaintiff(s), -against- XIANGYNG HE, Defendant(s). PLAINTIFFS EXPERT EXCHANGE PURSUANT TO C.P.LR. 3101(d) MAINETTI & MAINETTI, PC Attorneys for Plaintiff 130 N. Front Street Kingston, New York 12401 (845) 600-0000 To: Attorney(s)for Serviceof a copyof the within is herebyadmitted Dated: Attorney(s)for PLEASE TAKE NOTICE O that the within is a true of a (certified) copy Noticeof entered in the office of the clerk of the within named court 20 Entry O that an Order of which the within is a true will be presented for copy Noticeof One of the judges of the within named Court, settlement at on 20 , at M. Dated: MAINETTI & MAINETTI, PC Attorneys for Plaintiff 130 N. Front Street To: Kingston, New York 12401 (845) 600-0000 10 of 10