Preview
FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
______________________________________________________________________________Ç
SUSAN PIAZZA,
Plaintiffs, Index No.: 619418/21
-against- CPLR NOTICE
2303(a)
CARA F. VINCI, EAN HOLDINGS, LLC., d/b/a Enterprise
Rent-A-Car, SNORAC, LLC., d/b/a Enterprise Rent-A-Car,
ASURION LLC., d /a New Asurion Corporation,
Defendants.
______________________________________________________________________________Ç
PLEASE TAKE NOTICE, that the plaintiff(s) attach hereto a copy of each Subpoena
Duces Tecum to be served in the above action as of the date of this Notice.
Dated: Lake Grove, New York
April 8, 2024
Yours, etc.
ichael A. Raimdnd , sq.
THE RAIMONDO LAW FIRM
Attorneys for Plaintiff
2780 Middle Country Road, Suite 312
Lake Grove, New York 11755
TO: MARTYN, SMITH & MURRAY, ESQS.
Attorneys for Defendants
102 Motor Parkway, Ste. 230
Hauppauge, NY 11788
1 of 21
FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024
.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
_________________-_______________________________..______________..___________Ç
Index No.: 619418/21
SUSAN PIAZZA '
Calendar No.: 202400393MV
Plaintiffs,
-against- JUDICIAL SUBPOENA
DUCES TECUM
CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise
Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car.
ASURION LLC, d/b/a New Asurion Corporation,
Defendants.
---------------------------------------------------------------------------X
TO: North Shore Surgi-Center
989 W. Jericho Turnpike
Smithtown, NY 11787
WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before
15*
THE RAIMONDO LAW FIRM, 2780 Middle Country Road, Suite 312, NY 11755, on day of May of2024 at
9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this
action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid:
physicians'
Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes,
nurses'
notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports,
bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports,
hospital charts, hospital records, emergency room records, in-patientrecords, out-patient records, progress records,
operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with
respect to the treatment of the following:
Patient: Susan Piazza
Date of Birth: 05/31/62
Date of Accident: 8/25/21
Date of Service: 11/16/21
now in your custody, and all other deeds, evidences and writings, which you have in your custody or power,
concerning the premises. The records demanded in this subpoena must be provided only if accompanied by
written authorization for their release, or if accompanied by court order directing production of the
documents.2
Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on
whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of
your failure to comply.
Witness, Honorable Presiding Justice, one of the Justices of saj,dfo at S k County Supreme Court, on April 8,
2024.
You do not need to appear. /THE AIMON O LAW FIRM
You may comply with this subpoena By: MICHAEL A. RAIMONDO
by sending certified copy of the records to: Attorneys for Plaintiff
THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312
2780 Middle Country Road, Suite 312 Lake NY 11755
Grove,
Lake Grove, NY 11755
631-471-1222
Please melude a copy of subpoena.
2 CPLR
2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attomey or
self-represented party at the retum address set forth in the subpoena, a copy of the subpoena shall be served upon all parties
simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the
same format to all opposing counsel and self-represented parties where applicable, forthwith.
2 of 21
FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
__________________________________-__________________..______________________Ç
Index No.: 619418/21
SUSAN PIAZZA '
Calendar No.: 202400393MV
Plaintiffs,
JUDICIAL SUBPOENA
-against-
DUCES TECUM
CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise
Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car.
ASURION LLC, d/b/a New Asurion Corporation,
Defendants.
____________________________________________________________________________Ç
TO: North Shore Surgi-Center
989 W. Jericho Turnpike
Smithtown, NY 11787
WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before
LAW FIRM, 154
THE RAIMONDO 2780 Middle Country Road, Suite 312, NY 11755, on day of May of2024 at
9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this
action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid:
physicians'
Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes,
nurses'
notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports,
bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports,
hospital charts, hospital records, emergency room records, in-patient records, out-patient records, progress records,
operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with
respect to the treatment of the following:
Patient: Susan Piazza
Date of Birth: 05/31/62
Date of Accident: 8/25/21
Date of Service: 2/1/22
now in your custody, and all other deeds, evidences and writings, which you have in your custody or power,
concerning the premises. The records demanded in this subpoena must be provided only if accompanied by
written authorization for their release, or if accompanied by court order directing production of the
documents.3
Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on
whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of
your failure to comply.
