Motion to Amend in Debra Jeronimo v. City Of New York, Lutheran Medicalcenter, Nyu Langone Hospitals, Consolidated Edison, Inc.| Trellis.Law

On December 24, 2020 a No Value was filed involving a dispute between Debra Jeronimo, and City Of New York, Consolidated Edison, Inc., Lutheran Medicalcenter, Nyu Langone Hospitals, for Torts - Other (Trip and Fall) in the District Court of Kings County.

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FILED: KINGS COUNTY CLERK 03/01/2023 02:32 PM INDEX NO. 525864/2020
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 03/01/2023

JPC:cg SUPREME COURT OF THE STATE OF NEW YORK
03/01/23
COUNTY OF KINGS
DEBRA JERONIMO, INDEX NO.
525864/20
Plaintiff,

- against - VERIFIED ANSWER TO
AMENDED COMPLAINT
CITY OF NEW YORK, LUTHERAN MEDICAL CENTER, and AND CROSS-COMPLAINT
NYU LANGONE HOSPITALS, and CONSOLIDATED
EDISON, INC.,

Defendants.

The defendant, Consolidated Edison Company of New York, Inc. s/h/a

Consolidated Edison, Inc. (hereinafter “Consolidated Edison Company of New York, Inc.”), by

its attorney, Lauren A. Jones, answering the amended complaint, alleges:

FIRST: Denies knowledge or information sufficient to form a belief as to the

allegations contained in paragraphs “1”, “2”, “3”, “4”, “5”, “6”, “7”, “8”, “9”, “10”, “11”, “12”,

“13”, “14”, “15”, “16”, “17”, “18”, “19”, “20”, “21”, “22”, “23”, “24”, “25”, “26”, “34”, “35”, “36”,

“37”, “38”, “39”, “40”, “41”, “42”, “43”, “44”, “45”, “46”, “47”, “48”, “49”, “50”, “51”, “52”, “53”,

“54”, “55”, “56”, “57”, “63”, “65”, and “66”.

SECOND: Denies the allegations contained in paragraph “29”.

THIRD: Denies knowledge or information sufficient to form a belief as to the

allegations contained in paragraph “32“ and “33”, except admits defendant, Consolidated Edison

Company of New York, Inc., was and still is a domestic corporation, duly organized and existing

under the Transportation Corporations Law of the State of New York, was and still is engaged in

the generation, distribution and sale of electric energy to its customers in New York City and

Westchester County, and was and still is a gas and electric corporation subject to the Public Service

Our File #:
2023-000832
FN2047630

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Law of the State of New York and to the jurisdiction of the Public Service Commission of the State

of New York.

FOURTH: Denies upon information and belief each allegation in paragraphs

“58”, “59”, “60”, “61”, “62”, and “64”.

AS TO THE FIRST ALLEGED CAUSE OF ACTION:

FIFTH: Repeats each denial made of the allegations contained in all prior

paragraphs and repeated in paragraph “67”.

SIXTH: Denies knowledge or information sufficient to form a belief as to the

allegations contained in paragraphs “68”, “69”, “70”, “71”, “72”, “73”, “74”, “75”, “76”, “77”,

“78”, and “80”.

SEVENTH: Denies upon information and belief each allegation in paragraph

“79”.

AS TO THE SECOND ALLEGED CAUSE OF ACTION:

EIGHTH: Repeats each denial made of the allegations contained in all prior

paragraphs and repeated in paragraph “81”.

NINTH: Denies knowledge or information sufficient to form a belief as to the

allegations contained in paragraphs “82”, “83”, “84”, “85”, “86”, “87”, “88”, “89”, “90”, “91”,

“92”, and “94”.

TENTH: Denies upon information and belief each allegation in paragraph “93”.

AS TO THE THIRD ALLEGED CAUSE OF ACTION:

ELEVENTH: Repeats each denial made of the allegations contained in all prior

paragraphs and repeated in paragraph “95”.

Our File #:
2023-000832
FN2047630

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TWELFTH: Denies knowledge or information sufficient to form a belief as to the

allegations contained in paragraphs “96”, “97”, “98”, “99”, “100”, “101”, “102”, “103”, “104”,

“105”, “106”, and “108”.

THIRTEENTH: Denies upon information and belief each allegation in paragraph

“107”.

