Preview
FILED: NEW YORK COUNTY CLERK 10/24/2023 01:10 PM INDEX NO. 153338/2023
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 10/24/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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JOSE ROMERO, Index No.: 153338/2023
Plaintiff,
DEMAND FOR
- against - AUTHORIZATIONS
LAWRENCE EXTERIOR RESTORATION CORP. AND THE
TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF
NEW YORK,,
Defendant.
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LAWRENCE EXTERIOR RESTORATION CORP.,
Defendant/Third-Party Plaintiff,
-against-
RAMACRI CONTRACTING SERVICES INC.,
Third-Party Defendant(s).
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PLEASE TAKE NOTICE, that pursuant to CPLR 3101, you are required to furnish the
undersigned attorneys for Defendant, LAWRENCE EXTERIOR RESTORATION CORP.,
(hereinafter “Defendant”) by its attorneys, SEGAL McCAMBRIDGE SINGER & MAHONEY,
LTD., within twenty (20) days after receipt of this demand, the following:
1. Written, fully addressed, duly executed, unrestricted as to date, and acknowledged
authorizations which are in full compliance with the Health Insurance Portability and
Accountability Act (“HIPAA”), which became effective on April 14, 2003, enabling SEGAL
McCAMBRIDGE SINGER & MAHONEY, LTD., to obtain plaintiff’s entire medical record
from: Dr. Mark Goodstein, with complete address.
2. Written, fully addressed, duly executed, unrestricted as to date, and acknowledged
authorizations which are in full compliance with the Health Insurance Portability and
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FILED: NEW YORK COUNTY CLERK 10/24/2023 01:10 PM INDEX NO. 153338/2023
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 10/24/2023
Accountability Act (“HIPAA”), which became effective on April 14, 2003, enabling SEGAL
McCAMBRIDGE SINGER & MAHONEY, LTD., to obtain plaintiff’s entire medical record
from: Atlantis Surgery Center, with complete address.
3. Written, fully addressed, duly executed, unrestricted as to date, and acknowledged
authorizations which are in full compliance with the Health Insurance Portability and
Accountability Act (“HIPAA”), which became effective on April 14, 2003, enabling SEGAL
McCAMBRIDGE SINGER & MAHONEY, LTD., to obtain plaintiff’s entire medical record
from: Citimed Diagnostic, with complete address.
4. Written, fully addressed, duly executed, unrestricted as to date, and acknowledged
authorizations which are in full compliance with the Health Insurance Portability and
Accountability Act (“HIPAA”), which became effective on April 14, 2003, enabling SEGAL
McCAMBRIDGE SINGER & MAHONEY, LTD., to obtain plaintiff’s entire medical record
from: Citimed Complete Medical Care, with complete address.
PLEASE TAKE FURTHER NOTICE, that your failure to comply with this demand will
result in your being precluded from offering the demanded items or introducing testimony based
on said items at the trial of this action.
Dated: New York, New York
October 23, 2023
SEGAL McCAMBRIDGE SINGER &
MAHONEY, LTD.
By: /s/ Antigone Tzakis
Antigone Tzakis, Esq.
Attorneys for Defendant/Third-Party Plaintiff
LAWRENCE EXTERIOR RESTORATION CORP.
777 Third Avenue, Suite 2400
New York, NY 10017
T: (212) 651-7445
E: atzakis@smsm.com
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FILED: NEW YORK COUNTY CLERK 10/24/2023 01:10 PM INDEX NO. 153338/2023
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 10/24/2023
TO:
THE BONGIORNO LAW FIRM, PLLC
Brandon M. Cruz, Esq.
Attorneys for Plaintiff
JOSE ROMERO
1415 Kellum Place, Suite 205
Garden City, NY 11530
(516) 741-4170
bcruz@bongiornolawfirm.com
RIVKIN RADLER LLP
Brian S. Schlosser, Esq.
