Preview
FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017
NYSCEF DOC. NO. 140 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:
QUALIFICATION OF THE EXPERT
Plaintiff hereby designates Kornelia Teslic, M.D., as an expert in the field of radiology in
this matter. The curriculum vitae of Kornelia Teslic, M.D. is annexed hereto as Exhibit A.
THE SUBJECT MATTER OF TESTIMONY
The subject matter of Kornelia Teslic, M.D’s testimony includes, without limitation,
opinions and findings based on the review of Plaintiff’s radiological studies and medical records
as fully described in the report, a copy of which will be provided under separate cover.
1 of 8
FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017
NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022
In addition, Kornelia Teslic, M.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 Plaintiff in the past or in the future regarding treatment of
these injuries and the casual relationship, to the accident of July 18, 2016.
THE SUBSTANCE OF THE FACTS AND OPINIONS
The substance of facts and opinions and grounds for said expert's opinion will be based upon
her examination of Plaintiff’s radiographic films, review of Plaintiff’s EBT transcripts, medical
records, review of documents provided by the Plaintiff, as well as those records previously
exchanged, and all documents introduced into evidence at the time of trial.
Dr. Kornelia Teslic, M.D. will also offer testimony to refute the testimony and
opinions of defendants’ experts herein. Further details as to the subject matter on which
Dr. Kornelia Teslic, M.D. will testify are contained in the report, report, a copy of which
will be provided under separate cover.
PLEASE TAKE FURTHER NOTICE, that Plaintiff reserves the right to
supplement and amend her disclosure up to and including the time of trial.
Dated: New York, New York
December 23, 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 8
FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017
NYSCEF DOC. NO. 140 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 8
FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017
NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022
EXHIBIT “A”
4 of 8
FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017
NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022
KORNELIA TESLIC, M.D.
Neuroradiologist
The Bonati Spine Institute
7315 Hudson Ave, Hudson, FL 34667
Ph cell: 813-577-2416
Ph office: 727-868-9563 extension 3504
kornelia.teslic@bonati.com
Clinical Expertise:
Neuroradiology Brain and Spine imaging
Head and Neck Oncology imaging
MRI, PET/CT
Brain DTI/NeuroQuant TBI
Certifications:
Diplomate American Board of Radiology, 06/01/1999.
Senior Member American Society of Neuroradiology, 06/01/2015.
American Society of Head and Neck Radiology, 06/01/2012.
Memorial Sloan-Kettering Cancer Center Alumni Society Member.
Licensure:
NYS License MD 212855 issued 4/30/1994: status active
California License AFE73590 issued 12/07/2000: status passive
Pennsylvania License MD423514 issued 1/14/2004: status passive
Florida License ME146759: status active
Postdoctoral training:
Fellowship in Neuroradiology 1998 - 1999.
Weill Cornell/ New York-Presbyterian and MSKCC.
New York, NY
Fellowship in PET and Nuclear Medicine 1994 -1995.
Memorial Sloan- Kettering Cancer Center, New York, NY
Residency in Diagnostic Radiology 1995 -1998.
New York Medical College, Valhalla, New York.
Transitional Internship 1993 -1994.
Jefferson Frankford Hospital, Philadelphia, PA
Medical School, University of Novi Sad
5 of 8
FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017
NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022
Novi Sad, Yugoslavia, 1984 -1991.
Work Experience:
Alpha 3T MRI Diagnostic Imaging Consultants, P.L.L.C.
Neuroradiology Consultant for TBI MRI/NeuroQuant
145 East 32nd St, New York, New York 10016
7/1/1999 - 7/1/2012
Premier Imaging Consultants Teleradiology Corporation, P.L.L.C.
Neuroradiologist and Diagnostic Radiologist
85 Secor Road, Scarsdale, New York
9/11/2001-7/1/2012
Personal Health Imaging, P.L.L.C.
Diagnostic Radiologist and Neuroradiologist
d/b/a Rockland Diagnostic Imaging
d/b/a Greenpoint Diagnostic Imaging
d/b/a Allium Diagnostic Imaging
d/b/a Upright Imaging of Westchester
260 Route 303 North
West Nyack, New York 10994
Ph 845-353-0400
Fax 845-353-5563
7/1/2012-4/1/2020
The Bonati Spine Institute, Golf Coast Orthopedic Imaging
Neuroradiologist, Chief of Neuroradiology, Gulf Coast Orthopedic Center
11/1/2020 – Present
Medical Liability Insurance:
Physician Reciprocal Ins. policy # 38384-00-00
Limits of Liability $1,000,000 per claim $3,000,000 annual aggregate.
