Preview
FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
CHERYL SIMS,
Plaintiff(s)
DEMAND FOR DISCOVERY
- against -
Index No.: 715063/2021
CAROLYN G. JOHNSON,
Defendant(s)
PLEASE TAKE NOTICE that pursuant to the applicable Rules, you are hereby required to
serve the following upon the undersigned within twenty (20) days after receipt of this notice:
A. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated January 30, 1999 enabling FERRO & STENZ to obtain the
following:
▪ GOVERNMENT EMPLOYEES INSURANCE COMPANY, Claim #
0111544550101029 (No-fault file)
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
B. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated March 10, 2000 enabling FERRO & STENZ to obtain the
following:
▪ VANGUARD CAR RENTAL, Claim # T224710801AC (No-fault file)
Sensitivity: Confidential
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FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
C. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated August 10, 2000 enabling FERRO & STENZ to obtain the
following:
▪ GOVERNMENT EMPLOYEES INSURANCE COMPANY, Claim #
0111544550101086 (No-fault file)
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
D. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated December 31, 2000 enabling FERRO & STENZ to obtain the
following:
▪ GOVERNMENT EMPLOYEES INSURANCE COMPANY, Claim #
0111544550101094 (No-fault file)
Sensitivity: Confidential
2 of 8
FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
E. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated March 8, 2003 enabling FERRO & STENZ to obtain the
following:
▪ GEICO INDEMNITY COMPANY, Claim # 0111544550101102 (No-fault file)
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
F. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated November 7, 2003 enabling FERRO & STENZ to obtain the
following:
▪ GEICO GENERAL INSURANCE COMPANY, Claim # 0111544550101136 (No-fault
file)
Sensitivity: Confidential
3 of 8
FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
G. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated October 31, 2005 enabling FERRO & STENZ to obtain the
following:
▪ GEICO GENERAL INSURANCE COMPANY, Claim # 0111544550101169 (No-fault
file)
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
H. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated April 5, 2007 enabling FERRO & STENZ to obtain the following:
▪ GEICO GENERAL INSURANCE COMPANY, Claim # 0111544550101177 (No-fault
file)
Sensitivity: Confidential
4 of 8
FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
I. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated December 1, 2009 enabling FERRO & STENZ to obtain the
following:
▪ GEICO GENERAL INSURANCE COMPANY, Claim # 01115445501012 (No-fault
file)
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
J. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with
proper address that expire upon the conclusion of the current litigation pending in Queens
County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl
Sims prior loss dated November 24, 2010 enabling FERRO & STENZ to obtain the
following:
▪ GEICO GENERAL INSURANCE COMPANY, Claim # 0111544550101391 (No-fault
file)
Sensitivity: Confidential
5 of 8
FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022
▪ All other collateral sources including no-fault, disability, workers’ compensation,
private health insurance, Medicaid, Medicare, Social Security Administration, Motor
Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc.
▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance,
emergency care, specialists, physicians, hospitals, psychological, rehabilitative,
diagnostic and surgical facilities and surgeons (to include intra-operative
films/videos/photographs) for injuries sustained
▪ Employment and/or school attendance records, if any
▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index
number, bill of particulars, and deposition transcripts
If any of the above cannot be provided, Plaintiff(s) are to provide an
affidavit stating the same, including the reason(s) said material(s)
cannot be provided.
PLEASE PROVIDE a copy of all medical reports received from each physician or Health
care provider treating the plaintiff for injuries incurred as a result of the occurrence set forth in the
Complaint.
PLEASE TAKE FURTHER NOTICE that each of these authorizations must have an
expiration date of, “the completion of litigation”.
PLEASE TAKE FURTHER NOTICE that each of these authorizations must include
complete names, addresses, and any and all pertinent identifying information.
PLEASE TAKE FURTHER NOTICE that this is a continuing demand and should any of
the above requested information become available to or known in the future, you are then required
to furnish same at such time.
DATED: Westbury, New York
January 5, 2022
Yours, etc.
_______________________________________
Rida Siddiqui, Esq.
FERRO & STENZ
Attorneys for Defendant(s)
Carolyn Johnson
875 Merrick Avenue
Westbury, New York 11590-6603
Telephone: 516-229-4276
Sensitivity: Confidential
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FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022
Fax: 516-229-4203
Email: RSiddiqui@geico.com
Our File Number: 21-0098715
Claim Number: 0521350160101043
TO:
Gratt & Associates P.C
Attorneys for Plaintiff(s)
Cheryl Sims
2021 Nostrand Avenue
Brooklyn, NY 11210
718-963-3339
Sensitivity: Confidential
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FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022
Index No.: 715063/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
CHERYL SIMS,
Plaintiff(s)
- against - DEMAND FOR DISCOVERY
CAROLYN G. JOHNSON,
Defendant(s)
FERRO & STENZ
Attorneys for the Defendant(s)
Carolyn Johnson
875 Merrick Avenue
Westbury, New York 11590-6603
516-229-4276
------------------------------------------------------------------------------------------------------------------------
TO:
Gratt & Associates P.C
Attorneys for Plaintiff(s)
Cheryl Sims
2021 Nostrand Avenue
Brooklyn, NY 11210
718-963-3339
------------------------------------------------------------------------------------------------------------------------
Due and timely service of a copy of the within DEMAND FOR DISCOVERY is hereby admitted.
