Preview
FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
----------------------------------------------- X Index Nos. 611214/2015
ALICIA M. ARUNDEL; SUZANNE SCHULMAN, 609082/2015
As Administratrix of the ESTATE OF BRITTANY 600055/2016
SCHULMAN, deceased; OLGA LIPETS, MINDY 603536/2016
GRAB1NA, as Administratrix of the Estate of AMY 003364/2016
GRABINA, and MINDY GRABINA, Individually, 607598/2016
STEVEN BARUCH, as Administrator of the Estate 001831/2016
Of LAUREN BARUCH, deceased and STEVEN 614685/2016
BARUCH, Individually, JOELLE DIMONTE; and
MELISSA A. CRAI and ARTHUR A. BELLI JR.,
As parent and Natural Guardian of STEPHANIE
BELLI, deceased, and as the Administrator of THE
ESTATE OF STEPHANIE BELLI,
Plaintiffs
-against- DEMAND FOR AUTHORIZATIONS
AS TO PLAINTIFF MELISSA CRAI
ULTIMATE CLASS LIMOUSINE, INC., CARLOS
PINO, ROMEO DIMON MARINE SERVICES, INC.,
STEVEN ROMEO, TOWN OF SOUTHOLD and
COUNTY OF SUFFOLK, CABOT COACH BUILDERS,
INC. d/b/a ROYALE LIMOUSINE and "XYZ
1-5"
COMPANIES name being fictitious but intended
to be the remanufacturers, distributors and/or sellers
of the 2007 Lincoln Town Car stretch limousine
involved in the collision,
Defendants.
---------------------------- --------------X
PLEASE TAKE NOTICE, that pursuant to CPLR 3101 and Rule 3120, the plaintiff is
hereby required to furnish to the undersigned within thirty (30) days hereof, original duly
executed and addressed, open-ended HIPAA compliant authorizations for the following
providers:
1. An original duly executed HIPAA compliant authorization, non-restricted as to
date, which will enable the office of the undersigned to obtain duplicate originals
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FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021
of all updated medical records, prescription records, diagnostic records and billing
records from the following providers:
a. CareMount Medical, 110 S. Bedford Road, Mount Kisco, New York 10549
b. Gary Orentlicher, DMD, 495 Central Park Avenue, Scarsdale, New York
10583;
c. Stony Brook University Medical Center, 101 Nicholls Road, Stony Brook,
New York 11976;
d. Westchester Medical Center, 95 Grasslands Road, Valhalla, New York
10595;
e. White Plains Hospital, 41 East Post Road, White Plains, New York 10601;
f. R. Joy Bergins, LMSW, 9 Oakley Road, White Plains, New York 10606;
g. Jinah K. Shin, Ph.D., NNP, 144-24 37th Avenue, Flushing, New York 11354;
2. An original duly executed HIPAA compliant authorization, non-restricted as to
date, which will enable the office of the undersigned to obtain duplicate originals
of all medical records, prescription records, diagnostic records and billing records
from Mount Kisco Medical Group, 90 South Bedford Road, Mount Kisco, New
York 10549 that plaintiff has treated at from July 18, 2015 to present.
3. An original duly executed HIPAA compliant authorization, non-restricted as to
date, which will enable the office of the undersigned to obtain duplicate originals
of all medical records, prescription records, diagnostic records and billing records
from Elena Vezza, M.D. 485 Logan Avenue, Bronx, New York 10465 that
plaintiff has treated at from July 18, 2015 to present.
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FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021
4. An original duly executed HIPAA compliant authorization, non-restricted as to
date, which will enable the office of the undersigned to obtain duplicate originals
of all medical records, prescription records, diagnostic records and billing records
from any and all new doctors/medical facilities that plaintiff has treated at from
July 18, 2015 to present.
5. An original duly executed HIPAA compliant authorization, non-restricted as to
date, which will enable the office of the undersigned to obtain duplicate originals
of allmedical records, prescription records, diagnostic records and billing records
from any and all new hospitals that plaintiff has treated at from July 18, 2015 to
present.
