Legal Document: Karina Leon v. Tiffanie M. Bonello, Serafina Bonello

On June 19, 2023 a DEMAND FOR: - Combined Demands was filed involving a dispute between Karina Leon, and Serafina Bonello, Tiffanie M. Bonello, for Torts - Motor Vehicle in the District Court of Richmond County.

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FILED: RICHMOND COUNTY CLERK 08/03/2023 12:20 PM INDEX NO. 151132/2023
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 08/03/2023

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
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KARINA LEON, Index No. 151132/2023

Plaintiff,
-against- COMBINED DEMANDS

TIFFANIE M. BONELLO and SERAFINA BONELLO,

Defendants.
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COUNSEL:

PLEASE TAKE NOTICE that answering defendants, TIFFANIE M. BONELLO and

SERAFINA BONELLO, by their attorneys, ABRAMS, GORELICK, FRIEDMAN &

JACOBSON, LLP., hereby demand, pursuant to CPLR Article 31, The Uniform Rules for New

York State Trial Courts and the applicable case law, the production to said attorney at One Battery

Park Plaza, 4th Floor, New York, New York 10004 within thirty (30) days of the date of service

hereof, the following:

A. DEMAND FOR EMPLOYMENT RECORD AUTHORIZATIONS

1. the names and addresses of all of plaintiff s employers for the five (5) year
period prior to the date of the accident and up to the present date, including
the dates of employment for each such employer; and

2. duly executed and acknowledged original written authorizations which
permit defendant(s) to obtain a complete copy of the employment records
for the plaintiff from each of the employers identified in paragraph
numbered “1” above.

B. DEMAND FOR MEDICAL INFORMATION, REPORTS AND
AUTHORIZATIONS

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1. The names and addresses of all physicians, therapists or other health-care
providers of every description who have consulted, examined or treated
plaintiff for each of the conditions allegedly caused by, or exacerbated by,
the occurrence described in the complaint, including the dates of such
consultations, examinations or treatments;

2. Duly executed and acknowledged original written authorizations
separately directed to any hospital, clinic or health care facility, including,
but not limited to, Emergency Medical Service (EMS) or any ambulance
service, in which plaintiff herein was or continues to be treated or
confined due to the occurrence set forth in the complaint so as to permit
the securing of a copy of the entire hospital record or records including x-
rays, EKGs, EMGs, CAT scans, MRIs and other diagnostic tests, and
reports regarding x-rays, EKGs, EMGs, CAT scans, MRIs and other
diagnostic tests and all technicians' reports.

3. Duly executed and acknowledged original written authorizations which
allow defendant(s) to obtain the complete office medical records,
including x-rays, EKGs, CAT scans, MRIs and other diagnostic tests and
any reports regarding x-rays, EKGs, EMGs, CAT scans, MRIs and other
diagnostic tests, relating to plaintiff, of each physician or health care
provider identified in response to “1” above.

4. Copies of all medical reports, records, narrative records and statements
received from physicians or health care providers identified in response to
“1” above. These shall include a detailed recital of the injuries and
conditions as to which testimony will be offered at the trial of this action,
referring to and identifying those x-rays, EKGs, EMGS, CAT scans, MRIs
and other diagnostic tests and reports regarding the x-rays, EKGs, EMGs,
CAT scans, MRIs and other diagnostic tests which will be offered at the
trial of this action;

5. Duly executed and acknowledged original written authorizations which
allow defendant(s) to obtain complete pharmacy, drug store and/or
surgical supply records with respect to any drugs, surgical supplies and/or
prostheses prescribed for plaintiff from one (1) year prior to the
occurrence described in the complaint to the present date.

6. Within the time period of the date of the occurrence to the present, true
and accurate copies of all bills, invoices and statements for medical
treatment of every description, or any bills, invoices and statements
incidental to medical treatment of every description, including, but not

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limited to, bills, invoices and statements for drugs, medication or
pharmaceuticals of every description, relating to the injuries (to plaintiff)
allegedly caused or exacerbated by the occurrence described in the
complaint;

7. If it is claimed that the occurrence alleged in the complaint exacerbated
and/or aggravated any physical or mental condition of plaintiff herein, set
forth specifically each and every physical or mental condition it is claimed
was exacerbated and/or aggravated and set forth the names and addresses
of each and every physician or other health-care provider of every
description who has consulted, examined and/or treated plaintiff with
relation to the physical or mental condition which was allegedly
exacerbated and/or aggravated by the occurrence alleged in the complaint;

