On May 25, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Ann Marie Turner,
and
Moshim Kukar Md,
Roswell Park Cancer Institute Corporation,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 05/25/2021 11:49 PM INDEX NO. 806930/2021
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/25/2021
EXHIBIT “D”
FILED: ERIE COUNTY CLERK 05/25/2021 11:49 PM INDEX NO. 806930/2021
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/25/2021
LAW OFFICE OF
KEVIN T. STOCKER, Esq. PC
2645 Sheridan Drive
Tonawanda, New York 14150
Telephone: (716) 832-3006 / Fax:
(716) 832-3660
Email: kstockeresq@vahoo.com
May 18, 2021
CERTIFIED MAIL
Roswell Park Cancer Institute
Elm & Carlton Streets
Buffalo, New York 14263
Re: Notice of Claim for ANN MARIE TURNER
Date of Accident: 2/26/2020
Last Treatment: 5/18/2021
Dear Sir or Madam:
The following Notice of Claim is being submitted on behalf of Ann Marie Turner for the personal
injuries she suffered as a result of a botched thyroidectomy at Roswell Park Cancer Institute on February 26,
2020 which left the surgery as incomplete and her recurrent laryngeal nerve severed. The Notice of Claim is
set forth as follows:
1. Name and Address of Claiman_t: Ann Marie Turner ("Claimant"), who resides at 27
Marilyn Court, Tonawanda, New York 14150.
2. Nature of Claims: Negligence / Medical Malpractice; Lack of Informed Consent.
3. Time. Place & Manner: Claimant suffered personal injuries to her recurrent laryngeal
nerve as a result of an unsuccessful thyroidectomy surgery. Said surgery took place at
Roswell Park Cancer Institute on February 26, 2020, and Plaintiff's treatment there
started in January of 2020 and continued through May of 2021.
4. Items of Damage or Injuries Claimed: Personal injuries in excess of $50,000,
including labored breathing, loss of voice, and laryngeal spasms.
Respectf
Ann Marie Turne
Swo n to before me t
ft f May, 1
KEVIN B. CAMPBELL
Notary Public, State of New York
Reg. No. 02CA6305315
Notary ic ouaimed in Erie County
Commission Expires June 9, 20
Document Filed Date
May 25, 2021
Case Filing Date
May 25, 2021
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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FILED: ERIE COUNTY CLERK 05/25/2021 11:49 PM INDEX NO. 806930/2021 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/25/2021 EXHIBIT “D” FILED: ERIE COUNTY CLERK 05/25/2021 11:49 PM INDEX NO. 806930/2021 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/25/2021 LAW OFFICE OF KEVIN T. STOCKER, Esq. PC 2645 Sheridan Drive Tonawanda, New York 14150 Telephone: (716) 832-3006 / Fax: (716) 832-3660 Email: kstockeresq@vahoo.com May 18, 2021 CERTIFIED MAIL Roswell Park Cancer Institute Elm & Carlton Streets Buffalo, New York 14263 Re: Notice of Claim for ANN MARIE TURNER Date of Accident: 2/26/2020 Last Treatment: 5/18/2021 Dear Sir or Madam: The following Notice of Claim is being submitted on behalf of Ann Marie Turner for the personal injuries she suffered as a result of a botched thyroidectomy at Roswell Park Cancer Institute on February 26, 2020 which left the surgery as incomplete and her recurrent laryngeal nerve severed. The Notice of Claim is set forth as follows: 1. Name and Address of Claiman_t: Ann Marie Turner ("Claimant"), who resides at 27 Marilyn Court, Tonawanda, New York 14150. 2. Nature of Claims: Negligence / Medical Malpractice; Lack of Informed Consent. 3. Time. Place & Manner: Claimant suffered personal injuries to her recurrent laryngeal nerve as a result of an unsuccessful thyroidectomy surgery. Said surgery took place at Roswell Park Cancer Institute on February 26, 2020, and Plaintiff's treatment there started in January of 2020 and continued through May of 2021. 4. Items of Damage or Injuries Claimed: Personal injuries in excess of $50,000, including labored breathing, loss of voice, and laryngeal spasms. Respectf Ann Marie Turne Swo n to before me t ft f May, 1 KEVIN B. CAMPBELL Notary Public, State of New York Reg. No. 02CA6305315 Notary ic ouaimed in Erie County Commission Expires June 9, 20