6. An original duly executed HIPAA compliant authorization, non-restricted as to
date, which will enable the office of the undersigned to obtain duplicate originals
of all prescription records, and billing records from any and all pharmacies that
plaintiff has treated at from July 18, 2015 to present.
7. An original duly executed HIPAA compliant authorization, non-restricted as to
date, which will enable the office of the undersigned to obtain duplicate originals
of allmedical records, prescription records, diagnostic records and billing records
from any and all new physical therapy facilities that plaintiff has treated at from
July 18, 2015 to present.
8. An original duly executed HIPAA compliant authorization, non-restricted as to
date, which will enable the office of the undersigned to obtain duplicate originals
of all medical records, prescription records, diagnostic records and billing records
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FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021
from any and all new mental health and counseling providers that plaintiff has
treated at from July 18, 2015 to present.
PLEASE TAKE FURTHER NOTICE, that failure to comply with said demand within
thirty (30) days from the date herein will result in a motion for appropriate relief.
Dated: January 12, 2021
Mineola, New York
Yours, etc.,
BONGIORN , M IGLIO MITCHELL
& PALMIE , P
By: Neil J. Palmieri, Esq.
Attorneys for Ultimate Class Limousines, Inc.
and Carlos Pino
200 Old Country Road, Suite 680
Mineola, New York 11501
(516) 620-4490
Our File No.: IBM 068515 NJP
To: The Bongiorno Law Firm, PLLC
Attorneys for Plaintiff - Arundel
1415 Kellum Place, Suite 205
Garden City, New York 11530
(516) 741-4170
File No. 6230.PP
John L. Juliano, P.C.
for Plaintiff - Schulman
Attorney
39 Doyle Court
East Northport, New York 11731
(631) 499-9300
Chaikin, PLLC
Attorneys for Plaintiff - Lipets
1 Penn Plaza, Suite 5315
New York, New York 10122
(212) 977-2020
Frank J. Laine, P.C.
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NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021
for Plaintiff - Grabina
Attorney
449 South Oyster Bay Road
Plainview, New York 11803
(516) 937-1010
The Law Office of Robin V. Singh, P.C.
for Plaintiff - Grabina
Attorney
193-15 Hillside Avenue
Hollis, New York 11423
(917) 923-1646
Sullivan Papain Block McGrath & Cannavo, P.C.
Attorneys for Plaintiff - Baruch
1140 Franklin Avenue, Suite 200
Garden City, New York 11530
(516) 742-0707
Pegalis Law Group, LLC
Attorneys for Plaintiff - Dimonte
One Hollow Lane, Suite 107
Lake Success, New York 11042
(516) 684-2900
Joseph J. Tock, Esq.
for Plaintiff - Crai
Attorney
963 Route 6
Mahopac, New York 10541
(845) 682-8080
Block O'Toole & Murphy, LLP
for Plaintiff -Belli
Attorney
1 Pennsylvania Plaza, suite 5315
New York, New York 10119
(212) 736-5300
Lewis, Johs, Avallone & Aviles, LLP
Attorneys for Steven D. Romeo
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
File No. 0114-1460-001C
Cascone & Kluepfel, LLP
Attorneys for Romeo Dimon Marine Services, Inc.
1399 Franklin Avenue, Suite 302
Garden City, New York 11530
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FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021
(516) 747-1990
File No. 03787DVM
Law Offices of Vincent D. McNamara
Attorneys for The County of Suffolk
Tower Square - 1045 Oyster Suite 1
Bay Road,
East Norwich, New York 11732
(516) 922-9100
File No.: 907-4677
Law Office of Thomas M. Volz, PLLC
Attomeys for The Town of Southold
280 Smithtown Boulevard
Nesconset, New York 11767
(631) 366-2700
Law Office of Victor J. Natale
Attorney for Cabot Coach Builders, Inc.