Witness, Honorable Presiding Justice, one of the Justices of sai urt, a ffolk County Supreme Court, on April 8,
2024.
You do not need to appear. frH IM DO LAW FIRM
You maycomply with this subpoena By: MICHAEL A. RAIMONDO
by sending certified copy of the records to: Attorneys for Plaintiff
THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312
2780 Middle
Country Road, Suite 312 Lake NY 11755
Grove,
Lake Grove, NY 11755
1 631-471-1222
Please include a copy of subpoena.
3 CPLR
2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attorney or
self-represented party at the retum address set forth in the subpoena, a copy of the subpoena shall be served upon all parties
simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the
same format to all opposing counsel and self-represented parties where applicable, forthwith.
3 of 21
FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
______________________________________________________________________x
Index No.: 619418/21
SUSAN PIAZZA '
Calendar No.: 202400393MV
Plaintiffs,
-against- JUDICIAL SUBPOENA
DUCES TECUM
CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise
Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car.
ASURION LLC, d/b/a New Asurion Corporation,
Defendants.
__.._______.._________________________________________________________Ç
TO: North Shore Surgi-Center
989 W. Jericho Turnpike
Smithtown, NY I 1787
WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before
RAIMONDO LAW FIRM, 15*
THE 2780 Middle Country Road, Suite 312, NY 11755, on day of May of 2024 at
9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this
action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid:
physicians'
Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes,
nurses'
notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports,
bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports,
hospital charts, hospital records, emergency room records, in-patientrecords, out-patient records, progress records,
operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with
respect to the treatment of the following:
Patient: Susan Piazza
Date of Birth: 05/31/62
Date of Accident: 8/25/21
Date of Service: 4/8/22
now in your custody, and all other deeds, evidences and writings, which you have in your custody or power,
concerning the premises. The records demanded in this subpoena must be provided only if accom panied by
written authorization for their release, or if accompanied by court order directing production of the
documents.4
Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on
whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of
your failure to comply.
Witness, Honorable Presiding Justice, one of the Justices of said rt, at Suf lk County Supreme Court, on April 8,
2024.
You do not need to appear. (HEffAl 40N LAW FIRM
You may comply with this subpoena By: MICHAEL A. RAIMONDO
by sending certified copy of the records to: Attorneys for Plaintiff
THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312
2780 Middle Country Road, Suite 312 Lake NY 11755
Grove,
Lake Grove, NY 11755
1 631-471-1222
Please include a copy of subpoena.
4 CPLR
2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attorney or
self-represented party at the return address set forth in the subpoena, a copy of the subpoena shall be served upon all parties
simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the
same format to all opposing counsel and self-represented parties where applicable, forthwith.
4 of 21
FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024
.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
____________________________________________________________________________Ç
Index No.: 619418/21
SUSAN PIAZZA
Calendar No.: 202400393MV
Plaintiffs,
-against- JUDICIAL SUBPOENA
DUCES TECUM
CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise
Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car.
ASURION LLC, d/b/a New Asurion Corporation,
Defendants.
____________________________________________________________________________Ç
TO: Mt. Sinai Hospital
1 Gustave Levy Place
New York, NY 10029
WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before
LAW FIRM, 155
THE RAIMONDO 2780 Middle Country Road, Suite 312, NY 11755, on day of May of 2024 at
9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this
action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid:
physicians'
Copies of all medical records, medical reports, medical
charts, offices records, offices notes, written notes,
nurses'
notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports,
bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports,
hospital charts, hospital records, emergency room records, in-patient records, out-patient records, progress records,
operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with
respect to the treatment of the following:
Patient: Susan Piazza
Date of Birth: 05/31/62
Date of Accident: 8/25/21
now in your custody, and all other deeds, evidences and writings, which you have in your custody or power,
concerning the premises. The records demanded in this subpoena must be provided only if accom panied by
written authorization for their release, or if accom panied by court order directing production of the
documents.5
Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on
whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of
your failure to comply.