AS TO THE FOURTH ALLEGED CAUSE OF ACTION:

FOURTEENTH: Repeats each denial made of the allegations contained in all

prior paragraphs and repeated in paragraph “109”.

FIFTEENTH: Denies upon information and belief each allegation in paragraphs

“110”, “111”, “112”, “113”, “114”, “115”, “116”, “117”, “118”, “119”, “120”, “121”, and “122”.

AS TO THE ALLEGATIONS AS TO ALL DEFENDANTS:

SIXTEENTH: Repeats each denial made of the allegations contained in all prior

paragraphs and repeated in paragraph “123”.

SEVENTEENTH: Denies knowledge or information sufficient to form a belief as

to the allegations contained in paragraph “124” and refers all questions of law to the Court.

EIGHTEENTH: Denies knowledge or information sufficient to form a belief as to

the allegations contained in paragraph “125”.

AS A FIRST AFFIRMATIVE DEFENSE:

NINETEENTH: Any injuries or damages which the plaintiff sustained were

caused in whole or in part by the plaintiff's negligence.

Our File #:
2023-000832
FN2047630

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AS A SECOND, SEPARATE, AND COMPLETE DEFENSE TO
THE ALLEGED CAUSES OF ACTION, THE DEFENDANT,
CONSOLIDATED EDISON COMPANY OF NEW YORK,
INC., ALLEGES, UPON INFORMATION AND BELIEF:

TWENTIETH: That the defendant, Consolidated Edison Company of New York,

Inc., is a New York corporation engaged in the sale and distribution of electricity, gas and steam

under franchises. All work performed or equipment installed at the times mentioned in the

amended complaint was pursuant to the rights granted by law and the permission or license of

the proper municipal authorities.

AS AND FOR A THIRD AFFIRMATIVE DEFENSE TO THE ENTIRE
AMENDED COMPLAINT, THIS ANSWERING DEFENDANT ALLEGES:

TWENTY-FIRST: That if any liability is found as against this answering

defendant, then said liability will constitute 50% or less of the total liability assigned to all

persons liable and, as such, the liability of this answering defendant to plaintiff for non-

economic loss shall be limited and shall not exceed this answering defendant’s equitable share,

as provided in Article 16 of the CPLR.

AS A FOURTH AFFIRMATIVE DEFENSE:

TWENTY-SECOND: To the extent plaintiff releases or otherwise settles with any

other person/entity relative to the alleged injuries/damages in this action, answering defendant

will be entitled to have any claim for damages asserted against it reduced to the extent

permitted by operation of New York General Obligations Law Section 15-108 or any other

applicable law.

Our File #:
2023-000832
FN2047630

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IF JUDGMENT IS RENDERED AGAINST CONSOLIDATED
EDISON COMPANY OF NEW YORK, INC., IT ALLEGES UPON
INFORMATION AND BELIEF, AS A CROSS-COMPLAINT
AGAINST THE DEFENDANTS, CITY OF NEW YORK, LUTHERAN
MEDICAL CENTER, AND NYU LANGONE HOSPITALS:

TWENTY-THIRD: That any liability to the plaintiff against the defendant,

Consolidated Edison Company of New York, Inc., will have arisen in whole or in part out of the

negligent acts of the defendants, CITY OF NEW YORK, LUTHERAN MEDICAL CENTER, and

NYU LANGONE HOSPITALS, its/their respective agents, and/or employees, and that

defendant, Consolidated Edison Company of New York, Inc., are entitled to be indemnified in

whole or in part by CITY OF NEW YORK, LUTHERAN MEDICAL CENTER, and NYU

LANGONE HOSPITALS, for the amount of any verdict or judgment which may be recovered

against it.

WHEREFORE, Consolidated Edison Company of New York, Inc., demand

judgment dismissing the amended complaint with costs and disbursements, and further demand

judgment against defendants, CITY OF NEW YORK, LUTHERAN MEDICAL CENTER, and NYU

LANGONE HOSPITALS, for all or part of any judgment recovered against it.

