On March 07, 2024 a
Petition
was filed
involving a dispute between
In The Matter Of The Application Of Micheline Nakhleh,
and
And The Guirguis Obstetrics & Gynecology Group,
Peter Guiguis Md,
for Special Proceedings - Other (Compel Production of Doc)
in the District Court of Richmond County.
Preview
FILED: RICHMOND COUNTY CLERK 03/07/2024 03:32 PM INDEX NO. 85053/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/07/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
_______________________________________________________________________Ç
In the Matter of the Application of Micheline Nakhleh
PETITION
Petitioner,
-against-
Index No.:
The Guirguis Obstetrics & Gynecology Group and
Peter Guirguis, M.D.,
Respondents,
___________________________________..___________________________________Ç
STATE OF NEW YORK )
SS:
COUNTY OF RICHMOND )
The Petitioner, Micheline Nakhleh, having been duly sworn, deposes and says:
1. On April 18, 2023, I signed a retainer agreement with the law firm of Bonina &
Bonina, P.C. This retainer was signed in order to have the law firm of Bonina & Bonina, P.C.
investigate a potential medical malpractice claim on my behalf.
2. On that same date, I signed numerous authorizations allowing my attorneys, Bonina &
Bonina, P.C., to obtain any and all medical records they felt relevant to this particular claim.
3. My attorneys have informed me that pursuant to the laws of the State ofNew York, I am
entitled to receive a complete set of any and all records maintained by the Respondents in
connection with the treatment rendered.
4. I make this application to the Court, so that the Court may grant this Order, and so that
my attorneys may further investigate any potential medical malpractice claim.
5. No previous application for this relief has been made to this or any other Court or
Justice.
(00298537}
1 of 3
FILED: RICHMOND COUNTY CLERK 03/07/2024 03:32 PM INDEX NO. 85053/2024
NYSCEF
.
DOC. NO. 1 RECEIVED NYSCEF: 03/07/2024
WHEREFORE, your Petitioner respectfully prays this Court will direct the Respondents
to produce all records, documents and evidence cited in this Petition, which are necessary to
identify the proposed defendants and to frame proper pleadings in a lawsuit to be brought, and for
such other and further relief as to this Court shall seem just, proper and equitable.
Micheline Nakhleh
Sworn to bef re me this .
day of , 2024
. Nicholas Diamantis
Not Pubhe Notary Pu i , t INew York
Qualified in Richmond Coun
Commission Expires October 18, 20
{00298537}
2 of 3
FILED: RICHMOND COUNTY CLERK 03/07/2024 03:32 PM INDEX NO. 85053/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/07/2024
. . .
State of New York )
SS:
County of RICHMOND)
Micheline Nakhleh, having been duly sworn, deposes and says: That your deponent is the
Petitioner in the within proceeding and that deponent has read the foregoing Petition and knows the
contents thereof and that the same is true to deponent's own knowledge except as those matters
therein stated to be upon and belief, and those matters deponent believes to be true.
Micheline Nakhleh
Sworn to before me this
of , 2024 Nicholas Diamantis
day
NotaryPublic, State of New York
01010014498
Quanned in Richmond County
C Expkes October 18, 20
Notary Public
{00298537}
3 of 3
Document Filed Date
March 07, 2024
Case Filing Date
March 07, 2024
Category
Special Proceedings - Other (Compel Production of Doc)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: RICHMOND COUNTY CLERK 03/07/2024 03:32 PM INDEX NO. 85053/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/07/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND _______________________________________________________________________Ç In the Matter of the Application of Micheline Nakhleh PETITION Petitioner, -against- Index No.: The Guirguis Obstetrics & Gynecology Group and Peter Guirguis, M.D., Respondents, ___________________________________..___________________________________Ç STATE OF NEW YORK ) SS: COUNTY OF RICHMOND ) The Petitioner, Micheline Nakhleh, having been duly sworn, deposes and says: 1. On April 18, 2023, I signed a retainer agreement with the law firm of Bonina & Bonina, P.C. This retainer was signed in order to have the law firm of Bonina & Bonina, P.C. investigate a potential medical malpractice claim on my behalf. 2. On that same date, I signed numerous authorizations allowing my attorneys, Bonina & Bonina, P.C., to obtain any and all medical records they felt relevant to this particular claim. 3. My attorneys have informed me that pursuant to the laws of the State ofNew York, I am entitled to receive a complete set of any and all records maintained by the Respondents in connection with the treatment rendered. 4. I make this application to the Court, so that the Court may grant this Order, and so that my attorneys may further investigate any potential medical malpractice claim. 5. No previous application for this relief has been made to this or any other Court or Justice. (00298537} 1 of 3 FILED: RICHMOND COUNTY CLERK 03/07/2024 03:32 PM INDEX NO. 85053/2024 NYSCEF . DOC. NO. 1 RECEIVED NYSCEF: 03/07/2024 WHEREFORE, your Petitioner respectfully prays this Court will direct the Respondents to produce all records, documents and evidence cited in this Petition, which are necessary to identify the proposed defendants and to frame proper pleadings in a lawsuit to be brought, and for such other and further relief as to this Court shall seem just, proper and equitable. Micheline Nakhleh Sworn to bef re me this . day of , 2024 . Nicholas Diamantis Not Pubhe Notary Pu i , t INew York Qualified in Richmond Coun Commission Expires October 18, 20 {00298537} 2 of 3 FILED: RICHMOND COUNTY CLERK 03/07/2024 03:32 PM INDEX NO. 85053/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/07/2024 . . . State of New York ) SS: County of RICHMOND) Micheline Nakhleh, having been duly sworn, deposes and says: That your deponent is the Petitioner in the within proceeding and that deponent has read the foregoing Petition and knows the contents thereof and that the same is true to deponent's own knowledge except as those matters therein stated to be upon and belief, and those matters deponent believes to be true. Micheline Nakhleh Sworn to before me this of , 2024 Nicholas Diamantis day NotaryPublic, State of New York 01010014498 Quanned in Richmond County C Expkes October 18, 20 Notary Public {00298537} 3 of 3