Preview
FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/20/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
HUSSEIN BADR,
Index No. 515722/2023
Plaintiff,
-against- DEFENDANTS JEAN
BOULOUTE, ADT LLC, AND
JEAN BOULOUTE, ADT SECURITY SERVICES INC., GELCO FLEET TRUST’S
and GELCO FLEET TRUST, DEMAND FOR
MEDICARE/MEDICAID LIEN
Defendants. INFORMATION DIRECTED TO
PLAINTIFF
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, 42
U.S.C. § 1395y(b)(2)(B), and New York Social Services Law § 104-b, Defendants JEAN
BOULOUTE, ADT LLC (incorrectly named as ADT SECURITY SERIVCES INC.), and GELCO
FLEET TRUST request that you furnish the following within twenty (20) days of the service of
this demand:
1. Plaintiff’s date of birth.
2. Plaintiff’s social security number.
3. Plaintiff’s Medicare file numbers.
4. The addresses of the offices handling Plaintiff’s Medicare files.
5. The name, address, and telephone number of the claim handler/recovery contractors
handling Plaintiff’s Medicare files.
6. Plaintiff’s Medicaid file numbers.
7. The addresses of the offices handling Plaintiff’s Medicaid files.
8. The name, address, and telephone number of the claim handler/recovery contractors
handling Plaintiff’s Medicaid files.
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FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/20/2023
9. Copies of all documents, records, memoranda, notes, and the like in each Plaintiff’s
possession and control concerning their receipts of Medicare benefits including but not limited to,
interim conditional payment information, documents, and materials.
10. Copies of all documents, records, memoranda, notes, and the like in each Plaintiff’s
possession and control concerning their receipts of Medicaid benefits.
11. A duly-executed authorization bearing each Plaintiff’s date of birth and social
security number which permits this firm and other representatives of Defendant to obtain copies
of their Medicare records.
12. A duly-executed authorization bearing each Plaintiff’s date of birth and social
security number which permits this firm and other representatives of Defendant to obtain copies
of their Medicaid records.
13. Copies of all writings by which each Plaintiff and/or their representatives have
placed Medicare on notice of their pending personal injury claims and/or lawsuits and copies of
any acknowledgement and/or responses from Medicare.
14. Copies of writings by which each Plaintiff and/or their representatives have placed
Medicaid on notice of their pending personal injury claims and/or lawsuits and copies of any
acknowledgement and/or responses from Medicaid.
15. Copies of each Plaintiff’s applications for Social Security disability benefits and
copies of any response(s) thereto.
16. Copies of each Plaintiff’s applications for Medicaid benefits and copies of any
responses thereto.
17. State whether Medicare, Medicaid, and/or the Social Security Administration has a
lien on any potential award, judgment, or settlement in this lawsuit and, if so, sate the amount of
such liens and provide all information/documentation relative to these liens.
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FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/20/2023
These demands are continuing in nature. If any responsive information is obtained after the
date of this demand, it is to be immediately furnished to us. If you fail to comply, we shall rely on
all sanctions provided by law.
Dated: New York, NY
June 20, 2023 Respectfully submitted,
Abraham D. Leybengrub, Esq.
GOLDBERG SEGALLA LLP
711 3rd Avenue, Suite 1900
New York, NY 10017-4013
Telephone: (646) 292-8785
aleybengrub@goldbergsegalla.com
Attorneys for Defendants,
JEAN BOULOUTE, ADT LLC (incorrectly named
as ADT SECURITY SERIVCES INC.), and
GELCO FLEET TRUST
TO: Nicholas Elefterakis, Esq.
ELEFTERAKIS, ELEFTERAKIS & PANEK
80 Pine Street, 38th Floor
New York, New York 10005
T: (212) 532-1116
Attorneys for Plaintiff,
HUSSEIN BADR
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FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/20/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
HUSSEIN BADR,
Index No. 515722/2023
Plaintiff,
-against-
JEAN BOULOUTE, ADT SECURITY SERVICES INC.,
and GELCO FLEET TRUST,
Defendants.
DEFENDANTS JEAN BOULOUTE, ADT LLC, AND GELCO FLEET TRUST’S DEMAND
FOR MEDICARE/MEDICAID LIEN INFORMATION DIRECTED TO PLAINTIFF
GOLDBERG SEGALLA, LLP
Attorneys for Defendant
JEAN BOULOUTE, ADT LLC (incorrectly named as ADT SECURITY SERIVCES INC.), and
GELCO FLEET TRUST
711 Third Avenue, Suite 1900
New York, New York 10017
Tel: 646-292-8700
______________________________________________________________________________
TO:
Nicholas Elefterakis, Esq.