Witness, Honorable Presiding Justice, one of the Justices of s Court, at ffolk County Supreme Court, on April 8,
2024.
You do not need to appear. NI ,/XAIMO DO LAW FIRM
You maycomply with this subpoena B . MICHA L A. RAIMONDO
by sending certified copy of the records to: Attorneys for Plaintiff
THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312
2780 Middle
Country Road, Suite 312 Lake NY 11755
Grove,
Lake Grove, NY 11755
631-471-1222
Please melude a copy of subpoena.
8 CPLR
2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attomey or
self-represented party at the retum address set forth in the subpoena, a copy of the subpoena shall be served upon all parties
simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the
same format to all opposing counsel and self-represented parties where applicable, forthwith.
5 of 21
FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024
.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
_____________________________________________________________________Ç
Index No.: 619418/21
SUSAN PIAZZA
Calendar No.: 202400393MV
Plaintiffs,
-against- JUDICIAL SUBPOENA
DUCES TECUM
CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise
Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car.
ASURION LLC, d/b/a New Asurion Corporation,
Defendants.
_______________________________________________________________Ç
TO: Mirza Orthopedics
290 E. Main Street, Ste. 200
Smithtown, NY 11787
WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before
RAIMONDO LAW FIRM, 15*
THE 2780 Middle Country Road, Suite 312, NY 11755, on day of May of 2024 at
9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this
action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid:
physicians'
Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes,
nurses'
notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports,
bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports,
hospital charts, hospital records, emergency room records, in-patient records, out-patient records, progress records,
operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with
respect to the treatment of the following:
Patient: Susan Piazza
Date of Birth: 05/31/62
Date of Accident: 8/25/21
now in your custody, and all other deeds, evidences and writings, which you have in your custody or power,
concerning the premises. The records demanded in this subpoena must be provided only if accompanied by
written authorization for their release, or if accompanied by court order directing production of the
documents.6
Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on
whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of
your failure to comply.
Honorable one of the Justices of said Co t Suffol - Supreme on April
Witness, Presiding Justice, ounty Court, 8,
2024.
You do not need to appear. T RAIMOND AW FIRM
You may comply with this subpoena y: MICHAEL A. RAIMONDO
by sending certified copy of the records to: Attorneys for Plaintiff
THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312
2780 Middle Country Road, Suite 312 Lake NY 11755
Grove,
Lake Grove, NY 11755
1 631-471-1222
Please melude a copy of subpoena.
' CPLR
2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attorney or
self-represented party at the return address set forth in the subpoena, a copy of the subpoena shall be served upon all parties
simultaneously and the party receiving such subpoenaed records, in any forrnat, shall deliver a complete copy of such records in the
same format to all opposing counsel and self-represented parties where applicable, forthwith.
6 of 21
FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024
. .
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
_____________________________________________________-______.______________Ç
SUSAN PIAZZA
Calendar No.: 202400393MV
Plaintiffs,
-against- JUDICIAL SUBPOENA
DUCES TECUM
CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise
Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car.
ASURION LLC, d/b/a New Asurion Corporation,
Defendants.
_______________________________________________..___________________________Ç
TO: Dr. Walsh
98* 96
5 East Street, Floor
New York, NY 10029
WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before
THE RAIMONDO LAW FIRM, 155
2780 Middle Country Road, Suite 312, NY 11755, on day of May of2024 at
9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this
action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid:
physicians'
Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes,
nurses'
notes, laboratory reports, x-rays/radiographic films and reports, MM films and reports, CT scans and reports,
bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports,
hospital charts, hospital records, emergency room records, in-patientrecords, out-patient records, progress records,
operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with
respect to the treatment of the following:
Patient: Susan Piazza
Date of Birth: 05/31/62
Date of Accident: 8/25/21
now in your custody, and all other deeds, evidences and writings, which you have in your custody or power,
concerning the premises. The records demanded in this subpoena must be provided only if accompanied by
written authorization for their release, or if accompanied by court order directing production of the
documents.7
Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on
whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of
your failure to comply.