Dated: New York, New York
March 1, 2023.
LAUREN A. JONES

By:______________________________
John P. Campana, Esq.
Attorney for Defendant
Consolidated Edison Company
of New York, Inc. s/h/a
Consolidated Edison, Inc.
Address:
4 Irving Place, Room 1800
New York, NY 10003-3598

Our File #:
2023-000832
FN2047630

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RIDER

TO:

LAW OFFICES OF
MICHAEL S. LAMONSOFF, PLLC
Attorneys for Plaintiff
Financial Square at 32 Old Slip – 8th Floor
New York, NY 10005

SYLVIA HINDS-RADIX, ESQ.
Corporation Counsel
Attorney for Defendant
CITY OF NEW YORK
100 Church Street, 4th Floor
New York, NY 10007

HEIDELL, PITTONI, MURPHY & BACH, LLP
Attorneys for Defendants
NYU LANGONE HOSPITAL and
LUTHERAN MEDICAL CENTER
99 Park Avenue
New York, NY 10005

Our File #:
2023-000832
FN2047630

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VERIFICATION

STATE OF NEW YORK )
) SS.:
COUNTY OF KINGS )

Scott A. Levinson, an attorney duly authorized to practice in the State of New York

who is not a party to this action and an officer of Consolidated Edison Company of New

York, Inc., affirms under penalty of perjury that that the foregoing is true to his knowledge

except as to the matters therein stated to be alleged upon information and belief, and that

as to those matters, he believes them to be true. The grounds for his belief as to all matters

not stated upon personal knowledge are the books and records of the corporation.

Scott A. Levinson, Esq.
Vice President
Consolidated Edison Company of New York,
Inc.

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LAUREN A. JONES
Attorney For
Consolidated Edison Company of New York, Inc.
s/h/a Consolidated Edison, Inc.
4 Irving Place
New York, NY 10003
Tel. No. (212) 460-3355

Counselors:

Enclosed herein is Consolidated Edison Company of New York, Inc.’s:

◼ Demand for a Verified Bill of Particulars
◼ Demand for Medical and Employment Records and Authorizations
◼ Notice for Discovery and Inspection for Medicare or Medicaid Liens
❑ Notice for Discovery and Inspection
◼ Combined Demand
◼ Notice for Discovery and Inspection of Plaintiff
◼ Notice for Discovery and Inspection of The City of New York
❑ Third Party Notice for Discovery and Inspection
◼ Notice of Discovery and Inspection for Collateral Source Reimbursement
◼ Demand for Expert Witness Information
◼ Notice of Consent to Accept Service by Email on this Case
◼ Notice to Take Deposition Upon Oral Questions
❑ Notice for Discovery and Inspection for Reimbursement for
Property Damage
❑ First Notice to Produce Documents
❑ Demand for Insurance and Claim File Information
❑ Demand Pursuant to CPLR 2103(e)
◼ Insurance Disclosure Pursuant to 3101(f)
❑ _______________________________________________

The undersigned certifies that to the best of my knowledge, information and belief that,
as presented, served and/or filed, they are not frivolous as defined in Section 130-1.1(a)
and (c) of the Rules of the Chief Administrator of the Courts (22 N.Y.C.R.R.)

Very truly yours,

Lauren A. Jones

By: ______________________________
170290 John P. Campana, Esq.

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JPC:cg
03/01/23
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
DEBRA JERONIMO, INDEX NO.
525864/20
Plaintiff,

- against - DEMAND FOR A
VERIFIED BILL
CITY OF NEW YORK, LUTHERAN MEDICAL CENTER, OF PARTICULARS
and NYU LANGONE HOSPITALS, and
CONSOLIDATED EDISON, INC.,

Defendants.

COUNSELORS:

PLEASE TAKE NOTICE, that pursuant to CPLR §§3041, 3042, 3043, and

3044, you are required to serve the attorney for defendant, Consolidated Edison

Company of New York, Inc. s/h/a Consolidated Edison, Inc., at 4 Irving Place, New

York, NY 10003, within thirty (30) days after service of this demand, a Verified Bill of

Particulars, setting forth the following:

1. Plaintiff's date of birth, Social Security Number, and residence.

2. Is the plaintiff Medicare eligible?

3. Has the plaintiff applied for or received any Medicare payments in
connection with the injury alleged in this lawsuit?

4. The date and approximate time of the occurrence.

5. The approximate location of the occurrence.

6. A general description of the occurrence.

7. A statement of the acts or omissions constituting each defendant's
negligence.

8. A detailed description of the defect that caused the occurrence.
Our File #:
2023-000832
FN2047630

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9. Whether actual or constructive notice is claimed.

10. The facts supporting any claim of actual notice of a defect,
including:

(a) The date or dates of each notice.

