On June 08, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Priscilla Martinez,
and
Cats 3531 Broadway, Llc,
Rite Aid Of New York City Inc.,
for Torts - Other Negligence (Personal Injury)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 12/07/2020 07:03 PM INDEX NO. 154062/2020
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/07/2020
"G"
EXHIBIT
FILED: NEW YORK COUNTY CLERK 12/07/2020 07:03 PM INDEX NO. 154062/2020
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/07/2020
O 201-8s7-s81s
RUBlNE+CHA u.c SETH B. RUBINE, ESQ
M 917-494-7384
ATTORNEYS AT LAW 65 HARRISTOWN ROAD, SUITE 203 F 877-533-9898
GLEN ROCK, NJ 07452
SRUSINEORUBINECHA.COM RUBINECHA.COM
October 23, 2020
Vla Regular Man and
E-man - mzteher@subinlaw.com
Maria Zieher, Esq.
SUBIN ASSOCIATES, 11P
150 Broadway, 234 Floor
New York, NY 10038
Re: Priscilla Martinez v. Rite Aid of New York, Inc., et al
New York County Supreme Court, Index No. 1 54062/2020
Your File No. 30031
Our FileNo. RAC-1334-2020
Dear Ms. Zieber:
I am with to letter of October 158 (with in the
writing reference my enclosures)
abovs matter. To date, we have not
still yet received the fo|iowing:
• A signed verification from you or plaintiff, Priscilla Martinez, for the Billof
Particulars
• A initialed and executed HIPAA authorization for plaintiff's records
properly
from Mount Sinai St. Luke's Hospital
• A initiated and executed HIPAA authorization for plaintiff's records
properly
from the ambulance service that transported her from the accident scene
to the emergency room at Mount Sinai St. Luke's Hospital
• A specific response to Rite Aid's Demand for Damages - what is the
plaintiff's settlement demand9
• The name and address of the physician and/or medical that
facility
diagnosed and/or treated the plaintiff for the left knee injury alleged in the
Billof Particulars
• The name and address of the physician and/or medical that
faciftly
diagnosed and/or treated the plaintiff for the headaches alleged in the Bill
of Particulars
.
FILED: NEW YORK COUNTY CLERK 12/07/2020 07:03 PM INDEX NO. 154062/2020
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/07/2020
sETH B. RUB1NE, ESQ
• The name and address of the physician and/or medical that
facility
diagnosed and/or treated the plaintiff for vertigo alleged in the Billof
Particulars .
• The name and address of the physician and/or medical facility that
diagnosed and/or treated the plaintiff for post-traumatic stress disorder
alleged in the Billof Particulars
• initiated and executed HIPAA authorizations for plaintiff's
Properly
records from any and all physicians and medical facilities that treated the
plaintiff for her motor vehicle accident as referenced in the January 22,
2018 physical therapy note from All Boro Medical Rehabilitation
• initialed and executed HIPAA authorizations for plaintiff's
Properly
records from any and all physicians and medical facilities that treated the
plaintiff for her prior left knee condition and surgery in 2017 as referenced
in the January 22, 2018 physical therapy note from All Boro Medical
Rehabilitation
Please provide this outstanding discovery within the next 10 business days so that
we can continue to move forward without the Court's involvement.
Should you have any questions, please do not hesitate to contact me.
Very yours
RU E + A, LL
SETH B. BINE
SBR/jn
PG2
Document Filed Date
December 07, 2020
Case Filing Date
June 08, 2020
Category
Torts - Other Negligence (Personal Injury)
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Preview
FILED: NEW YORK COUNTY CLERK 12/07/2020 07:03 PM INDEX NO. 154062/2020 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/07/2020 "G" EXHIBIT FILED: NEW YORK COUNTY CLERK 12/07/2020 07:03 PM INDEX NO. 154062/2020 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/07/2020 O 201-8s7-s81s RUBlNE+CHA u.c SETH B. RUBINE, ESQ M 917-494-7384 ATTORNEYS AT LAW 65 HARRISTOWN ROAD, SUITE 203 F 877-533-9898 GLEN ROCK, NJ 07452 SRUSINEORUBINECHA.COM RUBINECHA.COM October 23, 2020 Vla Regular Man and E-man - mzteher@subinlaw.com Maria Zieher, Esq. SUBIN ASSOCIATES, 11P 150 Broadway, 234 Floor New York, NY 10038 Re: Priscilla Martinez v. Rite Aid of New York, Inc., et al New York County Supreme Court, Index No. 1 54062/2020 Your File No. 30031 Our FileNo. RAC-1334-2020 Dear Ms. Zieber: I am with to letter of October 158 (with in the writing reference my enclosures) abovs matter. To date, we have not still yet received the fo|iowing: • A signed verification from you or plaintiff, Priscilla Martinez, for the Billof Particulars • A initialed and executed HIPAA authorization for plaintiff's records properly from Mount Sinai St. Luke's Hospital • A initiated and executed HIPAA authorization for plaintiff's records properly from the ambulance service that transported her from the accident scene to the emergency room at Mount Sinai St. Luke's Hospital • A specific response to Rite Aid's Demand for Damages - what is the plaintiff's settlement demand9 • The name and address of the physician and/or medical that facility diagnosed and/or treated the plaintiff for the left knee injury alleged in the Billof Particulars • The name and address of the physician and/or medical that faciftly diagnosed and/or treated the plaintiff for the headaches alleged in the Bill of Particulars . FILED: NEW YORK COUNTY CLERK 12/07/2020 07:03 PM INDEX NO. 154062/2020 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/07/2020 sETH B. RUB1NE, ESQ • The name and address of the physician and/or medical that facility diagnosed and/or treated the plaintiff for vertigo alleged in the Billof Particulars . • The name and address of the physician and/or medical facility that diagnosed and/or treated the plaintiff for post-traumatic stress disorder alleged in the Billof Particulars • initiated and executed HIPAA authorizations for plaintiff's Properly records from any and all physicians and medical facilities that treated the plaintiff for her motor vehicle accident as referenced in the January 22, 2018 physical therapy note from All Boro Medical Rehabilitation • initialed and executed HIPAA authorizations for plaintiff's Properly records from any and all physicians and medical facilities that treated the plaintiff for her prior left knee condition and surgery in 2017 as referenced in the January 22, 2018 physical therapy note from All Boro Medical Rehabilitation Please provide this outstanding discovery within the next 10 business days so that we can continue to move forward without the Court's involvement. Should you have any questions, please do not hesitate to contact me. Very yours RU E + A, LL SETH B. BINE SBR/jn PG2