Preview
FILED: KINGS COUNTY CLERK 07/06/2021 01:22 PM INDEX NO. 515277/2018
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/06/2021
Kiernan Trebach LLP
40 Exchange Place
Suite 1600
New York, NY 10005
T: (212) 268-7535
F: (212) 268-4965
KiernanTrebach.com
July 6, 2021
Via Email & NYSCEF E-Filing:
Steven Labell
Steve Labell, Esq.
Oresky & Associates, PLLC
149 East 149th Street
Bronx, New York 10451
Re: Antonio Espinosa v. Mac 60, LLC and Royal Home
Improvements, Inc. v. Gilmar Design
Supreme Court, Kings County Index No.: 515277/2018
KT File Number: 1989.0016
Dear Counsel:
As you know, this office represents defendants/third-party plaintiffs, MAC 60 and Royal
Home Improvements, Inc. in the above-referenced matter.
Pursuant to our prior demands and correspondences dated May 22, 2020; November 30,
2020; and Supplemental Demand for Authorizations dated December 2, 2021 and the recent
Final Compliance Conference Order signed by Justice Knipel on June 21, 2021, kindly provide
us with HIPAA compliant executed and acknowledged authorizations made out to Kiernan
Trebach LLP, bearing plaintiff’s name, Social Security number, Date of Birth, and address,
including, where applicable, authority to speak with/interview each medical provider pursuant to
Arons v. Jutkowitz, 880 N.E. 2d 831 (2007) for the following:
1. Dr. J. DaSilva;
2. Dr. Gonzalez (who treated plaintiff in Dr. DaSilva’s office;
3. Dr. Jason Brown – Center for Cognitive and Communication;
4. Dr. Aric Hausknecht (we were unable to process the authorization we
received for Aric Hausknecht, M.D. because the address contained in the
authorization your office provided was no longer an active address for Dr.
Hausknecht; please provide us with an updated authorization containing Dr.
Hausknecht’s current address, which we believe to be 69-15 Austin Street,
CONNECTICUT | DISTRICT OF COLUMBIA | FLORIDA | MARYLAND | MASSACHUSETTS | NEW JERSEY | NEW YORK | PENNSYLVANIA | RHODE ISLAND | VIRGINIA
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FILED: KINGS COUNTY CLERK 07/06/2021 01:22 PM INDEX NO. 515277/2018
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/06/2021
Steve Labell, Esq.
July 6, 2021
Page 2
Forest Hills, NY 11375; if this address is incorrect, please provide us with an
authorization bearing the current correct address for Dr. Hausknecht);
5. Alpha 3-T MRI;
6. Dr. David Alan - Be Well Primary Health Care Center;
7. Injured Workers Pharmacy (IWP)(pharmacy records);
8. Coney Island Hospital
9. Jerusalem Glatt Meat (employment records);
10. Avenue J Fish Center (employment records);
11. Complete non-privileged legal file maintained by Finkelstein, Meirowitz &
Eidlisz, 11 Park Pl 15th floor, New York, NY 10007 related to Plaintiff’s
Workers’ Compensation Claim;
12. Complete non-privileged legal file maintained by Pyrros & Serresirowitz &
Eidlisz, 31-19 Newtown Avenue, 5th Floor, Astoria, NY 11102 related
to Plaintiff’s Workers’ Compensation Claim; and
13. Authorization to obtain plaintiff’s IRS Federal Income Tax returns for 2020
(plaintiff testified he obtained an ITN number and began filing tax returns in
2020).
Additionally, kindly provide copies of the following records:
1. Copy of plaintiff’s W-2 for 2019 and 2020 in plaintiff’s possession;
2. Copy of plaintiff’s 2020 IRS federal income tax return in plaintiff’s
possession.
Please be advised that the authorizations provided by your office under your cover letter
dated May 6, 2021 were made returnable to our former firm, Havkins Rosenfeld Ritzert, LLP.
We are unable to process any authorizations made returnable to our prior firm. The
authorizations being requested must be made out to Kiernan Trebach LLP at the address
reflected by the above letterhead.
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FILED: KINGS COUNTY CLERK 07/06/2021 01:22 PM INDEX NO. 515277/2018
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/06/2021
Steve Labell, Esq.
July 6, 2021
Page 3
Thank you in advance for your anticipated cooperation in this matter. Please contact me
should you have any questions or concerns.
Very truly yours,
Gail L. Ritzert, Esq.
cc: Via Email & NYSCEF E-filing: Richard Polner
Richard B. Polner, Esq.
