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  • Minel Johnson, Ansel Johnson v. Bernard Rimpel, Umesh Mishra, Joseph Dergan, Sarina Cranage, Stacey Martindale, Amer Homsi, David Schaner, The Brooklyn Hospital Center Torts - Medical, Dental, or Podiatrist Malpractice document preview
  • Minel Johnson, Ansel Johnson v. Bernard Rimpel, Umesh Mishra, Joseph Dergan, Sarina Cranage, Stacey Martindale, Amer Homsi, David Schaner, The Brooklyn Hospital Center Torts - Medical, Dental, or Podiatrist Malpractice document preview
						
                                

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FILED: KINGS COUNTY CLERK 03/09/2017 05:23 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 03/09/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------------x MINEL JOHNSON and ANSEL JOHNSON, Index No.: 523101/2016 Plaintiffs, DEMAND FOR -against- COLLATERAL SOURCE BERNARD RIMPEL, UMESH MISHRA, JOSEPH INFORMATION DERGAN, SARINA CRANAGE, STACEY MARTINDALE, AMER HOMSI, DAVID SCHANER, and THE BROOKLYN HOSPITAL CENTER, Defendants. --------------------------------------------------------------------------x TO ALL COUNSEL: PLEASE TAKE NOTICE, that you are hereby required to furnish to the undersigned within thirty (30) days hereof pursuant to § 3101 and § 4545(c) of the CPLR, all documents, bills, invoices, receipts or cancelled checks concerning indemnification, payment and/or reimbursements, in whole or in part, which plaintiffs have received from collateral sources, including, but not limited to, insurance, social security workers compensation, no-fault or employee benefit programs for the cost of medical care, custodial care, rehabilitation services, loss of earnings and other economic loss which the plaintiffs will claim as special damages in this action or which plaintiffs will claim were incurred as a result of the occurrence alleged in this action. PLEASE TAKE FURTHER NOTICE, that failure to comply with the above- mentioned request will render the plaintiffs subject to available provisions provided under the CPLR and that this demand is to be considered a continuing demand. Dated: New York, New York March 9, 2017 1 of 2 FILED: KINGS COUNTY CLERK 03/09/2017 05:23 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 03/09/2017 ELLENBERG & PARTNERS LLP Attorneys for Defendant BERNARD RIMPEL 494 Eighth Avenue, 7th Floor New York, NY 10001 (212) 629-8585 By: ________________________________ Corey Shulman TO: GURFEIN DOUGLAS LLP Attorneys for Plaintiffs 11 Park Place, Suite 1100 New York, NY 10007 (212) 406-1600 2 of 2