(b) The names of the agents or employees of the defendant
receiving notice.

(d) The precise language of the notice.

(e) The form of the notice (oral or written).

11. The facts supporting any claim of constructive notice, including the
length of time the condition existed prior to the occurrence.

12. Any statute, ordinance, or regulation violated by the defendant.

13. The names and addresses of all witnesses.

14. The nature and duration of each injury.

15. The length of time plaintiff was confined to (a) hospital, (b) bed,
and (c) home.

16. The cost of: (a) hospital, (b) medical, (c) X-rays, (d) nurses, (e)
medicines, (f) medical supplies, and (g) any other medical
expenses.

17. The dollar value of other damages, item by item.

18. Plaintiff's occupation, name and address of employer, dates absent
from employment, and amount of lost earnings. If a student, name
and address of school, grade and dates absent.

a) the method of calculation used to derive any and all lost
earnings claimed; and

Our File #:
2023-000832
FN2047630

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b) the name and address of any entity, carrier, or organization
providing plaintiff with compensation for any lost earnings
claimed, including, but not limited to No Fault
compensation and Workers Compensation.

19. State whether or not plaintiff has been reimbursed for claims of
economic loss from any collateral source and, if so, set forth:

a) the amount of reimbursement received and the name and
addresses of the person, firm or organization from whom
such reimbursement was received; and,

b) if such reimbursement was made by an insurance company,
state the number of the policy under which it was paid.

20. State whether or not plaintiff has made a claim for reimbursement
for economic loss to any collateral source and said claim has not as
yet been paid and, if so, set forth:

a) the name and address of the person, corporation or
organization to whom such claim was presented, the date of
presentation and the amount claimed; and

b) if such reimbursement was presented to an insurance
company, state the policy number under which it was made.

Dated: New York, New York
March 1, 2023.

Yours, etc.,

LAUREN A. JONES
Attorney for Defendant
Consolidated Edison Company
of New York, Inc. s/h/a
Consolidated Edison, Inc.
4 Irving Place, Room 1800
New York, NY 10003-3598

Our File #:
2023-000832
FN2047630

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TO:

LAW OFFICES OF
MICHAEL S. LAMONSOFF, PLLC
Attorneys for Plaintiff
Financial Square at 32 Old Slip – 8th Floor
New York, NY 10005

Our File #:
2023-000832
FN2047630

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JPC:cg
03/01/23
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
DEBRA JERONIMO, INDEX NO.
525864/20
Plaintiff,
NOTICE FOR DISCOVERY
- against - AND INSPECTION FOR
MEDICARE OR
CITY OF NEW YORK, LUTHERAN MEDICAL CENTER, MEDICAID LIENS
and NYU LANGONE HOSPITALS, and
CONSOLIDATED EDISON, INC.,

Defendants.

PLEASE TAKE NOTICE, that pursuant to Article 31 of the CPLR, you are

hereby required to produce at the offices of Lauren A. Jones, the attorney for the

defendant, Consolidated Edison Company of New York, Inc. s/h/a Consolidated

Edison, Inc., within thirty (30) days, the following documents, items and information

for discovery, inspection and/or copying:

1. A statement as to whether the plaintiff has received benefits from

Medicaid, Medicare or any Medicare insurance program at any time, for any reason, not

limited to the injuries alleged in the instant action.

Please state and/or provide:

a. Plaintiff’s full name;

b. Plaintiff’s gender;

c. Plaintiff’s date of birth;

d. Plaintiff’s Social Security number;

e. Is plaintiff enrolled in Medicare Part D?

f. Is plaintiff enrolled in Medicare Part B?

Our File #:
2023-000832
FN2047630

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g. Plaintiff’s residence telephone number;

h. The Health Insurance Claim Number, Medicare/Medicaid file
number, New York State Department of Social Services (“DSS”) file
number, and/or Medicare Secondary Payor (“MSP”) file number, if
applicable;

i. A copy of the plaintiff’s health insurance (Medicare) card;

j. The address of the office handling the plaintiff’s
Medicare/Medicaid claims and/or benefits;

k. A duly executed and notarized written authorization fully
compliant with the Health Insurance Portability and Accountability
Act of 1996 (“HIPAA”) and regulations applicable thereto and
expiring no less than six (6) months after the date of signature, and
bearing plaintiff’s date of birth and Social Security number
permitting this firm and/or the representatives of defendant to
obtain copies of plaintiff’s Medicaid records;