Dated January 5, 2022
Attorney(s) for Defendant(s) Carolyn Johnson
------------------------------------------------------------------------------------------------------------------------
Sensitivity: Confidential
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Preview
FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS CHERYL SIMS, Plaintiff(s) DEMAND FOR DISCOVERY - against - Index No.: 715063/2021 CAROLYN G. JOHNSON, Defendant(s) PLEASE TAKE NOTICE that pursuant to the applicable Rules, you are hereby required to serve the following upon the undersigned within twenty (20) days after receipt of this notice: A. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated January 30, 1999 enabling FERRO & STENZ to obtain the following: ▪ GOVERNMENT EMPLOYEES INSURANCE COMPANY, Claim # 0111544550101029 (No-fault file) ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts B. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated March 10, 2000 enabling FERRO & STENZ to obtain the following: ▪ VANGUARD CAR RENTAL, Claim # T224710801AC (No-fault file) Sensitivity: Confidential 1 of 8 FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022 ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts C. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated August 10, 2000 enabling FERRO & STENZ to obtain the following: ▪ GOVERNMENT EMPLOYEES INSURANCE COMPANY, Claim # 0111544550101086 (No-fault file) ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts D. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated December 31, 2000 enabling FERRO & STENZ to obtain the following: ▪ GOVERNMENT EMPLOYEES INSURANCE COMPANY, Claim # 0111544550101094 (No-fault file) Sensitivity: Confidential 2 of 8 FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022 ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts E. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated March 8, 2003 enabling FERRO & STENZ to obtain the following: ▪ GEICO INDEMNITY COMPANY, Claim # 0111544550101102 (No-fault file) ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts F. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated November 7, 2003 enabling FERRO & STENZ to obtain the following: ▪ GEICO GENERAL INSURANCE COMPANY, Claim # 0111544550101136 (No-fault file) Sensitivity: Confidential 3 of 8 FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022 ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts G. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated October 31, 2005 enabling FERRO & STENZ to obtain the following: ▪ GEICO GENERAL INSURANCE COMPANY, Claim # 0111544550101169 (No-fault file) ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts H. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated April 5, 2007 enabling FERRO & STENZ to obtain the following: ▪ GEICO GENERAL INSURANCE COMPANY, Claim # 0111544550101177 (No-fault file) Sensitivity: Confidential 4 of 8 FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022 ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts I. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated December 1, 2009 enabling FERRO & STENZ to obtain the following: ▪ GEICO GENERAL INSURANCE COMPANY, Claim # 01115445501012 (No-fault file) ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts J. Duly executed, current and acknowledged HIPAA Compliant authorizations complete with proper address that expire upon the conclusion of the current litigation pending in Queens County Supreme Court under index number 715063/2021 pertaining to plaintiff, Cheryl Sims prior loss dated November 24, 2010 enabling FERRO & STENZ to obtain the following: ▪ GEICO GENERAL INSURANCE COMPANY, Claim # 0111544550101391 (No-fault file) Sensitivity: Confidential 5 of 8 FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022 ▪ All other collateral sources including no-fault, disability, workers’ compensation, private health insurance, Medicaid, Medicare, Social Security Administration, Motor Vehicle Accident Indemnification Corp., State Insurance Fund of New York, etc. ▪ All examining, diagnosing, consulting and treating healthcare providers, ambulance, emergency care, specialists, physicians, hospitals, psychological, rehabilitative, diagnostic and surgical facilities and surgeons (to include intra-operative films/videos/photographs) for injuries sustained ▪ Employment and/or school attendance records, if any ▪ Non-privileged portion of attorney’s legal file including, but not limited to venue, index number, bill of particulars, and deposition transcripts If any of the above cannot be provided, Plaintiff(s) are to provide an affidavit stating the same, including the reason(s) said material(s) cannot be provided. PLEASE PROVIDE a copy of all medical reports received from each physician or Health care provider treating the plaintiff for injuries incurred as a result of the occurrence set forth in the Complaint. PLEASE TAKE FURTHER NOTICE that each of these authorizations must have an expiration date of, “the completion of litigation”. PLEASE TAKE FURTHER NOTICE that each of these authorizations must include complete names, addresses, and any and all pertinent identifying information. PLEASE TAKE FURTHER NOTICE that this is a continuing demand and should any of the above requested information become available to or known in the future, you are then required to furnish same at such time. DATED: Westbury, New York January 5, 2022 Yours, etc. _______________________________________ Rida Siddiqui, Esq. FERRO & STENZ Attorneys for Defendant(s) Carolyn Johnson 875 Merrick Avenue Westbury, New York 11590-6603 Telephone: 516-229-4276 Sensitivity: Confidential 6 of 8 FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022 Fax: 516-229-4203 Email: RSiddiqui@geico.com Our File Number: 21-0098715 Claim Number: 0521350160101043 TO: Gratt & Associates P.C Attorneys for Plaintiff(s) Cheryl Sims 2021 Nostrand Avenue Brooklyn, NY 11210 718-963-3339 Sensitivity: Confidential 7 of 8 FILED: QUEENS COUNTY CLERK 01/06/2022 04:20 PM INDEX NO. 715063/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/06/2022 Index No.: 715063/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS CHERYL SIMS, Plaintiff(s) - against - DEMAND FOR DISCOVERY CAROLYN G. JOHNSON, Defendant(s) FERRO & STENZ Attorneys for the Defendant(s) Carolyn Johnson 875 Merrick Avenue Westbury, New York 11590-6603 516-229-4276 ------------------------------------------------------------------------------------------------------------------------ TO: Gratt & Associates P.C Attorneys for Plaintiff(s) Cheryl Sims 2021 Nostrand Avenue Brooklyn, NY 11210 718-963-3339 ------------------------------------------------------------------------------------------------------------------------ Due and timely service of a copy of the within DEMAND FOR DISCOVERY is hereby admitted. Dated January 5, 2022 Attorney(s) for Defendant(s) Carolyn Johnson ------------------------------------------------------------------------------------------------------------------------ Sensitivity: Confidential 8 of 8