On December 31, 2020 a
Letter,Correspondence
was filed
involving a dispute between
Carlton L. Moitt Jr. As Administrator Of The Estate Of Cynthia Moitt,
and
Elena Vezza Md,
Throgs Neck Operating Co.Llc,
Throgs Neck Rehabilitation & Nursing Center,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Bronx County.
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FILED: BRONX COUNTY CLERK 04/20/2021 02:41 PM INDEX NO. 35921/2020E
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 04/20/2021
April 20, 2021
Via e-mail: mfruhling@lawyertime.com
Gersowitz Libo and Korek, PC.
111 Broadway, 12th Floor
New York, New York 10006
Attn: Michael Fruhling, Esq.
Re: Moitt v. Throgs Neck Operating Company, LLC d/b/a Throgs Neck Rehabilitation &
Nursing Center, et al.
LJAA No.: 0373-1020-NY00
Dear Mr. Fruhling:
As you are aware, we have been retained to represent the interests of Throgs Neck Rehabilitation
and Nursing Center with respect to the above referenced matter.
On January 29, 2021, we served initial demands at the time we interposed an Answer on behalf of
Throgs Neck Rehabilitation. We served demands for authorizations permitting review of medical
records and a demand for a Bill of Particulars simultaneously. We have received no responses to
date.
Please allow this to serve as a good faith attempt at discovery compliance. Thank you for your
attention to this matter.
If you have any questions, do not hesitate to contact me.
Very truly yours,
Theresa Scotto-Lavino
Theresa Scotto-Lavino
tslavino@lewisjohs.com
New York City Office
cc: Via email: ptaglia@dwyertaglia.com
One CA Plaza, Suite 225, Islandia NY 11749 631.755.0101 Fax 631.755.0117 www.lewisjohs.com
New York City | Long Island
1 of 1
Document Filed Date
April 20, 2021
Case Filing Date
December 31, 2020
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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FILED: BRONX COUNTY CLERK 04/20/2021 02:41 PM INDEX NO. 35921/2020E NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 04/20/2021 April 20, 2021 Via e-mail: mfruhling@lawyertime.com Gersowitz Libo and Korek, PC. 111 Broadway, 12th Floor New York, New York 10006 Attn: Michael Fruhling, Esq. Re: Moitt v. Throgs Neck Operating Company, LLC d/b/a Throgs Neck Rehabilitation & Nursing Center, et al. LJAA No.: 0373-1020-NY00 Dear Mr. Fruhling: As you are aware, we have been retained to represent the interests of Throgs Neck Rehabilitation and Nursing Center with respect to the above referenced matter. On January 29, 2021, we served initial demands at the time we interposed an Answer on behalf of Throgs Neck Rehabilitation. We served demands for authorizations permitting review of medical records and a demand for a Bill of Particulars simultaneously. We have received no responses to date. Please allow this to serve as a good faith attempt at discovery compliance. Thank you for your attention to this matter. If you have any questions, do not hesitate to contact me. Very truly yours, Theresa Scotto-Lavino Theresa Scotto-Lavino tslavino@lewisjohs.com New York City Office cc: Via email: ptaglia@dwyertaglia.com One CA Plaza, Suite 225, Islandia NY 11749 631.755.0101 Fax 631.755.0117 www.lewisjohs.com New York City | Long Island 1 of 1