Witness, Honorable Presiding Justice, one of the Justices of said rt, at Suffolk County Supreme Court, on April 8,
2024.
You do not need to appear. T 1 ÅIMON O LAW FIRM
You maycomply with this subpoena y: MICHAEL A. RAIMONDO
by sending certified copy of the records to: Attorneys for Plaintiff
THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312
2780 Middle
Country Road, Suite 312 Lake Grove, NY 11755
Lake Grove, NY 11755
631-471-1222
Please melude a copy of subpoena.1
7 CPLR
2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attorney or
self-represented party at the retum address set forth in the subpoena, a copy of the subpoena shall be served upon all parties
simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the
same format to all opposing counsel and self-represented parties where applicable, forthwith.
7 of 21
FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
__________________________________________________________________________Ç
Index No.: 619418/21
SUSAN PIAZZA
Calendar No.: 202400393MV
Plaintiffs,
-against- JUDICIAL SUBPOENA
DUCES TECUM
CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise
Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car.
ASURION LLC, d /a New Asurion Corporation,
Defendants.
_______________________________________________________________________Ç
TO: Dr. Eric Klein
250 E. Main Street
Bay Shore, NY 1 1706
WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before
THE RAIMONDO LAW FIRM, 2780 Middle Country Road, Suite312, NY 11755, on 15th day of May of 2024 at
9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this
action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid:
physicians'
Copies o
Preview
FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ______________________________________________________________________________Ç SUSAN PIAZZA, Plaintiffs, Index No.: 619418/21 -against- CPLR NOTICE 2303(a) CARA F. VINCI, EAN HOLDINGS, LLC., d/b/a Enterprise Rent-A-Car, SNORAC, LLC., d/b/a Enterprise Rent-A-Car, ASURION LLC., d /a New Asurion Corporation, Defendants. ______________________________________________________________________________Ç PLEASE TAKE NOTICE, that the plaintiff(s) attach hereto a copy of each Subpoena Duces Tecum to be served in the above action as of the date of this Notice. Dated: Lake Grove, New York April 8, 2024 Yours, etc. ichael A. Raimdnd , sq. THE RAIMONDO LAW FIRM Attorneys for Plaintiff 2780 Middle Country Road, Suite 312 Lake Grove, New York 11755 TO: MARTYN, SMITH & MURRAY, ESQS. Attorneys for Defendants 102 Motor Parkway, Ste. 230 Hauppauge, NY 11788 1 of 21 FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024 . SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK _________________-_______________________________..______________..___________Ç Index No.: 619418/21 SUSAN PIAZZA ' Calendar No.: 202400393MV Plaintiffs, -against- JUDICIAL SUBPOENA DUCES TECUM CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car. ASURION LLC, d/b/a New Asurion Corporation, Defendants. ---------------------------------------------------------------------------X TO: North Shore Surgi-Center 989 W. Jericho Turnpike Smithtown, NY 11787 WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before 15* THE RAIMONDO LAW FIRM, 2780 Middle Country Road, Suite 312, NY 11755, on day of May of2024 at 9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid: physicians' Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes, nurses' notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports, bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports, hospital charts, hospital records, emergency room records, in-patientrecords, out-patient records, progress records, operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with respect to the treatment of the following: Patient: Susan Piazza Date of Birth: 05/31/62 Date of Accident: 8/25/21 Date of Service: 11/16/21 now in your custody, and all other deeds, evidences and writings, which you have in your custody or power, concerning the premises. The records demanded in this subpoena must be provided only if accompanied by written authorization for their release, or if accompanied by court order directing production of the documents.2 Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of your failure to comply. Witness, Honorable Presiding Justice, one of the Justices of saj,dfo at S k County Supreme Court, on April 8, 2024. You do not need to appear. /THE AIMON O LAW FIRM You may comply with this subpoena By: MICHAEL A. RAIMONDO by sending certified copy of the records to: Attorneys for Plaintiff THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312 2780 Middle Country Road, Suite 312 Lake NY 11755 Grove, Lake Grove, NY 11755 631-471-1222 Please melude a copy of subpoena. 2 CPLR 2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attomey or self-represented party at the retum address set forth in the subpoena, a copy of the subpoena shall be served upon all parties simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the same format to all opposing counsel and self-represented parties where applicable, forthwith. 2 of 21 FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK __________________________________-__________________..