Preview
FILED: SUFFOLK COUNTY CLERK 09/12/2018 10:53 PM INDEX NO. 026910/2012
NYSCEF DOC. NO. 22 For ClerkNYSCEF:
RECEIVED Use 09/12/2018
NOTE OF ISSUE
Calendar No. (if any)
Index No.: 26910/12
SUPREME COURT OF THE STATE OF
NEW YORK
COUNTY CLERK SUFFOLK COUNTY.
Hon.
xxxxxx xxxxxxxx, on behalf of xxxxx NOTICE FOR TRIAL
xxxxxxxx, an infant under the age of 18, and [X] Trial by jury demanded
xxxxxx xxxxxxxx, Individually,
[X] Of all issues
Plaintiff, [ ] Or attached hereto
[ ] Trial without jury
Filed by attorney for plaintiff(s)
Date summons filed: __8/30/2012
-against- Date summons served: 10/1/2012
Date issue joined: 11/09/2012
RONALD J. TADEO, M.D., RICHARD
PITCH, M.D., SCOTT BERLIN, M.D., NATURE OF ACTION OR SPECIAL
SHORE PSYCHIATRIC CENTER, FAMILY PROCEEDING
PSYCHOLOGY OF LONG ISLAND, BERLIN [ ] Tort []Motor vehicle negligence
OBGYN ASSOCIATES, JANSSEN [ X ] Medical malpractice
PHARMACEUTICALS, INC. and ZYDUS [ ] Other tort
PHARMACEUTICALS (USA), INC., [ ] Contract
[ ] Contested matrimonial
Defendants. [ ] Tax certiorari
[ ] Condemnation
[ ] Other (not itemized above) specify:
[ ]This action is brought as a class action.
Special preference claimed under on the ground ___This action is brought as a class action
that plaintiff sustained severe personal injuries This is a medical malpractice action:
panel procedures prescribed by court rules
pursuant to Jud § 148-a
Napoli Shkolnik, PLLC have been completed have not been
Attorneys for Plaintiff completed
360 Lexington Avenue, 11th Floor Amount demanded exceeds the
New York, NY 10017 jurisdictional limits of all lower Courts,
which would otherwise have jurisdiction
See attached rider for Defendants. over this matter
Other relief:
_______________________
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FILED: SUFFOLK COUNTY CLERK 09/12/2018 10:53 PM INDEX NO. 026910/2012
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 09/12/2018
CERTIFICATE OF READINESS FOR TRIAL
For Clerk's Use N.I. served on
(Items 1-7 must be checked)
COMPLETED WAIVED NOT REQUIRED
1. All pleadings served. XX
2. Bill of particulars served. XX
3. Physical examination(s) completed. XX __
4. Medical reports exchanged. XX
5. Appraisal reports exchanged. XX
6. Compliance with the Rules in matrimonial
actions (22 NYCRR 202.16). _XX
7. Discovery proceedings now known to be
necessary completed. __XX
8. There are no outstanding requests for discovery.
9. There has been a reasonable opportunity to completc the
foregoing proceediñgs.
10. There has been cempliance with any order issued pursuant to the Pre-calendar Rules (22 NYCRR 202.12).
11. If a masons ==p·=_tice action, there has been compliance with any order issued pursuant to 22 NYCRR
202.56.
12. THIS CASE IS READY FOR TRIAL.
DATED: New York, New York
September 12, 2018
xxxxxx xxxxxxx
Napoli Shkolnik, PLLC
Attorneys for Plaintiff
11*
360 Lexington Avenue, Floor
New York, NY 10017
(212) 267-3700
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FILED: SUFFOLK COUNTY CLERK 09/12/2018 10:53 PM INDEX NO. 026910/2012
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 09/12/2018
To:
KAUFMAN BOORGEEST & RYAN, LLP
Attorneys for Defendant
FAMILY PSYCHOLOGY OF LONG ISLAND
1205 Franklin Avenue, Suite 200
Garden City, New York 11530
Tel: (516) 248-6000
ANGEL & MCCARTHY PLLC
Attorneys for Defendant
RICHARD PITCH, M.D.
