Preview
FILED: NEW YORK COUNTY CLERK 12/23/2023 12:07 AM INDEX NO. 153338/2023
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 12/23/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------X
JOSE ROMERO, Index No. 153338/2023
Plaintiff, FIRST SUPPLEMENTAL
VERIFIED BILL OF
-against- PARTICULARS AS TO
ALL DEFENDANTS
LAWRENCE EXTERIOR RESTORATION CORP.
and THE TRUSTEES OF COLUMBIA UNIVERSITY
IN THE CITY OF NEW YORK,
Defendants.
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Plaintiff, JOSE ROMERO, by his attorneys, THE BONGIORNO LAW FIRM, PLLC, as
and for his First Supplemental Verified Bill of Particulars, as to All Defendants, respectfully
alleges the following:
INJURIES:
LUMBAR SPINE
● LUMBAR DISCECTOMY: Lumbar Spine Discectomy on November 17, 2023, by
Mark Goodstein, MD, at Integrated Specialty ASC:
PREOPERATIVE/POSTOPERATIVE DIAGNOSIS:
(1) Left lumbar radiculopathy;
(2) Herniated nucleus pulposus, L2-L3;
PROCEDURES PERFORMED:
(1) Discectomy, L2-L3;
(2) Nucleus pulposus ablation with bipolar probe;
(3) Annuloplasty using bipolar probe;
(4) Discography, L2-L3;
(5) Interpretation of discography;
(6) Multiplanar fluoroscopy.
PLEASE BE ADVISED that plaintiff expressly reserves the right to amend and/or
supplement the above information should it change or become incomplete.
Dated: Garden City, New York
December 22, 2023
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FILED: NEW YORK COUNTY CLERK 12/23/2023 12:07 AM INDEX NO. 153338/2023
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 12/23/2023
Yours, etc.,
THE BONGIORNO LAW FIRM, PLLC
Brandon M. Cruz
By: ________________________
BRANDON M. CRUZ
Attorneys for Plaintiff
JOSE ROMERO
1415 Kellum Place, Suite 205
Garden City, New York 11530
(516) 741-4170
TO:
SEGAL McCAMBRIDGE SINGER &
MAHONEY, LTD.
Attorneys for Defendant
LAWRENCE EXTERIOR RESTORATION CORP.
777 Third Avenue, Suite 2400
New York, New York 10017
(212) 651-7500
Attorney: Antigone Tzakis, Esq.
Email: atzakis@smsm.com
RIVKIN RADLER LLP
Attorneys for Defendant
THE TRUSTEES OF COLUMBIA UNIVERSITY
IN THE CITY OF NEW YORK
926 RXR Plaza
Uniondale, New York 11556
(516) 357-3289
Attorney: Brian S. Schlosser, Esq.
Email: brian.schlosser@rivkin.com
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FILED: NEW YORK COUNTY CLERK 12/23/2023 12:07 AM INDEX NO. 153338/2023
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 12/23/2023
ATTORNEY VERIFICATION
STATE OF NEW YORK )
) ss.:
COUNTY OF NASSAU )
I, the undersigned, am an attorney admitted to practice in the Courts of the State of New
York, and say that I am a member of THE BONGIORNO LAW FIRM, PLLC, representing the
plaintiff herein and I have read the annexed FIRST SUPPLEMENTAL BILL OF
PARTICULARS and know the contents thereof and the same are true to my knowledge, except
as to the matters therein which are stated to be alleged on information and belief, and as to the
matters I believe them to be true. My belief, as to those matters therein not stated upon knowledge,
is based upon the following:
Files and records in your affirmant's possession, as well as discussions with my client.
The reason this verification is made by me and not by plaintiff is because the plaintiff
resides in a county other than where your affirmant maintains offices.
I affirm that the foregoing statements are true under the penalties of perjury.
Dated: Garden City, New York
December 22, 2023
Brandon M. Cruz
_________________________
BRANDON M. CRUZ, ESQ.
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FILED: NEW YORK COUNTY CLERK 12/23/2023 12:07 AM INDEX NO. 153338/2023
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 12/23/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK INDEX NO.: 153338/2023
JOSE ROMERO,
Plaintiff,
-against-
LAWRENCE EXTERIOR RESTORATION CORP. and
THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK,
Defendants.
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FIRST SUPPLEMENTAL VERIFIED BILL OF PARTICULARS
AS TO ALL DEFENDANTS
THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
JOSE ROMERO
1415 Kellum Place, Suite 205
Garden City, New York 11530
(516) 741-4170
ATTORNEY CERTIFICATION: Pursuant to NYCRR 130-1.1, the undersigned, an attorney
admitted to practice in the Courts of the State of New York, certifies, to the best of his knowledge
after reasonable inquiry, that the contentions contained in the annexed documents are not frivolous.
Brandon M. Cruz
Dated: Garden City, New York By: _______________________________
December 22, 2023 Brandon M. Cruz, Esq.