l. A duly executed consent to release (see attached CMS form
“Consent to Release”
http://www.cms.gov/Medicare/Coordination-of-Benefits-And-
Recovery-Overview/Non-Group-Health-Plan-
Recovery/Downloads/Consent to Release.pdf), valid for at least
three (3) years, which permits this firm to obtain plaintiff’s
Medicare records and to communicate with Medicare and its
contractors (MSPRC or COBC);

m. Identify any ICD-9 codes reported to Medicare and/or its
contractors as alleged to be related to injuries sustained in the
incident which is the subject of this litigation.

2. State whether Medicare and/or Medicaid has a lien and the

amount of any such lien.

3. Provide copies of all documents, records, memoranda, notes, etc.,

in plaintiff’s possession pertaining to plaintiff’s receipt of Medicare and/or Medicaid

benefits, including copies of all documents provided to or received from the Medicare

and/or Medicaid administrators and/or contractors, including but not limited to:

Our File #:
2023-000832
FN2047630

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a. Case reporting correspondence to Medicare COBC (Coordination
of Benefits Contractor)

b. Rights and responsibilities letter;

c. Conditional payment letters;

d. Payment summary forms

e. Demand/Recovery letters

f. Final demand letters

4. Provide a copy of any claims summaries from Medicaid, Medicare

or any Medicare insurance program.

5. If plaintiff has not received Medicare and/or Medicaid benefits in

the past or is not receiving Medicare and/or Medicaid benefits now, state whether

plaintiff is eligible to receive Medicare and/or Medicaid benefits.

6. Has the plaintiff applied for Social Security Disability Benefits?

a. If so, when?

b. Was the application denied?

c. Is plaintiff appealing or re-filing for Social Security Disability
benefits?

7. Has plaintiff received dialysis treatment for kidney disease?

8. Has plaintiff received treatment for End-Stage Renal Disease?

9. If plaintiff has been receiving Medicare and/or Medicaid benefits

and is now deceased, please provide the following:

a. Relationship of the administrator of plaintiff’s estate to plaintiff’s
decedent;

b. Name and address of plaintiff’s administrator;

Our File #:
2023-000832
FN2047630

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c. Telephone number and/or e-mail address of plaintiff’s
administrator;

d. Social Security number of plaintiff’s administrator;

e. An authorization to examine and copy deceased’s Medicare and/or
Medicaid records.

PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR, this is a

continuing demand and that you are required to serve the demanded information

within thirty (30) days of the date of this demand.

PLEASE TAKE FURTHER NOTICE, that failure to comply with this

Demand for Medicare/Medicaid information may result in the necessity of a motion to

compel discovery accompanied by a request for the appropriate costs.

Dated: New York, New York
March 1, 2023

Yours, etc.,

LAUREN A. JONES
Attorney for Defendant
Consolidated Edison Company
of New York, Inc. s/h/a
Consolidated Edison, Inc.
4 Irving Place, Room 1800
New York, NY 10003-3598
TO:

LAW OFFICES OF
MICHAEL S. LAMONSOFF, PLLC
Attorneys for Plaintiff
Financial Square at 32 Old Slip – 8th Floor
New York, NY 10005

Our File #:
2023-000832
FN2047630

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CONSENT TO RELEASE

The language below should be used when you, a Medicare beneficiary, want to authorize
someone other than your attorney or other representative to receive information, including
identifiable health information, from the Centers for Medicare & Medicaid Services (CMS)
related to your liability insurance (including self-insurance), no-fault insurance or workers'
compensation claim.
I, (print your name exactly as shown on your Medicare card)
hereby authorize the CMS, its agents and/or contractors to release, upon request, information
related to my injury/illness and/or settlement for the specified date of injury/illness to the
individual and/or entity listed below:
CHECK ONLY ONE OF THE FOLLOWING TO INDICATE WHO MAY RECEIVE
INFORMATION AND THEN PRINT THE REQUESTED INFORMATION;
(If you intend to have your information released to more than one individual or entity, you must
complete a separate release for each one.)
( ) Insurance Company ( ) Workers' Compensation Carrier ( ) Other
(Explain)
Name of entity:

Contact for above entity:

Address:

Telephone:
CHECK ONE OF THE FOLLOWING TO INDICATE HOW LONG CMS MAY RELEASE YOUR
INFORMATION
(The period you check will run from when you sign and date below.):
( ) One Year ( ) Two Years ( ) Other
(Provide a specific period of time)

I understand that I may revoke this "consent to release information" at any time, in writing.

