Preview
FILED: QUEENS COUNTY CLERK 07/25/2022 03:47 PM INDEX NO. 721838/2021
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 07/25/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
GEORGE FOY,,
Plaintiff(s)
POST EBT
- against - DEMAND FOR DISCOVERY
JAMES MICHAEL SHAW AND GAIL Index No.: 721838/2021
RAVENELL,,
Defendant(s)
PLEASE TAKE NOTICE that pursuant to the applicable Rules, you are hereby required to
serve the following upon the undersigned within twenty (20) days after receipt of this notice:
IN LIGHT OF THE RECENT TESTIMONY OF THE PLAINTIFF PLEASE PROVIDE THE
FOLLOWING:
A. Duly unrestricted executed current and acknowledged authorization enabling FERRO &
STENZ to obtain employment records, including but not limited to attendance records,
employment application, W-2, physical limitations and any medical or nurse’s file from two
years prior to date of loss until present, from LaserShip.
B. Duly executed, current and acknowledged IRS Form 4506 (including two forms of
identification-at least one having a photograph with signature), thereby enabling THE
LAW OFFICE OF MICHAEL FERRO & ASSOCIATES tatives to obtain copies of
plaintiff’s tax returns for 2019; 2020 and 2021.
C. Identify the complete names and addresses together with HIPAA Compliant unrestricted
authorizations enabling THE LAW OFFICE OF MICHAEL FERRO & ASSOCIATES
to obtain all applicable records from the following:
• Plaintiff’s back doctor;
• Plaintiff’s back surgeon (he testified these were two separate doctors);
• Plaintiff’s pain management doctor;
• Facility where plaintiff had medical clearance;
• First physical therapy facility where plaintiff went after the accident located in
Brooklyn;
• Plaintiff’s primary care provider
D. Please provide information regarding plaintiff’s medical lien, including the amounts the
plaintiff will claim as lawful liens against the plaintiff’s recovery
E. Duly executed, current and acknowledged authorizations enabling THE LAW OFFICE
OF MICHAEL FERRO & ASSOCIATES to obtain all records, photograph(s) and
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FILED: QUEENS COUNTY CLERK 07/25/2022 03:47 PM INDEX NO. 721838/2021
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 07/25/2022
video(s) to include email address(es) associated with the account, username/handle from the
following social networking accounts:
â–ª Twitter
â–ª Facebook
â–ª MySpace
â–ª Instagram
â–ª Vine
â–ª Snapfish
â–ª Linkedin
• If Plaintiff does not have any of the above accounts provide an affidavit from Plaintiff
stating same.
• If Plaintiff does not have any of the above social networking account presently and have not
had such for two years to the date of loss, but have had an account in the past, provide an
affidavit to that effect.
PLEASE TAKE FURTHER NOTICE that this is a continuing demand and should any of
the above requested information become available to or known in the future, you are then required
to furnish same at such time.
DATED: Melville, New York
July 11, 2022
Yours, etc.
_______________________________________
Rachel Goldberg, Esq.
The Law Office of Michael Ferro & Associates
Attorneys for Defendant(s)
James M. Shaw
2 Huntington Quadrangle, STE 2N01
Melville, New York 11747
516-229-4268
855-641-4102
rgoldberg@geico.com
Our File Number: 21-0136144
Claim Number: 0140838630101025 ()
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FILED: QUEENS COUNTY CLERK 07/25/2022 03:47 PM INDEX NO. 721838/2021
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 07/25/2022
TO:
The Dearie Law Firm, P.C.
Attorneys for Plaintiff(s)
George Foy
515 Madison Ave., 16th Floor,
New York, New York 10022
212-980-0404
Connors & Connors, P.C.
Attorneys for Co-Defendants(s)
Gail Ravenell
766 Castleton Avenue,
Staten Island, NY 10310
718-442-1700
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FILED: QUEENS COUNTY CLERK 07/25/2022 03:47 PM INDEX NO. 721838/2021
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 07/25/2022
Index No.: 721838/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
GEORGE FOY,,
Plaintiff(s)
- against -
DEMAND FOR DISCOVERY
JAMES MICHAEL SHAW AND GAIL
RAVENELL,,
Defendant(s)
The Law Office of Michael Ferro & Associates
Attorneys for the Defendant(s)
James M. Shaw
2 Huntington Quadrangle, STE 2N01
Melville, New York 11747
516-229-4268
------------------------------------------------------------------------------------------------------------------------
TO:
The Dearie Law Firm, P.C. Connors & Connors, P.C.
Attorneys for Plaintiff(s) Attorneys for Co-Defendants(s)
George Foy Gail Ravenell
515 Madison Ave., 16th Floor, 766 Castleton Avenue,
New York, New York 10022 Staten Island, NY 10310
212-980-0404 718-442-1700
------------------------------------------------------------------------------------------------------------------------
Due and timely service of a copy of the within ______________________ is hereby admitted.