3 Huntington Quadrangle, Suite 102S
Melville, New York 11747
(631) 501-3100
File No. 2017024539SAS
6 of 6
Preview
FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ----------------------------------------------- X Index Nos. 611214/2015 ALICIA M. ARUNDEL; SUZANNE SCHULMAN, 609082/2015 As Administratrix of the ESTATE OF BRITTANY 600055/2016 SCHULMAN, deceased; OLGA LIPETS, MINDY 603536/2016 GRAB1NA, as Administratrix of the Estate of AMY 003364/2016 GRABINA, and MINDY GRABINA, Individually, 607598/2016 STEVEN BARUCH, as Administrator of the Estate 001831/2016 Of LAUREN BARUCH, deceased and STEVEN 614685/2016 BARUCH, Individually, JOELLE DIMONTE; and MELISSA A. CRAI and ARTHUR A. BELLI JR., As parent and Natural Guardian of STEPHANIE BELLI, deceased, and as the Administrator of THE ESTATE OF STEPHANIE BELLI, Plaintiffs -against- DEMAND FOR AUTHORIZATIONS AS TO PLAINTIFF MELISSA CRAI ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICES, INC., STEVEN ROMEO, TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC. d/b/a ROYALE LIMOUSINE and "XYZ 1-5" COMPANIES name being fictitious but intended to be the remanufacturers, distributors and/or sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. ---------------------------- --------------X PLEASE TAKE NOTICE, that pursuant to CPLR 3101 and Rule 3120, the plaintiff is hereby required to furnish to the undersigned within thirty (30) days hereof, original duly executed and addressed, open-ended HIPAA compliant authorizations for the following providers: 1. An original duly executed HIPAA compliant authorization, non-restricted as to date, which will enable the office of the undersigned to obtain duplicate originals 1 of 6 FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021 of all updated medical records, prescription records, diagnostic records and billing records from the following providers: a. CareMount Medical, 110 S. Bedford Road, Mount Kisco, New York 10549 b. Gary Orentlicher, DMD, 495 Central Park Avenue, Scarsdale, New York 10583; c. Stony Brook University Medical Center, 101 Nicholls Road, Stony Brook, New York 11976; d. Westchester Medical Center, 95 Grasslands Road, Valhalla, New York 10595; e. White Plains Hospital, 41 East Post Road, White Plains, New York 10601; f. R. Joy Bergins, LMSW, 9 Oakley Road, White Plains, New York 10606; g. Jinah K. Shin, Ph.D., NNP, 144-24 37th Avenue, Flushing, New York 11354; 2. An original duly executed HIPAA compliant authorization, non-restricted as to date, which will enable the office of the undersigned to obtain duplicate originals of all medical records, prescription records, diagnostic records and billing records from Mount Kisco Medical Group, 90 South Bedford Road, Mount Kisco, New York 10549 that plaintiff has treated at from July 18, 2015 to present. 3. An original duly executed HIPAA compliant authorization, non-restricted as to date, which will enable the office of the undersigned to obtain duplicate originals of all medical records, prescription records, diagnostic records and billing records from Elena Vezza, M.D. 485 Logan Avenue, Bronx, New York 10465 that plaintiff has treated at from July 18, 2015 to present. 2 of 6 FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021 4. An original duly executed HIPAA compliant authorization, non-restricted as to date, which will enable the office of the undersigned to obtain duplicate originals of all medical records, prescription records, diagnostic records and billing records from any and all new doctors/medical facilities that plaintiff has treated at from July 18, 2015 to present. 5. An original duly executed HIPAA compliant authorization, non-restricted as to date, which will enable the office of the undersigned to obtain duplicate originals of allmedical records, prescription records, diagnostic records and billing records from any and all new hospitals that plaintiff has treated at from July 18, 2015 to present. 