No claims history.
Publications and Presentations:
“Clinical Impact of In-111 Pentetreotide imaging in the Management of patients
Neuroendocrine Tumors” H.Macapinlac, S.J.Goldsmith, K.Teslic, S.M.Larson, The
Journal of Nuclear Medicine 36:127.1996.
“Easy to Make Phantoms for Teaching Interventional Breast Procedures”.
K.Teslic, R.J.Stack,S.Klein, Association of University Radiologists, 45th Annual
Meeting, Dallas, TX,1997.
6 of 8
FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017
NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022
“Application of MRI in Patients with Neurologic and Hepatic Form of Wilson
Diseases” K.Teslic, D.Kozic , The Scientific Meeting of the International Society of MRI
in Medicine, Philadelphia, PA,1999.
Languages:
English, Spanish conversational, Croatian & Serbian native and bilingual.
7 of 8
FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017
NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------------------X Index No.: 504273/2017
ROBERT ZABORSKI,
Plaintiff,
-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
PLAINTIFF’S EXPERT WITNESS DISCLOSURE PURSUANT TO CPLR 3101(d)
THE PLATTA LAW FIRM, PLLC
Attorneys for: Plaintiff(s)
42 Broadway, Suite 1927
New York, New York 10004
(212) 514-5100
The undersigned attorney hereby certifies, pursuant to 22 NYCRR 130-1.1-a that he/she has read the
within papers and that same are not frivolous as that term is defined in 22 NYCRR 130-1.1(c).
Howard Frederick
Howard Frederick, Esq.
Service of a copy of the within _______________________________________ is hereby admitted.
Dated, _________________
Attorney(s) for_____________________
PLEASE TAKE NOTICE:
NOTICE OF ENTRY
that the within is a (certified) true copy of an Order duly entered in the office of the clerk of the
within named court on __________________20___.
NOTICE OF SETTLEMENT
that an Order of which the within is a true copy will be presented for settlement to the Honorable
Justice __________________________ one of the judges of the within named Court, on 20___
at________ O’clock ___.M.
Dated: December 23, 2022 Yours, etc.
THE PLATTA LAW FIRM, PLLC
8 of 8
Preview
FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 140 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: QUALIFICATION OF THE EXPERT Plaintiff hereby designates Kornelia Teslic, M.D., as an expert in the field of radiology in this matter. The curriculum vitae of Kornelia Teslic, M.D. is annexed hereto as Exhibit A. THE SUBJECT MATTER OF TESTIMONY The subject matter of Kornelia Teslic, M.D’s testimony includes, without limitation, opinions and findings based on the review of Plaintiff’s radiological studies and medical records as fully described in the report, a copy of which will be provided under separate cover. 1 of 8 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022 In addition, Kornelia Teslic, M.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 Plaintiff in the past or in the future regarding treatment of these injuries and the casual relationship, to the accident of July 18, 2016. THE SUBSTANCE OF THE FACTS AND OPINIONS The substance of facts and opinions and grounds for said expert's opinion will be based upon her examination of Plaintiff’s radiographic films, review of Plaintiff’s EBT transcripts, medical records, review of documents provided by the Plaintiff, as well as those records previously exchanged, and all documents introduced into evidence at the time of trial. Dr. Kornelia Teslic, M.D. will also offer testimony to refute the testimony and opinions of defendants’ experts herein. Further details as to the subject matter on which Dr. Kornelia Teslic, M.D. will testify are contained in the report, report, a copy of which will be provided under separate cover. PLEASE TAKE FURTHER NOTICE, that Plaintiff reserves the right to supplement and amend her disclosure up to and including the time of trial. Dated: New York, New York December 23, 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 8 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 140 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 8 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022 EXHIBIT “A” 4 of 8 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022 KORNELIA TESLIC, M.D. Neuroradiologist The Bonati Spine Institute 7315 Hudson Ave, Hudson, FL 