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SUPREME COURT OF THE STATE OF NEW YORK Index No.: 504273/2017
COUNTY OF KINGS
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ROBERT ZABORSKI, EXPERT WITNESS
Plaintiff, DISCLOSURE PURSUANT
TO CPLR§ 3101(d)
-against-
MB LORIMER LLC and CORNERSTONE
BUILDERS NY LLC,
Defendants.
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CORNERSTONE BUILDERS NY LLC,
Third-Party Plaintiff,
-against-
NEW YORK BUILDER OF STAIRS, INC.
Third-Party Defendants.
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C O U N S E L:
PLEASE TAKE NOTICE, that plaintiff, ROBERT ZABORSKI, through his attorneys,
THE PLATTA LAW FIRM, PLLC, as for his expert witness disclosure pursuant to CPLR 3101(d),
state as follows:
1. Plaintiff hereby designates Avraham Schweiger, Ph.D., as an expert in the field of
Neuropsychology. The curriculum vitae of Avraham Schweiger, Ph.D is attached hereto as
“Exhibit A”.
SUBSTANCE OF FACTS AND GROUNDS OF OPINIONS
2. The substance of facts and opinions that constitute grounds for expert’s opinion
and/or opinion will be based upon the doctor’s experience and expertise, their review of the
medical records of plaintiff’s treating physicians including, but not limited to, reports of treatment
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from hospitals, clinics, and treatment centers, and/or medical facilities of any kind, operative
reports, and radiological and other studies, and their oral and physical examinations of the plaintiff.
He will also rely on the testimony and documents introduced into evidence at the time of trial.
THE SUBJECT MATTER OF TESTIMONY
3. Avraham Schweiger, Ph.D. may opine as to the causation, severity, extent, and
permanence of plaintiff’s injuries – both from the accident itself, as well, as from the necessary
treatment that followed – as well as necessary future treatment. In addition, Avraham
Schweiger, Ph.D. will testify concerning the natural flowing sequel of the injuries, notes, reports,
memorandum, records and submissions, prognosis for plaintiff, and fees that may have been
incurred by her in the past or in the future regarding treatment of these injuries. Avraham
Schweiger, Ph.D. will also offer testimony to refute the testimony and opinions of defendants’
expert herein. Further details as to the subject matter on which Avraham Schweiger, Ph.D. will
testify are contained in his treating notes, report, Future Care Consideration report, copies of which
are annexed hereto as “Exhibit B.” Avraham Schweiger, Ph.D’s narrative report will be provided
under separate cover.
PLEASE TAKE FURTHER NOTICE that the plaintiff reserves the right to amend or
supplement this response, at any time up to and including the trial of this action.
Dated: New York, New York
December 27, 2022
THE PLATTA LAW FIRM, PLLC
Howard Frederick
By: Howard G. Frederick
Attorneys for Plaintiff(s)
42 Broadway, Suite 1927
New York, New York 10004
212-514-5100
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TO:
TRAUB LIEBERMAN STRAUS & SHREWSBERRY LLP
Attorneys for Defendant/Third-Party Plaintiff
CORNERSTONE BUILDERS NY LLC
7 Skyline Dr
Hawthorne, NY 10532
PILLINGER MILLER TARALLO, LLP
Attorneys for Third-Party Defendant
NEW YORK BUILDERS OF STAIRS, INC.
232 Madison Avenue, Suite 909
New York, NY 10016
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EXHIBIT “A”
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EXHIBIT “B”
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FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 SUPREME COURT OF THE STATE OF NEW YORK Index No.: 504273/2017 COUNTY OF KINGS --------------------------------------------------------------------------X ROBERT ZABORSKI, EXPERT WITNESS Plaintiff, DISCLOSURE PURSUANT TO CPLR§ 3101(d) -against- MB LORIMER LLC and CORNERSTONE BUILDERS NY LLC, Defendants. -------------------------------------------------------------------------X CORNERSTONE BUILDERS NY LLC, Third-Party Plaintiff, -against- NEW YORK BUILDER OF STAIRS, INC. Third-Party Defendants. --------------------------------------------------------------------------X C O U N S E L: PLEASE TAKE NOTICE, that plaintiff, ROBERT ZABORSKI, through his attorneys, THE PLATTA LAW FIRM, PLLC, as for his expert witness disclosure pursuant to CPLR 3101(d), state as follows: 1. Plaintiff hereby designates Avraham Schweiger, Ph.D., as an expert in the field of Neuropsychology. The curriculum vitae of Avraham Schweiger, Ph.D is attached hereto as “Exhibit A”. SUBSTANCE OF FACTS AND GROUNDS OF OPINIONS 2. The substance of facts and opinions that constitute grounds for expert’s opinion and/or opinion will be based upon the doctor’s experience and expertise, their review of the medical records of plaintiff’s treating physicians including, but not limited to, reports of treatment 1 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 from hospitals, clinics, and treatment centers, and/or medical facilities of any kind, operative reports, and radiological and other studies, and their oral and physical examinations of the plaintiff. He will also rely on the testimony and documents introduced into evidence at the time of trial. THE SUBJECT MATTER OF TESTIMONY 3. Avraham Schweiger, Ph.D. may opine as to the causation, severity, extent, and permanence of plaintiff’s injuries – both from the accident itself, as well, as from the necessary treatment that followed – as well as necessary future treatment. In addition, Avraham Schweiger, Ph.D. will testify concerning the natural flowing sequel of the injuries, notes, reports, memorandum, records and submissions, prognosis for plaintiff, and fees that may have been incurred by her in the past or in the future regarding treatment of these injuries. Avraham Schweiger, Ph.D. will also offer testimony to refute the testimony and opinions of defendants’ expert herein. Further details as to the subject matter on which Avraham Schweiger, Ph.D. will testify are contained in his treating notes, report, Future Care Consideration report, copies of which are annexed hereto as “Exhibit B.” Avraham Schweiger, Ph.D’s narrative report will be provided under separate cover. PLEASE TAKE FURTHER NOTICE that the plaintiff reserves the right to amend or supplement this response, at any time up to and including the trial of this action. Dated: New York, New York December 27, 2022 THE PLATTA LAW FIRM, PLLC Howard Frederick By: Howard G. Frederick Attorneys for Plaintiff(s) 42 Broadway, Suite 1927 New York, New York 10004 212-514-5100 2 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 TO: TRAUB LIEBERMAN STRAUS & SHREWSBERRY LLP Attorneys for Defendant/Third-Party Plaintiff CORNERSTONE BUILDERS NY LLC 7 Skyline Dr Hawthorne, NY 10532 PILLINGER MILLER TARALLO, LLP Attorneys for Third-Party Defendant NEW YORK BUILDERS OF STAIRS, INC. 232 Madison Avenue, Suite 909 New York, NY 10016 3 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 EXHIBIT “A” 4 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 5 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 6 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 7 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 8 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 9 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 12/27/2022 10 of 314 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. 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