Dated July 11, 2022
Attorney(s) for Defendant(s) James M. Shaw
------------------------------------------------------------------------------------------------------------------------
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Preview
FILED: QUEENS COUNTY CLERK 07/25/2022 03:47 PM INDEX NO. 721838/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 07/25/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS GEORGE FOY,, Plaintiff(s) POST EBT - against - DEMAND FOR DISCOVERY JAMES MICHAEL SHAW AND GAIL Index No.: 721838/2021 RAVENELL,, Defendant(s) PLEASE TAKE NOTICE that pursuant to the applicable Rules, you are hereby required to serve the following upon the undersigned within twenty (20) days after receipt of this notice: IN LIGHT OF THE RECENT TESTIMONY OF THE PLAINTIFF PLEASE PROVIDE THE FOLLOWING: A. Duly unrestricted executed current and acknowledged authorization enabling FERRO & STENZ to obtain employment records, including but not limited to attendance records, employment application, W-2, physical limitations and any medical or nurse’s file from two years prior to date of loss until present, from LaserShip. B. Duly executed, current and acknowledged IRS Form 4506 (including two forms of identification-at least one having a photograph with signature), thereby enabling THE LAW OFFICE OF MICHAEL FERRO & ASSOCIATES tatives to obtain copies of plaintiff’s tax returns for 2019; 2020 and 2021. C. Identify the complete names and addresses together with HIPAA Compliant unrestricted authorizations enabling THE LAW OFFICE OF MICHAEL FERRO & ASSOCIATES to obtain all applicable records from the following: • Plaintiff’s back doctor; • Plaintiff’s back surgeon (he testified these were two separate doctors); • Plaintiff’s pain management doctor; • Facility where plaintiff had medical clearance; • First physical therapy facility where plaintiff went after the accident located in Brooklyn; • Plaintiff’s primary care provider D. Please provide information regarding plaintiff’s medical lien, including the amounts the plaintiff will claim as lawful liens against the plaintiff’s recovery E. Duly executed, current and acknowledged authorizations enabling THE LAW OFFICE OF MICHAEL FERRO & ASSOCIATES to obtain all records, photograph(s) and 1 of 4 FILED: QUEENS COUNTY CLERK 07/25/2022 03:47 PM INDEX NO. 721838/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 07/25/2022 video(s) to include email address(es) associated with the account, username/handle from the following social networking accounts: ▪ Twitter ▪ Facebook ▪ MySpace ▪ Instagram ▪ Vine ▪ Snapfish ▪ Linkedin • If Plaintiff does not have any of the above accounts provide an affidavit from Plaintiff stating same. • If Plaintiff does not have any of the above social networking account presently and have not had such for two years to the date of loss, but have had an account in the past, provide an affidavit to that effect. PLEASE TAKE FURTHER NOTICE that this is a continuing demand and should any of the above requested information become available to or known in the future, you are then required to furnish same at such time. DATED: Melville, New York July 11, 2022 Yours, etc. _______________________________________ Rachel Goldberg, Esq. The Law Office of Michael Ferro & Associates Attorneys for Defendant(s) James M. Shaw 2 Huntington Quadrangle, STE 2N01 Melville, New York 11747 516-229-4268 855-641-4102 rgoldberg@geico.com Our File Number: 21-0136144 Claim Number: 0140838630101025 () 2 of 4 FILED: QUEENS COUNTY CLERK 07/25/2022 03:47 PM INDEX NO. 721838/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 07/25/2022 TO: The Dearie Law Firm, P.C. Attorneys for Plaintiff(s) George Foy 515 Madison Ave., 16th Floor, New York, New York 10022 212-980-0404 Connors & Connors, P.C. Attorneys for Co-Defendants(s) Gail Ravenell 766 Castleton Avenue, Staten Island, NY 10310 718-442-1700 3 of 4 FILED: QUEENS COUNTY CLERK 07/25/2022 03:47 PM INDEX NO. 721838/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 07/25/2022 Index No.: 721838/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS GEORGE FOY,, Plaintiff(s) - against - DEMAND FOR DISCOVERY JAMES MICHAEL SHAW AND GAIL RAVENELL,, Defendant(s) The Law Office of Michael Ferro & Associates Attorneys for the Defendant(s) James M. Shaw 2 Huntington Quadrangle, STE 2N01 Melville, New York 11747 516-229-4268 ------------------------------------------------------------------------------------------------------------------------ TO: The Dearie Law Firm, P.C. Connors & Connors, P.C. Attorneys for Plaintiff(s) Attorneys for Co-Defendants(s) George Foy Gail Ravenell 515 Madison Ave., 16th Floor, 766 Castleton Avenue, New York, New York 10022 Staten Island, NY 10310 212-980-0404 718-442-1700 ------------------------------------------------------------------------------------------------------------------------ Due and timely service of a copy of the within ______________________ is hereby admitted. Dated July 11, 2022 Attorney(s) for Defendant(s) James M. Shaw ------------------------------------------------------------------------------------------------------------------------ 4 of 4