Preview
FILED: QUEENS COUNTY CLERK 05/24/2018 03:36 PM INDEX NO. 701912/2017
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 05/24/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
-------------------------------------------------------------X
PETRIT BICAJ, Index No.: 701912/17
Plaintiffs,
RESPONSE PURSUANT
-against- TO CPLR 5 3101(d)
BRADLEY JAMES BRONCATI, JLJ IV
ENTERPRISES, INC.,
Defendants.
-------------------------------------------------------------X
Defendants, BRADLEY JAMES BRONCATI AND JLJ IV ENTERPRISES,
INC. by their attorneys LAW OFFICE OF KEITH J. CONWAY, hereby make the
following response, pursuant to CPLR 3101(d):
1. The Defendants, BRADLEY JAMES BRONCATI AND JLJ IV
ENTERPRISES, have retained Dr. John A. Bendo, an Orthopedist, as an expert
witness. At the time of trial in the above entitled action, Dr. Bendo will testify
based upon his examination of plaintiff, Petrit Bicaj, on May 1, 2018, his review
of plaintiff's medical records and any records, testimony, evidence or films in
evidence at trial. Dr. Bendo will testify as to his expert medical opinion
concerning plaintiffs alleged injuries, their cause and connection with the
accident or lack thereof, and his diagnosis, prognosis and opinion concerning
plaintiffs claim of incapacity. Dr. Bendo may also testify in rebuttal to any
testimony provided by plaintiff and/or plaintiffs experts. Dr. Bendo may testify
concerning admissions or statements made by plaintiff during the course of the
examination.
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FILED: QUEENS COUNTY CLERK 05/24/2018 03:36 PM INDEX NO. 701912/2017
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 05/24/2018
2. The facts, upon which Dr. Bendo will testify, as well as the
grounds for his opinions, are set forth in said report, a copy of which is
annexed hereto.
3. A copy of Dr. Bendo's Curriculum Vitae is annexed hereto.
Defendants reserve the right to amend or supplement this Response at
any time up through and including the time of trial, pursuant to the CPLR and
Uniform Court Rules.
DATED: Melville, New York
May 24, 2018
YOURS, Etc.
LAW OFFICE OF KEITH J. CONWAY
Attorneys for Defendants
BRADLEY JAMES BRONCATI AND JLJ IV
ENTERPRISES, INC.
58 South Service Road, Suite 350
Melville, New York 11747
(631) 845-2600
TO: CHARLES C. DESTEFANO, ESQ.
Attorneys for Plaintiff(s)
1082 Victory Boulevard
Staten Island, New York 10301
718-390-0580
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FILED: QUEENS COUNTY CLERK 05/24/2018 03:36 PM INDEX NO. 701912/2017
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 05/24/2018
AFFIDAVIT OF SERVICE BY MAIL
STATE OF NEW YORK )
COUNTY OF SUFFOLK )
CHRISTINE M. HICKEY, being duly sworn, deposes and says; that she is of 18
years and upwards; that she is a Secretary in LAW OFFICE OF KEITH J. CONWAY
attorneys for defendant(s), BRADLEY JAMES BRONCATI AND JLJ IV ENTERPRISES,
INC., in the above entitled action; that the office address of said attorneys is 58 South
Service Road, Suite 350, Melville, New York 11747 that on May _, 2018 deponent
served upon:
CHARLES C. DESTEFANO, ESQ.
Attorneys for Plaintiff(s)
1082 Victory Boulevard
Staten Island, New York 10301
herein a copy of a RESPONSE PURSUANT TO CPLR 3101(d) which is annexed as a
true copy, by depositing same properly enclosed in a postpaid wrapper in the U.S. Post
Office Box at 58 South Service Road, Suite 350, Melville, New York 11747 on said
date, directed to said attorneys(s) at the above address(es) designated by said
attorneys in the last paper served herein.
