Preview
FILED: KINGS COUNTY CLERK 02/22/2022 05:50 PM INDEX NO. 512147/2020
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/22/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
__-_____-__________________-____--------------__-_______-----------X
MAGLENY F. MENDEZ,
Index No.: 153798/2016
Plaintiff(s),
SUPPLEMENTAL
- against - DEMAND FOR
DISCOVERY AND
NEW YORK CITY HOUSING AUTHORITY, INSPECTION
NEW YORK CITY HOUSING AUTHORITY
TRIBOROUGH PRESERVATION
DEVELOPMENT and NEW YORK CITY
COUNCIL FOR HOUSING DEVELOPMENT
FUND COMPANIES,
Defendants.
-----------------------------------------------------------------x
PLEASE TAKE NOTICE that defendants, New York City Housing Authority and
New York City Housing Authority Triborough Preservation and Development, by and through
their attorneys, WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER, LLP, hereby
demand that the Plaintiff provide to said attorneys at 1133 Westchester Avenue, White Plains,
NY 10604, within 20
1. Duly executed and HIPAA compliant authorization for the release of plaintiff's records
from Lincoln Hospital.
2. Duly executed and HIPAA compliant authorization for the release of plaintiff's records
from any other hospital at which she treated as a result of the subject accident.
3. Courtesy copies of the medical records of Lincoln Hospital.
PLEASE TAKE FURTHER NOTICE that Responding Defendants reserve the right to
supplement and/or amend this response should such information become available.
264 219621v.1
1 of 4
FILED: KINGS COUNTY CLERK 02/22/2022 05:50 PM INDEX NO. 512147/2020
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/22/2022
Dated: White Plains, New York
December 8, 2021
Yours, etc.,
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
By:
Daniel Kirshblum, Esq.
Attorneys for Defendants
NYCHA and NYCHA Triborough Preservation
Development
1133 Westchester Avenue
White Plains, NY 10604
(914)-872-7267
File No.: 06985.00095
TO: SUBIN & ASSOCIATES, LLP
Attorneys for Plaintiff
23rd
150 Broadway, Floor
New York, NY 10038
(212) 285-3800
264219621v.1
2 of 4
FILED: KINGS COUNTY CLERK 02/22/2022 05:50 PM INDEX NO. 512147/2020
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/22/2022
AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
) ss.:
COUNTY OF WESTCHESTER )
ANDREA O'BRIEN, being duly sworn, deposes and says that deponent is not a party to
the within action, is over 18 years of age and has a business address in the State of New York,
County of Westchester.
9th
That on the day of December, 2021, deponent served the within SUPPLEMENTAL
DEMAND FOR DISCOVERY AND INSPECTION upon:
SUBIN & ASSOCIATES, LLP
23d
150 Broadway, Floor
New York, NY 10038
the attorney(s) for the respective parties in this action, at the above address(es) designated by
said attorney(s) for that purpose by depositing same enclosed in a postpaid properly addressed
wrapper, in an official depository under the exclusive care an custody of the United States Post
Office within the State of New York.
ANDREA O'B N
Sworn to before me this
9th 2021.
day of December,
Notary Public
MARGARET D. MENDEZ
Notary Public,Stateof New York
No. 01VA5088715
in Westchester
Qualified County
Commission ExpiresFebruary 22, 20
8478612v.1 3 of 4
FILED: Index KINGS
No.: COUNTY
153798/2016 CLERK 02/22/2022 05:50 PM INDEX
Daniel
NO.
Kirshblum
512147/2020
NYSCEF DOC. NO. 49 RECEIVED NYSCEF:
o6985.00095 02/22/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
MAGLENY F. MENDEZ,
Plaintiff,
-against-
THE NEW YORK CITY HOUSING AUTHORITY, NEW
YORK CITY HOUSING AUTHORITY TRIBOROUGH
PRESERVATION DEVELOPMENT and NEW
YORK CITY COUNSEL FOR HOUSING DEVELOPMENT
FUND COMPANIES,
Defendants.