8. Duly executed and acknowledged original written authorizations directed
to any hospital, clinic or health care- facility, including, but not limited to,
Emergency Medical Service (EMS) or any ambulance service, in which
plaintiff herein was treated, examined and/or confined prior to the date of
the occurrence alleged in the complaint with relation to any physical or
mental condition of plaintiff that was allegedly exacerbated and or
aggravated by the occurrence alleged in the complaint which permit
defendant(s) to obtain a complete record, relating to the plaintiff, including
x-rays, EKGs, EMGs, CAT scans, MRIs and other diagnostic tests and
reports regarding x-rays, EKGs, EMGs, CAT scans, MRIs and other
diagnostic tests.

9. Duly executed and acknowledged written authorizations which allow
defendant(s) to obtain the complete office medical records, including x-
rays, EKGs, EMGS, CAT scans. MRIs and other diagnostic tests and
reports regarding x-rays, EKGs, EMGs, CAT scans, MRIs and other
diagnostic tests of each physician or health care provider identified in
response to " 7 " above.

10. Copies of all medical reports, records, narrative records and statements
received from physicians or health care providers identified in response to
"7" above. These shall include a detailed recital of the injuries and
conditions as to which testimony will be offered at the trial of this action,
referring to and identifying those x-rays, EKGs, CAT scans, MRIs and
other diagnostic tests and reports relating to x-rays, EKGs, EMGs, CAT
scans, MRIs and other diagnostic tests and technicians' reports which will
be offered at the trial of this action; and

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11. Original authorizations directed to each pharmacy from which the plaintiff
purchased medications or devices prescribed for the injury or the condition
claimed in this law suit setting forth thereon the full name and address of
each said pharmacy permitting the release by said pharmacy to
defendant(s) of all pharmaceutical records concerning prescriptions filled
by it for the plaintiff from the date of the accident to date.

C. DEMAND FOR COLLATERAL SOURCE INFORMATION
PURSUANT TO CPLR 3101, 3120 AND 4545

1. A verified statement as to whether all or any part of the past or future cost
or expense of medical care, dental care, custodial care, rehabilitation
services, loss of earnings, economic losses, or other loss sought to be
recovered in this action was or will, with reasonable certainty, be replaced
or indemnified, in whole or in part, from any collateral source such as, but
not limited to, insurance (except life insurance), social security (except
those benefits provided under Title XVII of the social security act),
workers' compensation, or employee benefit programs (except such
collateral sources entitled by law to liens against any recovery of the
plaintiffs and, if so, the full name and address of each organization or
program providing such replacement or indemnification, together with an
itemized statement of the amount in which each such claimed item of
economic loss was or will, with reasonable certainty, be replaced or
indemnified by each such organization or program.)

2. Duly executed and acknowledged original written authorizations required
to permit defendant(s) to obtain all records reflecting any collateral
sources or payments, past or future, identified in response to the foregoing
demand.

D. DEMAND FOR WORKERS COMPENSATION RECORDS

1. Duly executed and acknowledged original written authorizations which
permit defendant(s) to obtain plaintiff s Workers' Compensation records
which pertain to:

a. the occurrence alleged in the complaint,

b. the injuries, damages and/or losses alleged in the
complaint,

c. prior and subsequent injuries to the parts of plaintiff s body injured
in the accident which is the subject of plaintiffs complaint, and

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d. for other injuries and accidents which limited plaintiff s ability to
work which occurred prior to or subsequent to the accident which
is the subject of this action.

2. With respect to any insurance company which provides or will provide to
plaintiff benefits for any disability relative to the occurrence alleged in the
complaint, duly executed and acknowledged original written
authorizations required to permit defendant(s) to obtain the file, relative to
plaintiff with regard to such benefits, maintained by said insurance
companies. Said authorizations should include, without limitation, the
pertinent file/claim number maintained by said insurance companies.

E. DEMAND FOR DISABILITY CLAIMS RECORDS

1. Duly executed and acknowledged original written authorizations which
permit defendant(s) to obtain plaintiffs disability records which pertain, to:

a. the occurrence alleged in the complaint,

b. the injuries, damages and/or losses alleged in the complaint,

c. prior and subsequent injuries to the parts of plaintiff s body injured
in the accident which is the subject of plaintiff s complaint, and

d. for other injuries and accidents which limited plaintiff s ability to
work which occurred prior to or subsequent to the accident which
is the subject of this action.