CHRISTINE M. HICKEY
Sworn to before me this date,
May _, 2018
NOTARY PUBLIC
E OR)fHBISl(ING
tPublic-
—
State ofNew 'ron(
Notary
No. 01c014890460
Qualifie
Preview
FILED: QUEENS COUNTY CLERK 05/24/2018 03:36 PM INDEX NO. 701912/2017 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 05/24/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS -------------------------------------------------------------X PETRIT BICAJ, Index No.: 701912/17 Plaintiffs, RESPONSE PURSUANT -against- TO CPLR 5 3101(d) BRADLEY JAMES BRONCATI, JLJ IV ENTERPRISES, INC., Defendants. -------------------------------------------------------------X Defendants, BRADLEY JAMES BRONCATI AND JLJ IV ENTERPRISES, INC. by their attorneys LAW OFFICE OF KEITH J. CONWAY, hereby make the following response, pursuant to CPLR 3101(d): 1. The Defendants, BRADLEY JAMES BRONCATI AND JLJ IV ENTERPRISES, have retained Dr. John A. Bendo, an Orthopedist, as an expert witness. At the time of trial in the above entitled action, Dr. Bendo will testify based upon his examination of plaintiff, Petrit Bicaj, on May 1, 2018, his review of plaintiff's medical records and any records, testimony, evidence or films in evidence at trial. Dr. Bendo will testify as to his expert medical opinion concerning plaintiffs alleged injuries, their cause and connection with the accident or lack thereof, and his diagnosis, prognosis and opinion concerning plaintiffs claim of incapacity. Dr. Bendo may also testify in rebuttal to any testimony provided by plaintiff and/or plaintiffs experts. Dr. Bendo may testify concerning admissions or statements made by plaintiff during the course of the examination. 1 of 27 FILED: QUEENS COUNTY CLERK 05/24/2018 03:36 PM INDEX NO. 701912/2017 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 05/24/2018 2. The facts, upon which Dr. Bendo will testify, as well as the grounds for his opinions, are set forth in said report, a copy of which is annexed hereto. 3. A copy of Dr. Bendo's Curriculum Vitae is annexed hereto. Defendants reserve the right to amend or supplement this Response at any time up through and including the time of trial, pursuant to the CPLR and Uniform Court Rules. DATED: Melville, New York May 24, 2018 YOURS, Etc. LAW OFFICE OF KEITH J. CONWAY Attorneys for Defendants BRADLEY JAMES BRONCATI AND JLJ IV ENTERPRISES, INC. 58 South Service Road, Suite 350 Melville, New York 11747 (631) 845-2600 TO: CHARLES C. DESTEFANO, ESQ. Attorneys for Plaintiff(s) 1082 Victory Boulevard Staten Island, New York 10301 718-390-0580 2 of 27 FILED: QUEENS COUNTY CLERK 05/24/2018 03:36 PM INDEX NO. 701912/2017 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 05/24/2018 AFFIDAVIT OF SERVICE BY MAIL STATE OF NEW YORK ) COUNTY OF SUFFOLK ) CHRISTINE M. HICKEY, being duly sworn, deposes and says; that she is of 18 years and upwards; that she is a Secretary in LAW OFFICE OF KEITH J. CONWAY attorneys for defendant(s), BRADLEY JAMES BRONCATI AND JLJ IV ENTERPRISES, INC., in the above entitled action; that the office address of said attorneys is 58 South Service Road, Suite 350, Melville, New York 11747 that on May _, 2018 deponent served upon: CHARLES C. DESTEFANO, ESQ. Attorneys for Plaintiff(s) 1082 Victory Boulevard Staten Island, New York 10301 herein a copy of a RESPONSE PURSUANT TO CPLR 3101(d) which is annexed as a true copy, by depositing same properly enclosed in a postpaid wrapper in the U.S. Post Office Box at 58 South Service Road, Suite 350, Melville, New York 11747 on said date, directed to said attorneys(s) at the above address(es) designated by said attorneys in the last paper served herein. CHRISTINE M. HICKEY Sworn to before me this date, May _, 2018 NOTARY PUBLIC E OR)fHBISl(ING tPublic- — State ofNew 'ron( Notary No. 01c014890460 Qualifie