Rawle & Henderson, LLP
14 Wall Street, 27th Floor
New York, NY 10005
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Preview
FILED: KINGS COUNTY CLERK 07/06/2021 01:22 PM INDEX NO. 515277/2018 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/06/2021 Kiernan Trebach LLP 40 Exchange Place Suite 1600 New York, NY 10005 T: (212) 268-7535 F: (212) 268-4965 KiernanTrebach.com July 6, 2021 Via Email & NYSCEF E-Filing: Steven Labell Steve Labell, Esq. Oresky & Associates, PLLC 149 East 149th Street Bronx, New York 10451 Re: Antonio Espinosa v. Mac 60, LLC and Royal Home Improvements, Inc. v. Gilmar Design Supreme Court, Kings County Index No.: 515277/2018 KT File Number: 1989.0016 Dear Counsel: As you know, this office represents defendants/third-party plaintiffs, MAC 60 and Royal Home Improvements, Inc. in the above-referenced matter. Pursuant to our prior demands and correspondences dated May 22, 2020; November 30, 2020; and Supplemental Demand for Authorizations dated December 2, 2021 and the recent Final Compliance Conference Order signed by Justice Knipel on June 21, 2021, kindly provide us with HIPAA compliant executed and acknowledged authorizations made out to Kiernan Trebach LLP, bearing plaintiff’s name, Social Security number, Date of Birth, and address, including, where applicable, authority to speak with/interview each medical provider pursuant to Arons v. Jutkowitz, 880 N.E. 2d 831 (2007) for the following: 1. Dr. J. DaSilva; 2. Dr. Gonzalez (who treated plaintiff in Dr. DaSilva’s office; 3. Dr. Jason Brown – Center for Cognitive and Communication; 4. Dr. Aric Hausknecht (we were unable to process the authorization we received for Aric Hausknecht, M.D. because the address contained in the authorization your office provided was no longer an active address for Dr. Hausknecht; please provide us with an updated authorization containing Dr. Hausknecht’s current address, which we believe to be 69-15 Austin Street, CONNECTICUT | DISTRICT OF COLUMBIA | FLORIDA | MARYLAND | MASSACHUSETTS | NEW JERSEY | NEW YORK | PENNSYLVANIA | RHODE ISLAND | VIRGINIA 1 of 3 FILED: KINGS COUNTY CLERK 07/06/2021 01:22 PM INDEX NO. 515277/2018 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/06/2021 Steve Labell, Esq. July 6, 2021 Page 2 Forest Hills, NY 11375; if this address is incorrect, please provide us with an authorization bearing the current correct address for Dr. Hausknecht); 5. Alpha 3-T MRI; 6. Dr. David Alan - Be Well Primary Health Care Center; 7. Injured Workers Pharmacy (IWP)(pharmacy records); 8. Coney Island Hospital 9. Jerusalem Glatt Meat (employment records); 10. Avenue J Fish Center (employment records); 11. Complete non-privileged legal file maintained by Finkelstein, Meirowitz & Eidlisz, 11 Park Pl 15th floor, New York, NY 10007 related to Plaintiff’s Workers’ Compensation Claim; 12. Complete non-privileged legal file maintained by Pyrros & Serresirowitz & Eidlisz, 31-19 Newtown Avenue, 5th Floor, Astoria, NY 11102 related to Plaintiff’s Workers’ Compensation Claim; and 13. Authorization to obtain plaintiff’s IRS Federal Income Tax returns for 2020 (plaintiff testified he obtained an ITN number and began filing tax returns in 2020). Additionally, kindly provide copies of the following records: 1. Copy of plaintiff’s W-2 for 2019 and 2020 in plaintiff’s possession; 2. Copy of plaintiff’s 2020 IRS federal income tax return in plaintiff’s possession. Please be advised that the authorizations provided by your office under your cover letter dated May 6, 2021 were made returnable to our former firm, Havkins Rosenfeld Ritzert, LLP. We are unable to process any authorizations made returnable to our prior firm. The authorizations being requested must be made out to Kiernan Trebach LLP at the address reflected by the above letterhead. 2 of 3 FILED: KINGS COUNTY CLERK 07/06/2021 01:22 PM INDEX NO. 515277/2018 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/06/2021 Steve Labell, Esq. July 6, 2021 Page 3 Thank you in advance for your anticipated cooperation in this matter. Please contact me should you have any questions or concerns. Very truly yours, Gail L. Ritzert, Esq. cc: Via Email & NYSCEF E-filing: Richard Polner Richard B. Polner, Esq. Rawle & Henderson, LLP 14 Wall Street, 27th Floor New York, NY 10005 3 of 3