F. DEMAND FOR SOCIAL SECURITY RECORDS

1. Duly executed and acknowledged original written authorizations which
permit defendant(s) to obtain plaintiff s Social Security Records, including
but not limited to SSI and SSD, which pertain to:

a. the occurrence alleged in the complaint,

b. the injuries, damages and/or losses alleged in the complaint,

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c. prior and subsequent injuries to the parts of plaintiffs body injured
in the accident which is the subject of plaintiff s complaint, and

d. for other injuries and accidents which limited plaintiff s ability to
work which occurred prior to or subsequent to the accident which
is the subject of this action.

G. DEMAND FOR THE RECORDS OF MEDICAID, MEDICARE AND
OTHER SIMILAR PROGRAMS

1. Duly executed and acknowledged original written authorizations which
permit defendant(s) to obtain the records maintained by Medicaid,
Medicare, and other similar programs, which pertain to:

a. the occurrence alleged in the complaint,

b. the injuries, damages and/or losses alleged in the complaint,

c. prior and subsequent injuries to the parts of plaintiffs body injured
in the accident which is the subject of plaintiffs complaint, and

d. for other injuries and accidents which limited plaintiff s ability to
work which occurred prior to or subsequent to the accident which
is the subject of this action.

H. DEMAND FOR NO-FAULT RECORDS

1. Duly executed and acknowledged original written authorizations which
permit defendant(s) to obtain plaintiff s No-Fault file which pertain to:

a. the occurrence alleged in the complaint,

b. the injuries, damages and/or losses alleged in the complaint,

c. prior and subsequent injuries to the parts of plaintiff s body injured
in the accident which is the subject of plaintiffs complaint, and

d. for other injuries and accidents which limited plaintiff’s ability to
work which occurred prior to or subsequent to the accident which
is the subject of this action.

2. With respect to any insurance company which provides or will provide to
plaintiff any benefits relative to the occurrence alleged in the complaint,
duly executed and acknowledged original written authorizations required
to permit defendant(s) to obtain the file, relative to plaintiff with regard to
such benefits, maintained by said insurance companies. Said

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authorizations should include, without limitation, the pertinent file/claim
number maintained by said insurance companies.

I. DEMAND FOR INCOME INFORMATION AND
AUTHORIZATION FOR IRS RECORDS

1. True and accurate copies of documentation reflecting income earned by
plaintiff for five (5) years prior to the occurrence alleged in the complaint
and up to the present date, including, but not limited to, W-2 Forms, 1099
Forms, and any other indicia of income earned

2. True and accurate copies of Federal, State and City income tax returns for
plaintiff(s) for five (5) years prior to the occurrence alleged in the
complaint and up to the present date; and

3. Duly executed and acknowledged written authorizations required to permit
defendant(s) to obtain Internal Revenue Service records, documents and
returns relative to plaintiff for five (5) years prior to the occurrence alleged
in the complaint and up to the present date. Please use authorization Form
4506 for this purpose. For each plaintiff, include photocopies of two (2)
pieces of identification bearing each plaintiffs signature, (i.e., social
security card, drivers license and/or passport).

J. DEMAND FOR SCHOOL RECORDS AUTHORIZATIONS

Duly executed and acknowledged written authorizations required to permit defendant(s) to
obtain plaintiff s complete school records, including, without limitation, attendance records,
grade achievements, physical examinations, extracurricular activities information,
gym/athletic/physical education records and the complete student file for plaintiff for each
school attended from five (5) years prior to the occurrence alleged in the complaint, the year
of said occurrence and up to the present date.
K. DEMAND FOR INDEX NUMBER

Pursuant to CPLR Section 306a and 22 NYCRR Section 202.5, plaintiff must purchase and
provide to said attorney for defendant index number for this action.

L. DEMAND TO PRODUCE STATEMENT OF PARTY PURSUANT
TO CPLR SECTIONS 3103(E) AND 3120

True and accurate copies of all statements, signed or unsigned, recorded on tape
electronically or otherwise, made by defendant(s), or their agents, servants and/or employees,
taken by, or on behalf of, or in the possession of, any party in this action or their attorney.
If there are no such statements, please so state in a sworn reply to this demand.

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M. DEMAND PURSUANT TO CPLR 2103(e)

A list of those parties who have appeared in this action together with the names and
addresses of their attorney(s).

