Preview
FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018
NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023
EXHIBIT “C”
FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018
NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS Index No.: 703721/2018
THALIA AGATHOCLEOUS, SUPPLEMENTAL
EXPERT WITNESS
Plaintiff, DISCLOSURE
-against-
795 FIFTH AVENUE CORPORATION d/b/a THE
PIERRE and IHMS, LLC,
Defendants.
COUNSELOR:
Plaintiff, THALIA AGATHOCLEOUS, by her attorneys, Sacco & Fillas, LLP, as and for her
response to the demand of the defendant for expert witness information, discloses the following
in accordance with the provisions of Section 3101(d) of the Civil Practice Law and Rules:
1. Plaintiff designates Ali E. Guy, M.D., as a medical expert specializing in Physical
Medicine and Rehabilitation. Dr. Guy is licensed to practice medicine in the State of New
York and maintains an office for the practice of medicine at 7 Gramercy Park West, Suite
IA, New York, NY 10003.
2. The Expert's qualifications are set forth in the Curriculum Vitae of Ali E. Guy, M.D., is
annexed hereto as Exhibit "1."
3. The subject matter of Dr. Guy's testimony will be, in his expert opinion, that the injuries
sustained by plaintiff were a direct result of a slip and fall accident which occurred on
January 6, 2018. A copy of Dr. Guy's narrative report is annexed hereto as Exhibit "2".
4. The substance of the facts and opinions on which the doctor is expected to testify are
contained in the annexed report and such findings and evidence presented up to and
including the time of trial are within the expert's area of expertise.
SACCO & FILLAS, LLP
FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018
NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023
5. The grounds for expert's opinions, all of which will be based to a reasonable degree of
medical certainty based on the doctor's education, training, and experience, are set forth in
the annexed report, amended report/supplemental report/addendum, review of pleadings,
testimony provided at depositions, medical records/reports, diagnostic tests, diagnostic
films, review of the reports from the defendants' independent medical examinations of the
plaintiff, review of the reports from workers' compensation independent medical
examinations, photographs, public records and/or all discovery in this matter.
6. Dr. Guy may use such demonstrative aids at trial.
PLEASE TAKE NOTICE that Plaintiff reserves the right to supplement and/or amend
this response at any time prior to the trial of this action.
Dated: Astoria, New York
January 16, 2023
By: Russell T. McHugh, Esq.
SACCO & FILLAS, LLP
Attorneys for Plaintiff
31-19 Newtown Avenue
Seventh Floor
Astoria, New York 11102
(718) 746-3440
Our File No.: 20173-18
TO:
MCMAHON, MARTINE & GALLAGHER, LLP
Attorney for Defendant
795 Fifth Avenue Corporation
55 Washington Street, 7th Floor
Brooklyn, NY 11201
(212) 747-1230
SACCO & FILLAS, LLP
FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018
NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023
EXHIBIT '' 1 ''
FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018
NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023
..
CURRICULUM VITAE
ALIE. GUY,. M.D.
DIPLOMATE OF THE
AMERICAN BOARD OF PHYSICAL MEDICINE AND REHABILITATION
POSTGRADUATE TRAINING
PHYSICAL MEDICINE AND REHABILITATION January 1,198S
Mount Sinai School of Medicine, Mount Sinai Medical Center to December 31, 1987
NewYork,NY
INTERNAL MEDICINE J_uly I, 1984
Mount Sinai School of Medicine to December 31,1984
Veterans Administration Medical Center
Bronx,NY
SURGERY July 1, 1983
Cabrini Medical Center to June 30, 1984
NewYork Medical College
NewYork,NY
INTERNAL MEDICINE July 1, 1982
Mount Sinai School of Medicine to June 30, 1983
Veterans Administration Medical Center
Bi::onx,NY
EDUCATION.
UNIVERSIDAD NORDESTANA
DOMINICAN REPUBLIC
AWARDED DEGREE OF DOCTOR OF MEDICINE April 1979 to July 1981
UNIVERSIDAD CENTRAL DEL ESTE January 1978 to
DOMINICAN REPUBLIC April 1979
QUEENS COLLEGE January 1974 to
FLUSHING,NY October 1977
MEDICAL LICENSES AND CERTIFICATIONS
NEW YORK STATE LICENSE- 163001-1
PENNSYLVANIA STATE LICENSE - MD-0336440E
DIPLOMATE of The American Board of Physical Medicine and Rehabilitation-May.JO, 1989
WORKERS' COMPENSATION RATING - CPMR
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: . ...
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...