MEDICARE BENEFICIARY INFORMATION AND SIGNATURE:
Beneficiary Signature: ______Date signed: ______________________
Note: If the beneficiary is incapacitated, the submitter of this document will need to include documentation establishing the authority of the
individual signing on the beneficiary's behalf. Please visit http://go.cms.gov/cobro for further instructions.
Medicare Health Insurance claim Number (The number on your Medicare card.): _________________
Date of Injury/Illness: _________________

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JPC:cg
03/01/23
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
DEBRA JERONIMO, INDEX NO.
525864/20
Plaintiff,
DEMAND FOR
- against - MEDICAL AND
EMPLOYMENT
CITY OF NEW YORK, LUTHERAN MEDICAL CENTER, RECORDS AND
and NYU LANGONE HOSPITALS, and AUTHORIZATIONS
CONSOLIDATED EDISON, INC.,

Defendants.

COUNSELORS:

PLEASE TAKE NOTICE, that pursuant to CPLR Rule 3120, the

undersigned defendant herewith demands that you produce the authorizations

specified and for the discovery and inspection of the records demanded, with leave to

photocopy, at the office of the undersigned within twenty (20) days from the date

hereof the following:

a. Names and addresses and copies of any and all reports of those
physicians and health care providers who have treated and/or
examined plaintiff, DEBRA JERONIMO, and the names of all
prescriptions by those physicians and health care providers issued
to the examined plaintiff and the names and addresses of
pharmacies at which said prescriptions issued by the
aforementioned physicians and health care providers were filled, as
a result of any injury (including prior injury) to the part or parts of
the body allegedly injured as a result of the occurrence giving rise
to this litigation, including any and all diagnostic reports, and
ambulance call reports, and;

b. Duly executed and acknowledged written authorizations, fully
compliant with the Health Insurance Portability and Accountability
Act of 1996 (HIPAA) and the regulations applicable thereto and
expiring no less than six (6) months after the date of signature,

Our File #:
2023-000832
FN2047630

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permitting the undersigned or their representative to inspect and
obtain photostatic copies of the records, office charts, nurses' notes,
diagnostic studies, x-rays and any other records maintained by
plaintiff(s) insurer(s) and by those physicians and health care
facilities referred to in paragraph "a" above, and permitting the
undersigned or their representative to inspect and obtain
photostatic copies of all records of filled pharmacy prescriptions
identified and referred to in paragraph “a” above.

c. Duly executed and notarized written authorizations, fully
compliant with the Health Insurance Portability and Accountability
Act of 1996 (HIPAA) and the regulations applicable thereto and
expiring no less than six (6) months after the date of signature,
permitting the undersigned or their representative to inspect and
obtain photostatic copies of the records of any and all hospitals
wherein Plaintiff(s) was/were treated and/or confined, including
all x-ray reports.

d. Names and addresses of all insurance carriers, including disability,
no-fault, or workers compensation carriers who have received
claims and/or provided benefits to the plaintiff as a result of any
injury resulting from the occurrence giving rise to this litigation.

e. Duly executed and acknowledged written authorizations, fully
compliant with the Health Insurance Portability and Accountability
Act of 1996 (HIPAA) and the regulations applicable thereto and
expiring no less than six (6) months after the date of signature,
permitting the undersigned or their representative to inspect and
obtain photostatic copies of all insurance records and files
maintained by those carriers referred to in paragraph "d" above.

f. Duly executed and acknowledged written authorizations, fully
compliant with the Health Insurance Portability and Accountability
Act of 1996 (HIPAA) and the regulations applicable thereto and
expiring no less than six (6) months after the date of signature,
permitting the undersigned or their representative to inspect and
obtain photostatic copies of all workers compensation records and
files maintained either by those workers compensation carriers
referred to in paragraph "d" above or maintained by The Workers
Compensation Board.

g. Duly executed and acknowledged written authorizations, fully
compliant with the Health Insurance Portability and Accountability
Our File #:
2023-000832
FN2047630

19 of 42
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NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 03/01/2023