N. DEMAND FOR ACCIDENT REPORTS

True and accurate copies of any reports of the occurrence alleged in the complaint.
O. DEMAND FOR THE NAMES AND ADDRESSES OF WITNESSES

The names and addresses of each person known and/or claimed by any party to be a witness
to any of the following:
(a) the occurrence alleged in the complaint,

(b) any acts, omissions or conditions which allegedly caused or contributed to
causing the occurrence alleged in the complaint,

(c) any actual notice allegedly given to defendant(s) or their agents, servants
or employees, or any other person, entire, or party to this action, of any
conditions which allegedly caused or contributed to causing the
occurrence alleged 'm the complaint,

(d) the nature and duration of any alleged condition which allegedly caused or
contributed to causing the occurrence alleged in the complaint,

(e) any repairs, at any time, made to the alleged location/condition which
allegedly caused the occurrences alleged in the complaint, and

(f) the alleged injuries, losses and/or damages.

If no such witnesses are known or claimed by the party you represent, so state in a sworn
reply to the above demands.
P. NOTICE FOR DISCOVERY AND INSPECTION

1. True and accurate copies of each and every recorded/written complaint
and/or notice, including, but not limited to, any work tickets made to
and/or from defendant(s) with respect to the condition alleged in the
complaint to have caused or contributed to the occurrence alleged in the
complaint;

2. True and accurate copies of any reports or other writings prepared by or
made to the police or any other governmental officers or agencies in
connection with the occurrence alleged in the complaint;

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3. All photographs of the scene of the incident/occurrence alleged in the
complaint, as said scene existed at the time of the incident/occurrence
alleged in the complaint;

4. All photographs of the plaintiff/decedent depicting the injuries allegedly
sustained as a result of the occurrence alleged in the complaint;

5. All photographs of all vehicles, instrumentalities and/or objects involved
in the incident/occurrence alleged in the complaint;

6. True and accurate copies of all transcripts of any hearings and/or
depositions concerning the occurrence alleged in the complaint;

7. True and accurate copies of all Notices of Claims served in this action;

8. True and accurate copies of the documents referred to by plaintiff during
testimony of plaintiff taken pursuant to Section 50-h of the General
Municipal Law;

9. A true and accurate copy of the agreement to rent, if any, which was in
effect between plaintiff/decedent and defendant(s) on the date of the
occurrence alleged in the complaint;

10. A true and accurate copy of plaintiff s birth certificate and social security
card;

11. A true and accurate copy of the

a. decedent's death certificate;

b. decedent's Letters of Administration or Executorship;

c. decedent's Will; and

d. decedent's autopsy report.

12. A duly executed and acknowledged written authorizations to allow
defendant(s) to obtain any testimony in any criminal proceeding involving
defendant(s), including without limitation Grand Jury testimony or trial
testimony, with all identifying information permitting location of said
testimony relative to criminal proceedings, if any, resulting from the
occurrence alleged in the complaint;

13. Copies of all claims and pleadings served upon any other person or entity,
including the parties to this action, in any other action or occurrence in
which the injuries or damages as alleged herein are in issue.

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14. Copies of any and all contracts, agreements, leases, bills, work progress
reports, daily logs or work orders or any communication exchanged by
and between any party to this action in relation to or in effect on the date
of this occurrence referred to in plaintiff s complaint for the accident site
referred to in plaintiff s complaint.

15. If a claim for loss of services is involved, supply a copy of the marriage
certificate with regard to any spouse who is a party to the action, and any
divorce or separation decree, and if an infant involved, the infant's birth
certificate.

16. Purchase, maintenance and repair records for the automobile involved in
the alleged occurrence for the period three (3) years prior to and six (6)
months subsequent to the alleged occurrence.

Q. DEMAND FOR EXPERT WITNESS INFORMATION PURSUANT

TO CPLR SECTION 3101(d)

1. The names and addresses of each person that plaintiff expects to call to
give expert testimony at the trial of this action;

2. Disclosure, in reasonable detail, of the qualifications, including, but not
limited to, educational background and degrees, academic experience,
publications, memberships in professional organizations, societies and
associations, certifications and licenses, and employment history and work
experience, of each person that plaintiff expects to call to give expert
testimony at the trial of this action;

3. For each person that plaintiff expects to call to give expert testimony at the
trial of this action, disclosure, in reasonable detail, of the facts upon which
the expert will rely in formulating his opinions and conclusions, and, the
source or sources of the expert's knowledge concerning such facts,
including, but not limited to, where applicable, the statistics, studies,
surveys, reports, test results, analyses and all other source material relied
upon by the expert;