170 Old Country Road, Suite 210
Mineola, New York 11501
(516) 741-3900
BARTLETT, McDONOUGH & MONAGHAN, LLP
Attorney for Defendants
SCOTT BERLIN, M.D. and BERLIN OBGYN ASSOCIATES
670 Main Street
Islip, New York 11751
(631) 277-0300
BOWER LAW, P.C.
Attorneys for Defendants
RONALD J. TADEO, M.D. and SHORE PSYCHIATRIC CENTER
1220 RXR Plaza
Uniondale, New York 11556
(516) 881-4380
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FILED: SUFFOLK COUNTY CLERK 09/12/2018 10:53 PM INDEX NO. 026910/2012
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 09/12/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
xxxxxx xxxxxxxx, on behalf of xxxxx Index No.: 26910/12
xxxxxxxx, an infant under the age of 18, and xxxxxx
xxxxxxxx, Individually,
Plaintiffs, AFFIRMATION OF
COMPLIANCE
-against-
RONALD J. TADEO, M.D., RICHARD PITCH, M.D.,
SCOTT BERLIN, M.D., SHORE PSYCHIATRIC
CENTER, FAMILY PSYCHOLOGY OF LONG
ISLAND, BERLIN OBGYN ASSOCIATES, JANSSEN
PHARMACEUTICALS, INC. and ZYDUS
PHARMACEUTICALS (USA), INC,
Defendants.
xxxxxx an =d=ª=d to practice law in the Courts of the State of New York affirms the
xxxxxxx, attomey duly
following to be true under penalties of perjury:
I am an attorney associated with the firm of NAPOLI SHKOLNIK, PLLC, attorneys for the plaintiff herein. I
f--™--
am fully
with the facts and circu-stsñces of this action. This affinnation is made upon information and
belief, your affirmant's source of knowledge being the file mai-ts -ed by this office.
This affirmation is submitted in compliance with the CPLR 3402(a)
The Summons and Verified Complaint were served on defendant on October 1, 2012.
Issues was joined by defendant on November 9, 2012.
A Bill of Particulars was served on defeñdañt(s)
on December 14, 2012.
Your affirmant respectfully submits, upon information and belief, that pre-trial proceedings have been
completed and the above action is now ready for calcñdâr.
WHEREFORE, it is respectfully requested that this matter be placed on the trial calendar of this court.
Dated: New York, New York
Sentember 12. 2018
xxxxxx xxxxxxx
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Preview
FILED: SUFFOLK COUNTY CLERK 09/12/2018 10:53 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 22 For ClerkNYSCEF: RECEIVED Use 09/12/2018 NOTE OF ISSUE Calendar No. (if any) Index No.: 26910/12 SUPREME COURT OF THE STATE OF NEW YORK COUNTY CLERK SUFFOLK COUNTY. Hon. xxxxxx xxxxxxxx, on behalf of xxxxx NOTICE FOR TRIAL xxxxxxxx, an infant under the age of 18, and [X] Trial by jury demanded xxxxxx xxxxxxxx, Individually, [X] Of all issues Plaintiff, [ ] Or attached hereto [ ] Trial without jury Filed by attorney for plaintiff(s) Date summons filed: __8/30/2012 -against- Date summons served: 10/1/2012 Date issue joined: 11/09/2012 RONALD J. TADEO, M.D., RICHARD PITCH, M.D., SCOTT BERLIN, M.D., NATURE OF ACTION OR SPECIAL SHORE PSYCHIATRIC CENTER, FAMILY PROCEEDING PSYCHOLOGY OF LONG ISLAND, BERLIN [ ] Tort []Motor vehicle negligence OBGYN ASSOCIATES, JANSSEN [ X ] Medical malpractice PHARMACEUTICALS, INC. and ZYDUS [ ] Other tort PHARMACEUTICALS (USA), INC., [ ] Contract [ ] Contested matrimonial Defendants. [ ] Tax certiorari [ ] Condemnation [ ] Other (not itemized above) specify: [ ]This action is brought as a class action. Special preference claimed under on the ground ___This action is brought as a class action that plaintiff sustained severe personal injuries This is a medical malpractice action: panel procedures prescribed by court rules pursuant to Jud § 148-a Napoli Shkolnik, PLLC have been completed have not been Attorneys for Plaintiff completed 360 Lexington Avenue, 11th Floor Amount demanded exceeds