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FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018
NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023
CURRICULUM VITAE
Preview
FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018 NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023 EXHIBIT “C” FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018 NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No.: 703721/2018 THALIA AGATHOCLEOUS, SUPPLEMENTAL EXPERT WITNESS Plaintiff, DISCLOSURE -against- 795 FIFTH AVENUE CORPORATION d/b/a THE PIERRE and IHMS, LLC, Defendants. COUNSELOR: Plaintiff, THALIA AGATHOCLEOUS, by her attorneys, Sacco & Fillas, LLP, as and for her response to the demand of the defendant for expert witness information, discloses the following in accordance with the provisions of Section 3101(d) of the Civil Practice Law and Rules: 1. Plaintiff designates Ali E. Guy, M.D., as a medical expert specializing in Physical Medicine and Rehabilitation. Dr. Guy is licensed to practice medicine in the State of New York and maintains an office for the practice of medicine at 7 Gramercy Park West, Suite IA, New York, NY 10003. 2. The Expert's qualifications are set forth in the Curriculum Vitae of Ali E. Guy, M.D., is annexed hereto as Exhibit "1." 3. The subject matter of Dr. Guy's testimony will be, in his expert opinion, that the injuries sustained by plaintiff were a direct result of a slip and fall accident which occurred on January 6, 2018. A copy of Dr. Guy's narrative report is annexed hereto as Exhibit "2". 4. The substance of the facts and opinions on which the doctor is expected to testify are contained in the annexed report and such findings and evidence presented up to and including the time of trial are within the expert's area of expertise. SACCO & FILLAS, LLP FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018 NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023 5. The grounds for expert's opinions, all of which will be based to a reasonable degree of medical certainty based on the doctor's education, training, and experience, are set forth in the annexed report, amended report/supplemental report/addendum, review of pleadings, testimony provided at depositions, medical records/reports, diagnostic tests, diagnostic films, review of the reports from the defendants' independent medical examinations of the plaintiff, review of the reports from workers' compensation independent medical examinations, photographs, public records and/or all discovery in this matter. 6. Dr. Guy may use such demonstrative aids at trial. PLEASE TAKE NOTICE that Plaintiff reserves the right to supplement and/or amend this response at any time prior to the trial of this action. Dated: Astoria, New York January 16, 2023 By: Russell T. McHugh, Esq. SACCO & FILLAS, LLP Attorneys for Plaintiff 31-19 Newtown Avenue Seventh Floor Astoria, New York 11102 (718) 746-3440 Our File No.: 20173-18 TO: MCMAHON, MARTINE & GALLAGHER, LLP Attorney for Defendant 795 Fifth Avenue Corporation 55 Washington Street, 7th Floor Brooklyn, NY 11201 (212) 747-1230 SACCO & FILLAS, LLP FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018 NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023 EXHIBIT '' 1 '' FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018 NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023 .. CURRICULUM VITAE ALIE. GUY,. M.D. DIPLOMATE OF THE AMERICAN BOARD OF PHYSICAL MEDICINE AND REHABILITATION POSTGRADUATE TRAINING PHYSICAL MEDICINE AND REHABILITATION January 1,198S Mount Sinai School of Medicine, Mount Sinai Medical Center to December 31, 1987 NewYork,NY INTERNAL MEDICINE J_uly I, 1984 Mount Sinai School of Medicine to December 31,1984 Veterans Administration Medical Center Bronx,NY SURGERY July 1, 1983 Cabrini Medical Center to June 30, 1984 NewYork Medical College NewYork,NY INTERNAL MEDICINE July 1, 1982 Mount Sinai School of Medicine to June 30, 1983 Veterans Administration Medical Center Bi::onx,NY EDUCATION. UNIVERSIDAD NORDESTANA DOMINICAN REPUBLIC AWARDED DEGREE OF DOCTOR OF MEDICINE April 1979 to July 1981 UNIVERSIDAD CENTRAL DEL ESTE January 1978 to DOMINICAN REPUBLIC April 1979 QUEENS COLLEGE January 1974 to FLUSHING,NY October 1977 MEDICAL LICENSES AND CERTIFICATIONS NEW YORK STATE LICENSE- 163001-1 PENNSYLVANIA STATE LICENSE - MD-0336440E DIPLOMATE of The American Board of Physical Medicine and Rehabilitation-May.JO, 1989 WORKERS' COMPENSATION RATING - CPMR .. ...·· . .:· : . ... .. . ... . FILED: QUEENS COUNTY CLERK 01/19/2023 05:10 PM INDEX NO. 703721/2018 NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 01/19/2023 CURRICULUM VITAE