Preview
FILED: RICHMOND COUNTY CLERK 04/21/2022 10:30 AM INDEX NO. 152064/2020
NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 04/21/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
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X
KEESHA WOODS, :
: Index No. 152064/2020
Plaintiff, :
: POST-DEPOSITION
-against- : DEMAND FOR DISCOVERY
: and INSPECTION
MUSLEH-FOREST REALTY, LLC, MEKKAH :
MEDITERANEAN MARKET and DOLLAR :
GENERAL STORE, :
Defendants.
----------------------------------------------------------------------X
C O U N S E L O R S:
PLEASE TAKE NOTICE, that pursuant to CPLR 3101, et seq., plaintiff, KEESHA
WOODS, is to serve upon the undersigned, within thirty (30) days, the following:
1. Duly executed, original and HIPAA-compliant authorizations permitting the
undersigned to secure the Entire Medical Record, including patient histories, office notes (except
psychotherapy notes), test results, radiology studies, films, referrals, consults, intraoperative
films/photos/video/diagnostics, insurance records and records sent by other health care providers, for
all medical providers including but not limited to hospitals, medical doctors, radiologists, surgeons,
and therapists, which Plaintiff treated for her spina bifida occulta condition from the date of first
treatment to present.
2. True and accurate copies of documentation reflecting income earned by Plaintiff
for two (2) years prior to the occurrence alleged in the complaint and up to the present date,
including, but not limited to, W-2 Forms, 1099 Form, and any other indicia of income earned.
3. Duly executed and acknowledged written authorizations required to permits this
defendant to obtain Internal Revenue Service records, documents and returns relative to Plaintiff
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FILED: RICHMOND COUNTY CLERK 04/21/2022 10:30 AM INDEX NO. 152064/2020
NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 04/21/2022
for two (2) years prior to the occurrence alleged in the complaint and up to the present date. Please
use authorization form 4506 for this purpose. Include photocopies of two (2) pieces of
identification bearing each plaintiff's signature, i.e.,social security card, driver’s license and/or
passport.
4. Duly executed and acknowledged original written authorization which permits the
demanding Defendant to obtain a complete copy of the employment records for the Plaintiff from two
years prior to the subject incident to present from Plaintiff’s employer, Government Employees
Insurance Company (“GEICO”).
5. Duly executed HIPAA-compliant original authorizations containing the proper
addresses permitting the release of Plaintiff’s medical records, including x-ray, MRI, and other
diagnostic testing films and reports, from NYU Hospital, from the date of the subject incident to
present.
PLEASE TAKE FURTHER NOTICE, that these are continuing demands, and that if any
of the above items are obtained after the date of this notice, they are to be furnished to the undersigned
pursuant to this notice.
PLEASE TAKE FURTHER NOTICE, that the foregoing authorizations shall be directed
to the appropriate entity with complete address of same, shall indicate any necessary identification
number, and shall be issued and executed in favor of the undersigned not more than thirty (30) days
before receipt by the undersigned.
PLEASE TAKE FURTHER NOTICE that each of these authorizations, where required,
must be HIPAA-compliant.
PLEASE TAKE FURTHER NOTICE that each of these authorizations should expire
upon completion of litigation.
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FILED: RICHMOND COUNTY CLERK 04/21/2022 10:30 AM INDEX NO. 152064/2020
NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 04/21/2022
PLEASE TAKE FURTHER NOTICE, that unless this notice is timely and fully complied
with, an appropriate application will be made seeking relief.
Dated: New York, New York
April 21, 2022
Yours, etc.
LAW OFFICE OF KEVIN J. PHILBIN
Attorneys for Defendant
MUSLEH-FOREST REALTY, LLC,
One Whitehall Street, 13th Floor
New York, NY 10004-2109
(212) 248-9100
LF Matter No.: 20-019377
By:
__________________________
Kerrie Barry, Esq.