the New York, NY 10017 jurisdictional limits of all lower Courts, which would otherwise have jurisdiction See attached rider for Defendants. over this matter Other relief: _______________________ 1 of 4 FILED: SUFFOLK COUNTY CLERK 09/12/2018 10:53 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 09/12/2018 CERTIFICATE OF READINESS FOR TRIAL For Clerk's Use N.I. served on (Items 1-7 must be checked) COMPLETED WAIVED NOT REQUIRED 1. All pleadings served. XX 2. Bill of particulars served. XX 3. Physical examination(s) completed. XX __ 4. Medical reports exchanged. XX 5. Appraisal reports exchanged. XX 6. Compliance with the Rules in matrimonial actions (22 NYCRR 202.16). _XX 7. Discovery proceedings now known to be necessary completed. __XX 8. There are no outstanding requests for discovery. 9. There has been a reasonable opportunity to completc the foregoing proceediñgs. 10. There has been cempliance with any order issued pursuant to the Pre-calendar Rules (22 NYCRR 202.12). 11. If a masons ==p·=_tice action, there has been compliance with any order issued pursuant to 22 NYCRR 202.56. 12. THIS CASE IS READY FOR TRIAL. DATED: New York, New York September 12, 2018 xxxxxx xxxxxxx Napoli Shkolnik, PLLC Attorneys for Plaintiff 11* 360 Lexington Avenue, Floor New York, NY 10017 (212) 267-3700 2 of 4 FILED: SUFFOLK COUNTY CLERK 09/12/2018 10:53 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 09/12/2018 To: KAUFMAN BOORGEEST & RYAN, LLP Attorneys for Defendant FAMILY PSYCHOLOGY OF LONG ISLAND 1205 Franklin Avenue, Suite 200 Garden City, New York 11530 Tel: (516) 248-6000 ANGEL & MCCARTHY PLLC Attorneys for Defendant RICHARD PITCH, M.D. 170 Old Country Road, Suite 210 Mineola, New York 11501 (516) 741-3900 BARTLETT, McDONOUGH & MONAGHAN, LLP Attorney for Defendants SCOTT BERLIN, M.D. and BERLIN OBGYN ASSOCIATES 670 Main Street Islip, New York 11751 (631) 277-0300 BOWER LAW, P.C. Attorneys for Defendants RONALD J. TADEO, M.D. and SHORE PSYCHIATRIC CENTER 1220 RXR Plaza Uniondale, New York 11556 (516) 881-4380 3 of 4 FILED: SUFFOLK COUNTY CLERK 09/12/2018 10:53 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 09/12/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK xxxxxx xxxxxxxx, on behalf of xxxxx Index No.: 26910/12 xxxxxxxx, an infant under the age of 18, and xxxxxx xxxxxxxx, Individually, Plaintiffs, AFFIRMATION OF COMPLIANCE -against- RONALD J. TADEO, M.D., RICHARD PITCH, M.D., SCOTT BERLIN, M.D., SHORE PSYCHIATRIC CENTER, FAMILY PSYCHOLOGY OF LONG ISLAND, BERLIN OBGYN ASSOCIATES, JANSSEN PHARMACEUTICALS, INC. and ZYDUS PHARMACEUTICALS (USA), INC, Defendants. xxxxxx an =d=ª=d to practice law in the Courts of the State of New York affirms the xxxxxxx, attomey duly following to be true under penalties of perjury: I am an attorney associated with the firm of NAPOLI SHKOLNIK, PLLC, attorneys for the plaintiff herein. I f--™-- am fully with the facts and circu-stsñces of this action. This affinnation is made upon information and belief, your affirmant's source of knowledge being the file mai-ts -ed by this office. This affirmation is submitted in compliance with the CPLR 3402(a) The Summons and Verified Complaint were served on defendant on October 1, 2012. Issues was joined by defendant on November 9, 2012. A Bill of Particulars was served on defeñdañt(s) on December 14, 2012. Your affirmant respectfully submits, upon information and belief, that pre-trial proceedings have been completed and the above action is now ready for calcñdâr. WHEREFORE, it is respectfully requested that this matter be placed on the trial calendar of this court. Dated: New York, New York Sentember 12. 2018 xxxxxx xxxxxxx 4 of 4