SUPPLEMENTAL DEMAND FOR DISCOVERY & INSPECTION
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
Attorneys For
Defendants New York City Housing Authority and New York City
Housing Authority Triborough Preservation Developnient
1133 westchester Avenue
White Plains, NY 1o604-3407
- 7000
(914) 323
5897428v.1
4 of 4
Preview
FILED: KINGS COUNTY CLERK 02/22/2022 05:50 PM INDEX NO. 512147/2020 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/22/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK __-_____-__________________-____--------------__-_______-----------X MAGLENY F. MENDEZ, Index No.: 153798/2016 Plaintiff(s), SUPPLEMENTAL - against - DEMAND FOR DISCOVERY AND NEW YORK CITY HOUSING AUTHORITY, INSPECTION NEW YORK CITY HOUSING AUTHORITY TRIBOROUGH PRESERVATION DEVELOPMENT and NEW YORK CITY COUNCIL FOR HOUSING DEVELOPMENT FUND COMPANIES, Defendants. -----------------------------------------------------------------x PLEASE TAKE NOTICE that defendants, New York City Housing Authority and New York City Housing Authority Triborough Preservation and Development, by and through their attorneys, WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER, LLP, hereby demand that the Plaintiff provide to said attorneys at 1133 Westchester Avenue, White Plains, NY 10604, within 20 1. Duly executed and HIPAA compliant authorization for the release of plaintiff's records from Lincoln Hospital. 2. Duly executed and HIPAA compliant authorization for the release of plaintiff's records from any other hospital at which she treated as a result of the subject accident. 3. Courtesy copies of the medical records of Lincoln Hospital. PLEASE TAKE FURTHER NOTICE that Responding Defendants reserve the right to supplement and/or amend this response should such information become available. 264 219621v.1 1 of 4 FILED: KINGS COUNTY CLERK 02/22/2022 05:50 PM INDEX NO. 512147/2020 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/22/2022 Dated: White Plains, New York December 8, 2021 Yours, etc., WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP By: Daniel Kirshblum, Esq. Attorneys for Defendants NYCHA and NYCHA Triborough Preservation Development 1133 Westchester Avenue White Plains, NY 10604 (914)-872-7267 File No.: 06985.00095 TO: SUBIN & ASSOCIATES, LLP Attorneys for Plaintiff 23rd 150 Broadway, Floor New York, NY 10038 (212) 285-3800 264219621v.1 2 of 4 FILED: KINGS COUNTY CLERK 02/22/2022 05:50 PM INDEX NO. 512147/2020 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/22/2022 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) ) ss.: COUNTY OF WESTCHESTER ) ANDREA O'BRIEN, being duly sworn, deposes and says that deponent is not a party to the within action, is over 18 years of age and has a business address in the State of New York, County of Westchester. 9th That on the day of December, 2021, deponent served the within SUPPLEMENTAL DEMAND FOR DISCOVERY AND INSPECTION upon: SUBIN & ASSOCIATES, LLP 23d 150 Broadway, Floor New York, NY 10038 the attorney(s) for the respective parties in this action, at the above address(es) designated by said attorney(s) for that purpose by depositing same enclosed in a postpaid properly addressed wrapper, in an official depository under the exclusive care an custody of the United States Post Office within the State of New York. ANDREA O'B N Sworn to before me this 9th 2021. day of December, Notary Public MARGARET D. MENDEZ Notary Public,Stateof New York No. 01VA5088715 in Westchester Qualified County Commission ExpiresFebruary 22, 20 8478612v.1 3 of 4 FILED: Index KINGS No.: COUNTY 153798/2016 CLERK 02/22/2022 05:50 PM INDEX Daniel NO. Kirshblum 512147/2020 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: o6985.00095 02/22/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK MAGLENY F. MENDEZ, Plaintiff, -against- THE NEW YORK CITY HOUSING AUTHORITY, NEW YORK CITY HOUSING AUTHORITY TRIBOROUGH PRESERVATION DEVELOPMENT and NEW YORK CITY COUNSEL FOR HOUSING DEVELOPMENT FUND COMPANIES, Defendants. SUPPLEMENTAL DEMAND FOR DISCOVERY & INSPECTION WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP Attorneys For Defendants New York City Housing Authority and New York City Housing Authority Triborough Preservation Developnient 1133 westchester Avenue White Plains, NY 1o604-3407 - 7000 (914) 323 5897428v.1 4 of 4