4. For each person that plaintiff expects to call to give expert testimony at the
trial of this action, disclosure, in reasonable detail, of the subject matter of
the testimony, including, but not limited to, the opinions to which the
expert is expected to testify, the conclusions to which the expert is expected
to testify, and, the grounds for the opinions and conclusions to which the
expert is expected to testify;

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5. Attach a complete copy of each expert's report, including photographs,
exhibits, diagrams, charts and any other material prepared by this expert in
connection with his retainer;

6. Attach a complete copy of each expert's curriculum vitae and/or resume;

7. State whether any of the named experts have previously testified on behalf
of your law office in other litigation. If so, provide case name and index
number;

8. With respect to physicians or other medical providers, for each person that
plaintiff expects to call to give expert testimony at the trial of this action,
disclosure, in reasonable detail of (in addition to all of the above) the
following:

a. whether the expert is licensed in this state;

b. whether the expert is licensed to practice medicine in any
other state;

c. whether the expert is certified in a specialty in this state or any
other state and, if so, set forth the specialties;

d. whether the expert has authored any medical books, treatises,
articles, publications and/or written materials in the field of his/her
expertise and, if so, set forth the name and date of said books,
treatises, articles, publications and/or written materials;

e. a description of every medical, dental and/or hospital record,
report, note and/or chart upon which the expert will rely;

f. a list of the names and dates of all books, treatises, articles,
publications and/or written materials upon which the expert will
rely.

g. In the event no such experts are expected to be called as expert
witnesses at the trial of this action, then a sworn statement to that
effect is hereby demanded to be produced.

R. DEMAND FOR COPIES OF INSURANCE CONTRACTS AND
AGREEMENTS

A copy of each insurance contract and/or agreement under which any person carrying on
insurance business may be liable to satisfy part or all of a judgment which may be entered in
this action against the party you represent or may be responsible to indemnify or reimburse

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the party you represent, in whole or in part, for any payment made to satisfy the judgment
which may be entered herein against the party you represent, including but not limited to
excess and additional coverage.
S. DEMAND FOR RECORDS FROM THE CITY OF NEW YORK

1. For the location of the accident set forth in plaintiff s complaint and for all
areas within 25 feet from said location, provide complete copies of the
following records for three years prior to the date of the accident:

a. repair records,

b. cut forms,

c. 15 day notices,

d. written complaints,

e. violations,

f. permits,

g. applications for permits,

h. contracts, Big Apple Notices,

j. prior written notice,

k. work orders,

1. repair orders, and

m. work records.

2. For the location of the accident set forth in plaintiff s complaint and for all
areas within 25 feet from said location, provide copies of all Notices of
Claims, served by plaintiff and other claimants, which were served on the
City of New York during the three year period prior to the date of plaintiff
s accident.

3. If the City of New York's own employees have renovated or rebuilt the
location of the accident set forth in plaintiff s complaint and/or the areas
within 25 feet from said location, within five years prior to the date of
plaintiff s accident, provide the names and addresses of the agencies
involved in such renovation or rebuilding, and copies of all such records in
the possession of such agency.

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T. PROPERTY DAMAGE CLAIM

1. If property damage is alleged, you are required to produce true, accurate
and complete copies of all property damage estimates, repair bills and/or
original purchase invoices for the property allegedly damaged, destroyed
or stolen.

PLEASE TAKE NOTICE that the above demands are continuing demands and all

responsive information that is made known or becomes available after service of the above

demands shall be furnished to the undersigned attorney in a timely fashion.

PLEASE TAKE FURTHER NOTICE that defendant(s) will move at the time of trial or

prior thereto, for an order precluding the giving of testimony by any witness for whom full and

complete information had not been furnished in compliance with the above demands. Further, the

failure to fully comply with the above demands in a timely fashion may also be grounds for an

order striking the complaint, dismissing the action, moving to compel compliance and/or such

other relief as the Court deems just under the circumstances.