______________________Ç Index No.: 619418/21 SUSAN PIAZZA ' Calendar No.: 202400393MV Plaintiffs, JUDICIAL SUBPOENA -against- DUCES TECUM CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car. ASURION LLC, d/b/a New Asurion Corporation, Defendants. ____________________________________________________________________________Ç TO: North Shore Surgi-Center 989 W. Jericho Turnpike Smithtown, NY 11787 WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before LAW FIRM, 154 THE RAIMONDO 2780 Middle Country Road, Suite 312, NY 11755, on day of May of2024 at 9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid: physicians' Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes, nurses' notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports, bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports, hospital charts, hospital records, emergency room records, in-patient records, out-patient records, progress records, operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with respect to the treatment of the following: Patient: Susan Piazza Date of Birth: 05/31/62 Date of Accident: 8/25/21 Date of Service: 2/1/22 now in your custody, and all other deeds, evidences and writings, which you have in your custody or power, concerning the premises. The records demanded in this subpoena must be provided only if accompanied by written authorization for their release, or if accompanied by court order directing production of the documents.3 Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of your failure to comply. Witness, Honorable Presiding Justice, one of the Justices of sai urt, a ffolk County Supreme Court, on April 8, 2024. You do not need to appear. frH IM DO LAW FIRM You maycomply with this subpoena By: MICHAEL A. RAIMONDO by sending certified copy of the records to: Attorneys for Plaintiff THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312 2780 Middle Country Road, Suite 312 Lake NY 11755 Grove, Lake Grove, NY 11755 1 631-471-1222 Please include a copy of subpoena. 3 CPLR 2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attorney or self-represented party at the retum address set forth in the subpoena, a copy of the subpoena shall be served upon all parties simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the same format to all opposing counsel and self-represented parties where applicable, forthwith. 3 of 21 FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ______________________________________________________________________x Index No.: 619418/21 SUSAN PIAZZA ' Calendar No.: 202400393MV Plaintiffs, -against- JUDICIAL SUBPOENA DUCES TECUM CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car. ASURION LLC, d/b/a New Asurion Corporation, Defendants. __.._______.._________________________________________________________Ç TO: North Shore Surgi-Center 989 W. Jericho Turnpike Smithtown, NY I 1787 WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before RAIMONDO LAW FIRM, 15* THE 2780 Middle Country Road, Suite 312, NY 11755, on day of May of 2024 at 9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid: physicians' Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes, nurses' notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports, bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports, hospital charts, hospital records, emergency room records, in-patientrecords, out-patient records, progress records, operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with respect to the treatment of the following: Patient: Susan Piazza Date of Birth: 05/31/62 Date of Accident: 8/25/21 Date of Service: 4/8/22 now in your custody, and all other deeds, evidences and writings, which you have in your custody or power, concerning the premises. The records demanded in this subpoena must be provided only if accom panied by written authorization for their release, or if accompanied by court order directing production of the documents.4 Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of your failure to comply. Witness, Honorable Presiding Justice, one of the Justices of said rt, at Suf lk County Supreme Court, on April 8, 2024. You do not need to appear. (HEffAl 40N LAW FIRM You may comply with this subpoena By: MICHAEL A. RAIMONDO by sending certified copy of the records to: Attorneys for Plaintiff THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312 2780 Middle Country Road, Suite 312 Lake NY 11755 Grove, Lake Grove, NY 11755 1 631-471-1222 Please include a copy of subpoena. 4 CPLR 2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attorney or self-represented party at the return address set forth in the subpoena, a copy of the subpoena shall be served upon all parties simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the same format to all opposing counsel and self-represented parties where applicable, forthwith. 