ELEFTERAKIS, ELEFTERAKIS &
Attorneys for Plaintiff
HUSSEIN BADR
80 Pine Street, 38th Floor
New York, New York 10005
T: (212) 532-1116
__________________________________________________________________________
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Preview
FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/20/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS HUSSEIN BADR, Index No. 515722/2023 Plaintiff, -against- DEFENDANTS JEAN BOULOUTE, ADT LLC, AND JEAN BOULOUTE, ADT SECURITY SERVICES INC., GELCO FLEET TRUST’S and GELCO FLEET TRUST, DEMAND FOR MEDICARE/MEDICAID LIEN Defendants. INFORMATION DIRECTED TO PLAINTIFF PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, 42 U.S.C. § 1395y(b)(2)(B), and New York Social Services Law § 104-b, Defendants JEAN BOULOUTE, ADT LLC (incorrectly named as ADT SECURITY SERIVCES INC.), and GELCO FLEET TRUST request that you furnish the following within twenty (20) days of the service of this demand: 1. Plaintiff’s date of birth. 2. Plaintiff’s social security number. 3. Plaintiff’s Medicare file numbers. 4. The addresses of the offices handling Plaintiff’s Medicare files. 5. The name, address, and telephone number of the claim handler/recovery contractors handling Plaintiff’s Medicare files. 6. Plaintiff’s Medicaid file numbers. 7. The addresses of the offices handling Plaintiff’s Medicaid files. 8. The name, address, and telephone number of the claim handler/recovery contractors handling Plaintiff’s Medicaid files. 1 of 4 FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/20/2023 9. Copies of all documents, records, memoranda, notes, and the like in each Plaintiff’s possession and control concerning their receipts of Medicare benefits including but not limited to, interim conditional payment information, documents, and materials. 10. Copies of all documents, records, memoranda, notes, and the like in each Plaintiff’s possession and control concerning their receipts of Medicaid benefits. 11. A duly-executed authorization bearing each Plaintiff’s date of birth and social security number which permits this firm and other representatives of Defendant to obtain copies of their Medicare records. 12. A duly-executed authorization bearing each Plaintiff’s date of birth and social security number which permits this firm and other representatives of Defendant to obtain copies of their Medicaid records. 13. Copies of all writings by which each Plaintiff and/or their representatives have placed Medicare on notice of their pending personal injury claims and/or lawsuits and copies of any acknowledgement and/or responses from Medicare. 14. Copies of writings by which each Plaintiff and/or their representatives have placed Medicaid on notice of their pending personal injury claims and/or lawsuits and copies of any acknowledgement and/or responses from Medicaid. 15. Copies of each Plaintiff’s applications for Social Security disability benefits and copies of any response(s) thereto. 16. Copies of each Plaintiff’s applications for Medicaid benefits and copies of any responses thereto. 17. State whether Medicare, Medicaid, and/or the Social Security Administration has a lien on any potential award, judgment, or settlement in this lawsuit and, if so, sate the amount of such liens and provide all information/documentation relative to these liens. 2 2 of 4 FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/20/2023 These demands are continuing in nature. If any responsive information is obtained after the date of this demand, it is to be immediately furnished to us. If you fail to comply, we shall rely on all sanctions provided by law. Dated: New York, NY June 20, 2023 Respectfully submitted, Abraham D. Leybengrub, Esq. GOLDBERG SEGALLA LLP 711 3rd Avenue, Suite 1900 New York, NY 10017-4013 Telephone: (646) 292-8785 aleybengrub@goldbergsegalla.com Attorneys for Defendants, JEAN BOULOUTE, ADT LLC (incorrectly named as ADT SECURITY SERIVCES INC.), and GELCO FLEET TRUST TO: Nicholas Elefterakis, Esq. ELEFTERAKIS, ELEFTERAKIS & PANEK 80 Pine Street, 38th Floor New York, New York 10005 T: (212) 532-1116 Attorneys for Plaintiff, HUSSEIN BADR 3 3 of 4 FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 06/20/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS HUSSEIN BADR, Index No. 515722/2023 Plaintiff, -against- JEAN BOULOUTE, ADT SECURITY SERVICES INC., and GELCO FLEET TRUST, Defendants. DEFENDANTS JEAN BOULOUTE, ADT LLC, AND GELCO FLEET TRUST’S DEMAND FOR MEDICARE/MEDICAID LIEN INFORMATION DIRECTED TO PLAINTIFF GOLDBERG SEGALLA, LLP Attorneys for Defendant JEAN BOULOUTE, ADT LLC (incorrectly named as ADT SECURITY SERIVCES INC.), and GELCO FLEET TRUST 711 Third Avenue, Suite 1900 New York, New York 10017 Tel: 646-292-8700 ______________________________________________________________________________ TO: Nicholas Elefterakis, Esq. ELEFTERAKIS, ELEFTERAKIS & Attorneys for Plaintiff HUSSEIN BADR 80 Pine Street, 38th Floor New York, New York 10005 T: (212) 532-1116 __________________________________________________________________________ 4 4 of 4