34667 Ph cell: 813-577-2416 Ph office: 727-868-9563 extension 3504 kornelia.teslic@bonati.com Clinical Expertise: Neuroradiology Brain and Spine imaging Head and Neck Oncology imaging MRI, PET/CT Brain DTI/NeuroQuant TBI Certifications: Diplomate American Board of Radiology, 06/01/1999. Senior Member American Society of Neuroradiology, 06/01/2015. American Society of Head and Neck Radiology, 06/01/2012. Memorial Sloan-Kettering Cancer Center Alumni Society Member. Licensure: NYS License MD 212855 issued 4/30/1994: status active California License AFE73590 issued 12/07/2000: status passive Pennsylvania License MD423514 issued 1/14/2004: status passive Florida License ME146759: status active Postdoctoral training: Fellowship in Neuroradiology 1998 - 1999. Weill Cornell/ New York-Presbyterian and MSKCC. New York, NY Fellowship in PET and Nuclear Medicine 1994 -1995. Memorial Sloan- Kettering Cancer Center, New York, NY Residency in Diagnostic Radiology 1995 -1998. New York Medical College, Valhalla, New York. Transitional Internship 1993 -1994. Jefferson Frankford Hospital, Philadelphia, PA Medical School, University of Novi Sad 5 of 8 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022 Novi Sad, Yugoslavia, 1984 -1991. Work Experience: Alpha 3T MRI Diagnostic Imaging Consultants, P.L.L.C. Neuroradiology Consultant for TBI MRI/NeuroQuant 145 East 32nd St, New York, New York 10016 7/1/1999 - 7/1/2012 Premier Imaging Consultants Teleradiology Corporation, P.L.L.C. Neuroradiologist and Diagnostic Radiologist 85 Secor Road, Scarsdale, New York 9/11/2001-7/1/2012 Personal Health Imaging, P.L.L.C. Diagnostic Radiologist and Neuroradiologist d/b/a Rockland Diagnostic Imaging d/b/a Greenpoint Diagnostic Imaging d/b/a Allium Diagnostic Imaging d/b/a Upright Imaging of Westchester 260 Route 303 North West Nyack, New York 10994 Ph 845-353-0400 Fax 845-353-5563 7/1/2012-4/1/2020 The Bonati Spine Institute, Golf Coast Orthopedic Imaging Neuroradiologist, Chief of Neuroradiology, Gulf Coast Orthopedic Center 11/1/2020 – Present Medical Liability Insurance: Physician Reciprocal Ins. policy # 38384-00-00 Limits of Liability $1,000,000 per claim $3,000,000 annual aggregate. No claims history. Publications and Presentations: “Clinical Impact of In-111 Pentetreotide imaging in the Management of patients Neuroendocrine Tumors” H.Macapinlac, S.J.Goldsmith, K.Teslic, S.M.Larson, The Journal of Nuclear Medicine 36:127.1996. “Easy to Make Phantoms for Teaching Interventional Breast Procedures”. K.Teslic, R.J.Stack,S.Klein, Association of University Radiologists, 45th Annual Meeting, Dallas, TX,1997. 6 of 8 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022 “Application of MRI in Patients with Neurologic and Hepatic Form of Wilson Diseases” K.Teslic, D.Kozic , The Scientific Meeting of the International Society of MRI in Medicine, Philadelphia, PA,1999. Languages: English, Spanish conversational, Croatian & Serbian native and bilingual. 7 of 8 FILED: KINGS COUNTY CLERK 12/27/2022 04:12 PM INDEX NO. 504273/2017 NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/27/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------------X Index No.: 504273/2017 ROBERT ZABORSKI, Plaintiff, -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 PLAINTIFF’S EXPERT WITNESS DISCLOSURE PURSUANT TO CPLR 3101(d) THE PLATTA LAW FIRM, PLLC Attorneys for: Plaintiff(s) 42 Broadway, Suite 1927 New York, New York 10004 (212) 514-5100 The undersigned attorney hereby certifies, pursuant to 22 NYCRR 130-1.1-a that he/she has read the within papers and that same are not frivolous as that term is defined in 22 NYCRR 130-1.1(c). Howard Frederick Howard Frederick, Esq. Service of a copy of the within _______________________________________ is hereby admitted. Dated, _________________ Attorney(s) for_____________________ PLEASE TAKE NOTICE: NOTICE OF ENTRY that the within is a (certified) true copy of an Order duly entered in the office of the clerk of the within named court on __________________20___. NOTICE OF SETTLEMENT that an Order of which the within is a true copy will be presented for settlement to the Honorable Justice __________________________ one of the judges of the within named Court, on 20___ at________ O’clock ___.M. Dated: December 23, 2022 Yours, etc. THE PLATTA LAW FIRM, PLLC 8 of 8