PLEASE TAKE NOTICE
____ NOTICE OF ENTRY that the within is a true copy of a entered
in the office of the clerk of the within named Court on
____ NOTICE OF SETTLEMENT that an Order of which the within is a true copy will be
presented for settlement to the Hon. one of the judges of the within named Court, on
THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
4 of 4
Preview
FILED: NEW YORK COUNTY CLERK 12/23/2023 12:07 AM INDEX NO. 153338/2023 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 12/23/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------------------------------------------------------------X JOSE ROMERO, Index No. 153338/2023 Plaintiff, FIRST SUPPLEMENTAL VERIFIED BILL OF -against- PARTICULARS AS TO ALL DEFENDANTS LAWRENCE EXTERIOR RESTORATION CORP. and THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK, Defendants. -------------------------------------------------------------------X Plaintiff, JOSE ROMERO, by his attorneys, THE BONGIORNO LAW FIRM, PLLC, as and for his First Supplemental Verified Bill of Particulars, as to All Defendants, respectfully alleges the following: INJURIES: LUMBAR SPINE ● LUMBAR DISCECTOMY: Lumbar Spine Discectomy on November 17, 2023, by Mark Goodstein, MD, at Integrated Specialty ASC: PREOPERATIVE/POSTOPERATIVE DIAGNOSIS: (1) Left lumbar radiculopathy; (2) Herniated nucleus pulposus, L2-L3; PROCEDURES PERFORMED: (1) Discectomy, L2-L3; (2) Nucleus pulposus ablation with bipolar probe; (3) Annuloplasty using bipolar probe; (4) Discography, L2-L3; (5) Interpretation of discography; (6) Multiplanar fluoroscopy. PLEASE BE ADVISED that plaintiff expressly reserves the right to amend and/or supplement the above information should it change or become incomplete. Dated: Garden City, New York December 22, 2023 1 of 4 FILED: NEW YORK COUNTY CLERK 12/23/2023 12:07 AM INDEX NO. 153338/2023 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 12/23/2023 Yours, etc., THE BONGIORNO LAW FIRM, PLLC Brandon M. Cruz By: ________________________ BRANDON M. CRUZ Attorneys for Plaintiff JOSE ROMERO 1415 Kellum Place, Suite 205 Garden City, New York 11530 (516) 741-4170 TO: SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD. Attorneys for Defendant LAWRENCE EXTERIOR RESTORATION CORP. 777 Third Avenue, Suite 2400 New York, New York 10017 (212) 651-7500 Attorney: Antigone Tzakis, Esq. Email: atzakis@smsm.com RIVKIN RADLER LLP Attorneys for Defendant THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK 926 RXR Plaza Uniondale, New York 11556 (516) 357-3289 Attorney: Brian S. Schlosser, Esq. Email: brian.schlosser@rivkin.com 2 of 4 FILED: NEW YORK COUNTY CLERK 12/23/2023 12:07 AM INDEX NO. 153338/2023 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 12/23/2023 ATTORNEY VERIFICATION STATE OF NEW YORK ) ) ss.: COUNTY OF NASSAU ) I, the undersigned, am an attorney admitted to practice in the Courts of the State of New York, and say that I am a member of THE BONGIORNO LAW FIRM, PLLC, representing the plaintiff herein and I have read the annexed FIRST SUPPLEMENTAL BILL OF PARTICULARS and know the contents thereof and the same are true to my knowledge, except as to the matters therein which are stated to be alleged on information and belief, and as to the matters I believe them to be true. My belief, as to those matters therein not stated upon knowledge, is based upon the following: Files and records in your affirmant's possession, as well as discussions with my client. The reason this verification is made by me and not by plaintiff is because the plaintiff resides in a county other than where your affirmant maintains offices. I affirm that the foregoing statements are true under the penalties of perjury. Dated: Garden City, New York December 22, 2023 Brandon M. Cruz _________________________ BRANDON M. CRUZ, ESQ. 3 of 4 FILED: NEW YORK COUNTY CLERK 12/23/2023 12:07 AM INDEX NO. 153338/2023 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 12/23/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK INDEX NO.: 153338/2023 JOSE ROMERO, Plaintiff, -against- LAWRENCE EXTERIOR RESTORATION CORP. and THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK, Defendants. -------------------------------------------------------------------------------------------------------------------- FIRST SUPPLEMENTAL VERIFIED BILL OF PARTICULARS AS TO ALL DEFENDANTS THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff JOSE ROMERO 1415 Kellum Place, Suite 205 Garden City, New York 11530 (516) 741-4170 ATTORNEY CERTIFICATION: Pursuant to NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the Courts of the State of New York, certifies, to the best of his knowledge after reasonable inquiry, that the contentions contained in the annexed documents are not frivolous. Brandon M. Cruz Dated: Garden City, New York By: _______________________________ December 22, 2023 Brandon M. Cruz, Esq. PLEASE TAKE NOTICE ____ NOTICE OF ENTRY that the within is a true copy of a entered in the office of the clerk of the within named Court on ____ NOTICE OF SETTLEMENT that an Order of which the within is a true copy will be presented for settlement to the Hon. one of the judges of the within named Court, on THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 4 of 4