Dated: New York, New York
August 3, 2023

ABRAMS, GORELICK, FRIEDMAN &
JACOBSON, LLP
Attorneys for Defendants
TIFFANIE M. BONELLO and SERAFINA
BONELLO

By: _______________________
Altea Di Stefano
One Battery Park Plaza, 4th Floor,
New York, New York 10004
(212) 968-1476
File No.: 92195

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TO: Kevin D. Gratt, Esq.
GRATT & ASSOCIATES, P.C.
Attorneys for Plaintiff
3011 Farragut Road, Suite 2
Brooklyn, NY 11210
(718) 963-3339

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
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KARINA LEON, Index No. 151132/2023

Plaintiff,
-against- NOTICE TO TAKE
DEPOSITION UPON
ORAL EXAMINATION
TIFFANIE M. BONELLO and SERAFINA BONELLO,

Defendants.
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PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and

Rules the testimony, upon oral examination, of plaintiff and defendants as adverse parties will be

taken before a notary public who is not an attorney, or employee of an attorney, for any party or

prospective party herein and is not a person who would be disqualified to act as a juror because

of interest or because of consanguinity or affinity to any party herein, at the offices of ABRAMS,

GORELICK, FRIEDMAN & JACOBSON, LLP, One Battery Park Plaza, 4th Floor, New York,

New York 10004 on the day, time and place to be mutually agreed upon at the Preliminary

Conference to be held herein with respect to evidence material and necessary in the defense of

this action:

That the said person to be examined is required to produce at such examination the

following:

All books, records, papers, documents and other things relevant to the pleadings,

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including, but not limited to, all correspondence relating to the above matter and/or relevant to

the issues raised by the pleadings.

Dated: New York, New York
August 3, 2023

ABRAMS, GORELICK, FRIEDMAN &
JACOBSON, LLP
Attorneys for Defendants
TIFFANIE M. BONELLO and SERAFINA
BONELLO

By: _______________________
Altea Di Stefano
One Battery Park Plaza, 4th Floor,
New York, New York 10004
(212) 968-1476
File No.: 92195

TO: Kevin D. Gratt, Esq.
GRATT & ASSOCIATES, P.C.
Attorneys for Plaintiff
3011 Farragut Road, Suite 2
Brooklyn, NY 11210
(718) 963-3339

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
-------------------------------------------------------------------x
KARINA LEON, Index No. 151132/2023

Plaintiff,
-against- DEMAND PURSUANT TO
CPLR §3017

TIFFANIE M. BONELLO and SERAFINA BONELLO,

Defendants.
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S I R S:

PLEASE TAKE NOTICE that within twenty (20) days after service of this notice, you

are required pursuant to CPLR §3017 to serve a supplemental statement of the amount of damages

sought.

Dated: New York, New York
August 3, 2023

ABRAMS, GORELICK, FRIEDMAN &
JACOBSON, LLP
Attorneys for Defendants
TIFFANIE M. BONELLO and SERAFINA
BONELLO

By: _______________________
Altea Di Stefano
One Battery Park Plaza, 4th Floor,
New York, New York 10004
(212) 968-1476
File No.: 92195
TO: Kevin D. Gratt, Esq.
GRATT & ASSOCIATES, P.C.
Attorneys for Plaintiff
3011 Farragut Road, Suite 2
Brooklyn, NY 11210
(718) 963-3339

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FILED: RICHMOND COUNTY CLERK 08/03/2023 12:20 PM INDEX NO. 151132/2023
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 08/03/2023

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
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KARINA LEON, Index No. 151132/2023

Plaintiff,
-against- DEMAND FOR MEDICARE
INFORMATION

TIFFANIE M. BONELLO and SERAFINA BONELLO,

Defendants.
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COUNSELORS:

PLEASE TAKE NOTICE, Defendants, TIFFANIE M. BONELLO and SERAFINA

BONELLO, demand the following:

1. Pursuant to CPLR 3120(a) and the requirements of Section 111 of the Medicare,
Medicaid, and SCHIP Extension Act of 2007 (42 U.S.C. 1 395(y)(b)(7) and (b)(8)),
provide:
a. The plaintiff’s date of birth;

b. The plaintiff’s Social Security No.;

c. The plaintiff’s Medicare Health Insurance Claim Numbers (HICNs), Medicaid
file number, New York State Department of Social Services (DSS) file number,
and/or Medicare Secondary Payor (MSP) file number, if applicable;
d. If the plaintiff has applied for or been awarded Medicare and/or Medicaid and/or
DSS and/or MSP benefits, all information/documentation related to the
application and/or award of

Case Info

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Ronald Castorina Track Judge’s New Case

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Document Filed Date

August 03, 2023

Case Filing Date

June 19, 2023

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