Act of 1996 (HIPAA) and the regulations applicable thereto and
expiring no less than six (6) months after the date of signature,
permitting the undersigned or his representative to inspect and
obtain photostatic copies of all employment records and files
maintained by plaintiff’s employer. If plaintiff is self-employed,
then written authorizations, fully compliant with the Health
Insurance Portability and Accountability Act of 1996 (HIPAA) and
the regulations applicable thereto and expiring no less than six (6)
months after the date of signature, permitting the undersigned or
their representative to inspect and obtain photostatic copies of
plaintiff’s IRS tax returns for the year of accident and two years
prior to the date of accident, including two forms of identification
customarily required by the IRS to obtain such records.

In lieu of appearing at the stated time and place, you may send by the

time required copies of the documents and a statement that you are furnishing them

pursuant to this notice.

PLEASE TAKE FURTHER NOTICE, that this demand shall be deemed to

continue during the pendency of this action, including the trial thereof. In the event of

refusal to comply with this demand, the defendant shall seek to preclude the testimony

of any parties in relation to the information and documentation sought herein.

Dated: New York, New York
March 1, 2023.

Yours, etc.,

LAUREN A. JONES
Attorney for Defendant
Consolidated Edison Company
of New York, Inc. s/h/a
Consolidated Edison, Inc.
4 Irving Place, Room 1800
New York, NY 10003-3598

Our File #:
2023-000832
FN2047630

20 of 42
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NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 03/01/2023

TO:

LAW OFFICES OF
MICHAEL S. LAMONSOFF, PLLC
Attorneys for Plaintiff
Financial Square at 32 Old Slip – 8th Floor
New York, NY 10005

Our File #:
2023-000832
FN2047630

21 of 42
FILED: KINGS COUNTY CLERK 03/01/2023 02:32 PM INDEX NO. 525864/2020
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 03/01/2023

JPC:cg
03/01/23
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
DEBRA JERONIMO, INDEX NO.
525864/20
Plaintiff,

- against - COMBINED
DEMAND
CITY OF NEW YORK, LUTHERAN MEDICAL CENTER,
and NYU LANGONE HOSPITALS, and
CONSOLIDATED EDISON, INC.,

Defendants.

COUNSELORS:

PLEASE TAKE NOTICE, that pursuant to CPLR Rule 3120, the

undersigned defendant herewith demands that all parties produce within twenty (20)

days at the Law Offices of Lauren A. Jones, located at 4 Irving Place, New York, NY

10003, the following information:

1. Set forth in writing the name and address of each witness to the

following:

Case Info

Judge

Kings Cdp22 Track Judge’s New Case

Case No.

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Document Filed Date

March 01, 2023

Case Filing Date

December 24, 2020

County

Parties

CAMPANA, JOHN PAUL Attorney for the Defendant
CHARDER, RYAN BOISVERT Attorney for the Plaintiff
CHEN, JEREMY PEI Attorney for the Defendant
CITY OF NEW YORK Defendant
CONSOLIDATED EDISON, INC. Defendant
Counsel, Corporation Attorney for the Defendant
Debra Jeronimo Plaintiff
KONG, PERRY H Attorney for the Plaintiff
LAMONSOFF, MICHAEL SCOTT Attorney for the Plaintiff
LUTHERAN MEDICALCENTER Defendant
NYU LANGONE HOSPITALS Defendant
THONUS, WILLIAM JOSEPH Attorney for the Plaintiff
SYLVIA HINDS-RADIX Attorneys for Defendants
SCOTT LEVINSON Attorney
JAMES JOHNSON Attorneys for Defendants
PAUL CHEN Attorney
BETH KIRSCHNER Attorney
RYAN SHARP Attorney
STACEY HASKEL Attorney
JASON LESNEVEC Attorney
MAYA KOGAN Attorney
MICHAEL ZOGALA Attorney
JAZMINE KENDRICK Attorney
JACOB TRAUB Attorney
DARREN MOORE Attorney
DAVID CARR Attorney
DEBORAH EDDY Attorney
JENNY XIA Attorney
VALERIE TSESARENKO Attorney
JOSHUA PERLMAN Attorney
JOSE SORIANO Attorney

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No Value: Debra Jeronimo v. City Of New York, Lutheran Medicalcenter, Nyu Langone Hospitals, Consolidated Edison, Inc.

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