6. An original duly executed HIPAA compliant authorization, non-restricted as to date, which will enable the office of the undersigned to obtain duplicate originals of all prescription records, and billing records from any and all pharmacies that plaintiff has treated at from July 18, 2015 to present. 7. An original duly executed HIPAA compliant authorization, non-restricted as to date, which will enable the office of the undersigned to obtain duplicate originals of allmedical records, prescription records, diagnostic records and billing records from any and all new physical therapy facilities that plaintiff has treated at from July 18, 2015 to present. 8. An original duly executed HIPAA compliant authorization, non-restricted as to date, which will enable the office of the undersigned to obtain duplicate originals of all medical records, prescription records, diagnostic records and billing records 3 of 6 FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021 from any and all new mental health and counseling providers that plaintiff has treated at from July 18, 2015 to present. PLEASE TAKE FURTHER NOTICE, that failure to comply with said demand within thirty (30) days from the date herein will result in a motion for appropriate relief. Dated: January 12, 2021 Mineola, New York Yours, etc., BONGIORN , M IGLIO MITCHELL & PALMIE , P By: Neil J. Palmieri, Esq. Attorneys for Ultimate Class Limousines, Inc. and Carlos Pino 200 Old Country Road, Suite 680 Mineola, New York 11501 (516) 620-4490 Our File No.: IBM 068515 NJP To: The Bongiorno Law Firm, PLLC Attorneys for Plaintiff - Arundel 1415 Kellum Place, Suite 205 Garden City, New York 11530 (516) 741-4170 File No. 6230.PP John L. Juliano, P.C. for Plaintiff - Schulman Attorney 39 Doyle Court East Northport, New York 11731 (631) 499-9300 Chaikin, PLLC Attorneys for Plaintiff - Lipets 1 Penn Plaza, Suite 5315 New York, New York 10122 (212) 977-2020 Frank J. Laine, P.C. 4 of 6 FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021 for Plaintiff - Grabina Attorney 449 South Oyster Bay Road Plainview, New York 11803 (516) 937-1010 The Law Office of Robin V. Singh, P.C. for Plaintiff - Grabina Attorney 193-15 Hillside Avenue Hollis, New York 11423 (917) 923-1646 Sullivan Papain Block McGrath & Cannavo, P.C. Attorneys for Plaintiff - Baruch 1140 Franklin Avenue, Suite 200 Garden City, New York 11530 (516) 742-0707 Pegalis Law Group, LLC Attorneys for Plaintiff - Dimonte One Hollow Lane, Suite 107 Lake Success, New York 11042 (516) 684-2900 Joseph J. Tock, Esq. for Plaintiff - Crai Attorney 963 Route 6 Mahopac, New York 10541 (845) 682-8080 Block O'Toole & Murphy, LLP for Plaintiff -Belli Attorney 1 Pennsylvania Plaza, suite 5315 New York, New York 10119 (212) 736-5300 Lewis, Johs, Avallone & Aviles, LLP Attorneys for Steven D. Romeo One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 File No. 0114-1460-001C Cascone & Kluepfel, LLP Attorneys for Romeo Dimon Marine Services, Inc. 1399 Franklin Avenue, Suite 302 Garden City, New York 11530 5 of 6 FILED: SUFFOLK COUNTY CLERK 01/15/2021 01:09 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 759 RECEIVED NYSCEF: 01/15/2021 (516) 747-1990 File No. 03787DVM Law Offices of Vincent D. McNamara Attorneys for The County of Suffolk Tower Square - 1045 Oyster Suite 1 Bay Road, East Norwich, New York 11732 (516) 922-9100 File No.: 907-4677 Law Office of Thomas M. Volz, PLLC Attomeys for The Town of Southold 280 Smithtown Boulevard Nesconset, New York 11767 (631) 366-2700 Law Office of Victor J. Natale Attorney for Cabot Coach Builders, Inc. 3 Huntington Quadrangle, Suite 102S Melville, New York 11747 (631) 501-3100 File No. 2017024539SAS 6 of 6