Preview
FILED: KINGS COUNTY CLERK 05/20/2021 07:31 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/20/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------x Index No.: 519726/2018
MARTHE MILIUS,
Plaintiff, SECOND SUPPLEMENTAL
VERIFIED BILL
OF PARTICULARS
-against-
ISABELLE CHARLES,
Defendants.
-------------------------------------------------------------------x
Plaintiff MARTHE MILIUS, as and for her second supplemental verified bill of
particulars, by his attorneys HARMON, LINDER & ROGOWSKY, respectfully sets forth and
alleges as follows:
10. Plaintiff MARTHE MILIUS underwent the following procedures:
â–ª EPIDURAL STEROID INJECTION TO THE LUMBAR SPINE ON
9/14/16
â–ª EPIDURAL STEROID INJECTION TO THE LUMBAR SPINE ON
9/28/16
â–ª LUMBAR FACET BLOCK OF THE MEDIAL BRANCH OF THE
DORSAL RAMI AT L3-L4, L4-L5, AND L5-S1
• BILATERAL LUMBAR FACET JOINT INJECTION UNDER
FLUOROSCOPY (previously identified as LUMBAR FACET JOINT
INJECTION UNDER FLUROSCOPY)
• LEFT HIP JOINT INJECTION UNDER FLUOROSCOPY
Plaintiff sustained the following injuries:
• DISC HERNIATION AT THE L5-S1 IMPINGING THE THECAL SAC AND
BILATERAL S1 NERVE ROOTS (previously identified as DISC
1 of 3
FILED: KINGS COUNTY CLERK 05/20/2021 07:31 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/20/2021
HERNIATION AT THE L5-S1)
• RIGHT PERONEAL NERVE ENTRAPMENT AT THE FIBULAR HEAD
• BILATERAL LUMBOSACRAL RADICULOPATHIES AT THE S1
LEVEL
â–ª ASIDE FROM THE NEW INJURIES, PLAINTIFF ALSO SUFFERED
AN EXACERBATION OF INJURIES FROM A PRIOR MOTOR
VEHICLE ACCIDENT ON 5/13/16
The above have resulted in pain, tenderness, weakness, discomfort, aching,
restriction of motion, numbness, stiffness, atrophy, insomnia, deformity, the possible need for
future surgery, spasm, stiffness, impairment of function, soft tissue injury, swelling partial and
permanent loss of use of the both ankles, and trunk area and, as a result, the entire body. The
plaintiff also was and is required to take medication, with other side effects. In addition, this
plaintiff was required to undergo painful and uncomfortable testing, casting, and treatment and
therapy, and have suffered curtailment of a great many activities. Upon information and belief, all
of the above injuries and/or their residuals, except those of a superficial nature, are of a permanent
nature.
Dated: New York, New York
May 20, 2021
Yours etc.,
HARMON, LINDER & ROGOWSKY
Attorneys for Plaintiffs
3 Park Ave, Suite 2300
New York, New York 10016
(212) 732-3665
MJL/am
2 of 3
FILED: KINGS COUNTY CLERK 05/20/2021 07:31 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/20/2021
TO: SILVERMAN, SHIN & BYRNE, PLLC
Attorney(s)for Defendant(s)
ISABELLE CHARLES
Wall Street Plaza
88 Pine Street, 22nd Floor
New York, New York 10005
(212) 779-8600
3 of 3
Preview
FILED: KINGS COUNTY CLERK 05/20/2021 07:31 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------x Index No.: 519726/2018 MARTHE MILIUS, Plaintiff, SECOND SUPPLEMENTAL VERIFIED BILL OF PARTICULARS -against- ISABELLE CHARLES, Defendants. -------------------------------------------------------------------x Plaintiff MARTHE MILIUS, as and for her second supplemental verified bill of particulars, by his attorneys HARMON, LINDER & ROGOWSKY, respectfully sets forth and alleges as follows: 10. Plaintiff MARTHE MILIUS underwent the following procedures: ▪ EPIDURAL STEROID INJECTION TO THE LUMBAR SPINE ON 9/14/16 ▪ EPIDURAL STEROID INJECTION TO THE LUMBAR SPINE ON 9/28/16 ▪ LUMBAR FACET BLOCK OF THE MEDIAL BRANCH OF THE DORSAL RAMI AT L3-L4, L4-L5, AND L5-S1 • BILATERAL LUMBAR FACET JOINT INJECTION UNDER FLUOROSCOPY (previously identified as LUMBAR FACET JOINT INJECTION UNDER FLUROSCOPY) • LEFT HIP JOINT INJECTION UNDER FLUOROSCOPY Plaintiff sustained the following injuries: • DISC HERNIATION AT THE L5-S1 IMPINGING THE THECAL SAC AND BILATERAL S1 NERVE ROOTS (previously identified as DISC 1 of 3 FILED: KINGS COUNTY CLERK 05/20/2021 07:31 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/20/2021 HERNIATION AT THE L5-S1) • RIGHT PERONEAL NERVE ENTRAPMENT AT THE FIBULAR HEAD • BILATERAL LUMBOSACRAL RADICULOPATHIES AT THE S1 LEVEL ▪ ASIDE FROM THE NEW INJURIES, PLAINTIFF ALSO SUFFERED AN EXACERBATION OF INJURIES FROM A PRIOR MOTOR VEHICLE ACCIDENT ON 5/13/16 The above have resulted in pain, tenderness, weakness, discomfort, aching, restriction of motion, numbness, stiffness, atrophy, insomnia, deformity, the possible need for future surgery, spasm, stiffness, impairment of function, soft tissue injury, swelling partial and permanent loss of use of the both ankles, and trunk area and, as a result, the entire body. The plaintiff also was and is required to take medication, with other side effects. In addition, this plaintiff was required to undergo painful and uncomfortable testing, casting, and treatment and therapy, and have suffered curtailment of a great many activities. Upon information and belief, all of the above injuries and/or their residuals, except those of a superficial nature, are of a permanent nature. Dated: New York, New York May 20, 2021 Yours etc., HARMON, LINDER & ROGOWSKY Attorneys for Plaintiffs 3 Park Ave, Suite 2300 New York, New York 10016 (212) 732-3665 MJL/am 2 of 3 FILED: KINGS COUNTY CLERK 05/20/2021 07:31 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/20/2021 TO: SILVERMAN, SHIN & BYRNE, PLLC Attorney(s)for Defendant(s) ISABELLE CHARLES Wall Street Plaza 88 Pine Street, 22nd Floor New York, New York 10005 (212) 779-8600 3 of 3