Preview
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
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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
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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
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NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/29/2022
Physician 4 Back
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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.
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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
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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.
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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
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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
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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
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
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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
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