Attorneys for Defendant
THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK
926 Rxr Plaza
Uniondale, NY 11556
(516) 357-3289
Brian.schlosser@rivkin.com
Third-Party Defendant
RAMACRI CONTRACTING SERVICES INC.
37-20 87th Street Apartment 4G
Jackson Heights, New York 11372
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Preview
FILED: NEW YORK COUNTY CLERK 10/24/2023 01:10 PM INDEX NO. 153338/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 10/24/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------------------------------------------X JOSE ROMERO, Index No.: 153338/2023 Plaintiff, DEMAND FOR - against - AUTHORIZATIONS LAWRENCE EXTERIOR RESTORATION CORP. AND THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK,, Defendant. ---------------------------------------------------------------------------X LAWRENCE EXTERIOR RESTORATION CORP., Defendant/Third-Party Plaintiff, -against- RAMACRI CONTRACTING SERVICES INC., Third-Party Defendant(s). ----------------------------------------------------------------------------X PLEASE TAKE NOTICE, that pursuant to CPLR 3101, you are required to furnish the undersigned attorneys for Defendant, LAWRENCE EXTERIOR RESTORATION CORP., (hereinafter “Defendant”) by its attorneys, SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD., within twenty (20) days after receipt of this demand, the following: 1. Written, fully addressed, duly executed, unrestricted as to date, and acknowledged authorizations which are in full compliance with the Health Insurance Portability and Accountability Act (“HIPAA”), which became effective on April 14, 2003, enabling SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD., to obtain plaintiff’s entire medical record from: Dr. Mark Goodstein, with complete address. 2. Written, fully addressed, duly executed, unrestricted as to date, and acknowledged authorizations which are in full compliance with the Health Insurance Portability and 1 of 3 FILED: NEW YORK COUNTY CLERK 10/24/2023 01:10 PM INDEX NO. 153338/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 10/24/2023 Accountability Act (“HIPAA”), which became effective on April 14, 2003, enabling SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD., to obtain plaintiff’s entire medical record from: Atlantis Surgery Center, with complete address. 3. Written, fully addressed, duly executed, unrestricted as to date, and acknowledged authorizations which are in full compliance with the Health Insurance Portability and Accountability Act (“HIPAA”), which became effective on April 14, 2003, enabling SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD., to obtain plaintiff’s entire medical record from: Citimed Diagnostic, with complete address. 4. Written, fully addressed, duly executed, unrestricted as to date, and acknowledged authorizations which are in full compliance with the Health Insurance Portability and Accountability Act (“HIPAA”), which became effective on April 14, 2003, enabling SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD., to obtain plaintiff’s entire medical record from: Citimed Complete Medical Care, with complete address. PLEASE TAKE FURTHER NOTICE, that your failure to comply with this demand will result in your being precluded from offering the demanded items or introducing testimony based on said items at the trial of this action. Dated: New York, New York October 23, 2023 SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD. By: /s/ Antigone Tzakis Antigone Tzakis, Esq. Attorneys for Defendant/Third-Party Plaintiff LAWRENCE EXTERIOR RESTORATION CORP. 777 Third Avenue, Suite 2400 New York, NY 10017 T: (212) 651-7445 E: atzakis@smsm.com 2 of 3 FILED: NEW YORK COUNTY CLERK 10/24/2023 01:10 PM INDEX NO. 153338/2023 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 10/24/2023 TO: THE BONGIORNO LAW FIRM, PLLC Brandon M. Cruz, Esq. Attorneys for Plaintiff JOSE ROMERO 1415 Kellum Place, Suite 205 Garden City, NY 11530 (516) 741-4170 bcruz@bongiornolawfirm.com RIVKIN RADLER LLP Brian S. Schlosser, Esq. Attorneys for Defendant THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK 926 Rxr Plaza Uniondale, NY 11556 (516) 357-3289 Brian.schlosser@rivkin.com Third-Party Defendant RAMACRI CONTRACTING SERVICES INC. 37-20 87th Street Apartment 4G Jackson Heights, New York 11372 3 of 3