To: SUBIN ASSOCIATES LLP
Attorneys for Plaintiff
150 Broadway – 23rd Fl
New York, NY 10038
(212)285-3800
File No: 32137
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Preview
FILED: RICHMOND COUNTY CLERK 04/21/2022 10:30 AM INDEX NO. 152064/2020 NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 04/21/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND ------------------------------------------------------------------------ X KEESHA WOODS, : : Index No. 152064/2020 Plaintiff, : : POST-DEPOSITION -against- : DEMAND FOR DISCOVERY : and INSPECTION MUSLEH-FOREST REALTY, LLC, MEKKAH : MEDITERANEAN MARKET and DOLLAR : GENERAL STORE, : Defendants. ----------------------------------------------------------------------X C O U N S E L O R S: PLEASE TAKE NOTICE, that pursuant to CPLR 3101, et seq., plaintiff, KEESHA WOODS, is to serve upon the undersigned, within thirty (30) days, the following: 1. Duly executed, original and HIPAA-compliant authorizations permitting the undersigned to secure the Entire Medical Record, including patient histories, office notes (except psychotherapy notes), test results, radiology studies, films, referrals, consults, intraoperative films/photos/video/diagnostics, insurance records and records sent by other health care providers, for all medical providers including but not limited to hospitals, medical doctors, radiologists, surgeons, and therapists, which Plaintiff treated for her spina bifida occulta condition from the date of first treatment to present. 2. True and accurate copies of documentation reflecting income earned by Plaintiff for two (2) years prior to the occurrence alleged in the complaint and up to the present date, including, but not limited to, W-2 Forms, 1099 Form, and any other indicia of income earned. 3. Duly executed and acknowledged written authorizations required to permits this defendant to obtain Internal Revenue Service records, documents and returns relative to Plaintiff 1 of 3 FILED: RICHMOND COUNTY CLERK 04/21/2022 10:30 AM INDEX NO. 152064/2020 NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 04/21/2022 for two (2) years prior to the occurrence alleged in the complaint and up to the present date. Please use authorization form 4506 for this purpose. Include photocopies of two (2) pieces of identification bearing each plaintiff's signature, i.e.,social security card, driver’s license and/or passport. 4. Duly executed and acknowledged original written authorization which permits the demanding Defendant to obtain a complete copy of the employment records for the Plaintiff from two years prior to the subject incident to present from Plaintiff’s employer, Government Employees Insurance Company (“GEICO”). 5. Duly executed HIPAA-compliant original authorizations containing the proper addresses permitting the release of Plaintiff’s medical records, including x-ray, MRI, and other diagnostic testing films and reports, from NYU Hospital, from the date of the subject incident to present. PLEASE TAKE FURTHER NOTICE, that these are continuing demands, and that if any of the above items are obtained after the date of this notice, they are to be furnished to the undersigned pursuant to this notice. PLEASE TAKE FURTHER NOTICE, that the foregoing authorizations shall be directed to the appropriate entity with complete address of same, shall indicate any necessary identification number, and shall be issued and executed in favor of the undersigned not more than thirty (30) days before receipt by the undersigned. PLEASE TAKE FURTHER NOTICE that each of these authorizations, where required, must be HIPAA-compliant. PLEASE TAKE FURTHER NOTICE that each of these authorizations should expire upon completion of litigation. 2 of 3 FILED: RICHMOND COUNTY CLERK 04/21/2022 10:30 AM INDEX NO. 152064/2020 NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 04/21/2022 PLEASE TAKE FURTHER NOTICE, that unless this notice is timely and fully complied with, an appropriate application will be made seeking relief. Dated: New York, New York April 21, 2022 Yours, etc. LAW OFFICE OF KEVIN J. PHILBIN Attorneys for Defendant MUSLEH-FOREST REALTY, LLC, One Whitehall Street, 13th Floor New York, NY 10004-2109 (212) 248-9100 LF Matter No.: 20-019377 By: __________________________ Kerrie Barry, Esq. To: SUBIN ASSOCIATES LLP Attorneys for Plaintiff 150 Broadway – 23rd Fl New York, NY 10038 (212)285-3800 File No: 32137 3 of 3