4 of 21 FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024 . SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ____________________________________________________________________________Ç Index No.: 619418/21 SUSAN PIAZZA Calendar No.: 202400393MV Plaintiffs, -against- JUDICIAL SUBPOENA DUCES TECUM CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car. ASURION LLC, d/b/a New Asurion Corporation, Defendants. ____________________________________________________________________________Ç TO: Mt. Sinai Hospital 1 Gustave Levy Place New York, NY 10029 WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before LAW FIRM, 155 THE RAIMONDO 2780 Middle Country Road, Suite 312, NY 11755, on day of May of 2024 at 9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid: physicians' Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes, nurses' notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports, bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports, hospital charts, hospital records, emergency room records, in-patient records, out-patient records, progress records, operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with respect to the treatment of the following: Patient: Susan Piazza Date of Birth: 05/31/62 Date of Accident: 8/25/21 now in your custody, and all other deeds, evidences and writings, which you have in your custody or power, concerning the premises. The records demanded in this subpoena must be provided only if accom panied by written authorization for their release, or if accom panied by court order directing production of the documents.5 Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of your failure to comply. Witness, Honorable Presiding Justice, one of the Justices of s Court, at ffolk County Supreme Court, on April 8, 2024. You do not need to appear. NI ,/XAIMO DO LAW FIRM You maycomply with this subpoena B . MICHA L A. RAIMONDO by sending certified copy of the records to: Attorneys for Plaintiff THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312 2780 Middle Country Road, Suite 312 Lake NY 11755 Grove, Lake Grove, NY 11755 631-471-1222 Please melude a copy of subpoena. 8 CPLR 2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attomey or self-represented party at the retum address set forth in the subpoena, a copy of the subpoena shall be served upon all parties simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the same format to all opposing counsel and self-represented parties where applicable, forthwith. 5 of 21 FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024 . SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK _____________________________________________________________________Ç Index No.: 619418/21 SUSAN PIAZZA Calendar No.: 202400393MV Plaintiffs, -against- JUDICIAL SUBPOENA DUCES TECUM CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car. ASURION LLC, d/b/a New Asurion Corporation, Defendants. _______________________________________________________________Ç TO: Mirza Orthopedics 290 E. Main Street, Ste. 200 Smithtown, NY 11787 WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before RAIMONDO LAW FIRM, 15* THE 2780 Middle Country Road, Suite 312, NY 11755, on day of May of 2024 at 9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid: physicians' Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes, nurses' notes, laboratory reports, x-rays/radiographic films and reports, MRI films and reports, CT scans and reports, bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports, hospital charts, hospital records, emergency room records, in-patient records, out-patient records, progress records, operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with respect to the treatment of the following: Patient: Susan Piazza Date of Birth: 05/31/62 Date of Accident: 8/25/21 now in your custody, and all other deeds, evidences and writings, which you have in your custody or power, concerning the premises. The records demanded in this subpoena must be provided only if accompanied by written authorization for their release, or if accompanied by court order directing production of the documents.6 Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of your failure to comply. Honorable one of the Justices of said Co t Suffol - Supreme on April Witness, Presiding Justice, ounty Court, 8, 2024. You do not need to appear. T RAIMOND AW FIRM You may comply with this subpoena y: MICHAEL A. RAIMONDO by sending certified copy of the records to: Attorneys for Plaintiff THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312 2780 Middle Country Road, Suite 312 Lake NY 11755 Grove, Lake Grove, NY 11755 1 631-471-1222 Please melude a copy of subpoena. ' CPLR 2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attorney or self-represented party at the return address set forth in the subpoena, a copy of the subpoena shall be served upon all parties simultaneously and the party receiving such subpoenaed records, in any forrnat, shall deliver a complete copy of such records in the same format to all opposing counsel and self-represented parties where applicable, forthwith. 6 of 21 FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024 . . SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK _____________________________________________________-______.______________Ç SUSAN PIAZZA Calendar No.: 202400393MV Plaintiffs, -against- JUDICIAL SUBPOENA DUCES TECUM CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car. ASURION LLC, d/b/a New Asurion Corporation, Defendants. _______________________________________________..___________________________Ç TO: Dr. Walsh 98* 96 5 East Street, Floor New York, NY 10029 WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before THE RAIMONDO LAW FIRM, 155 2780 Middle Country Road, Suite 312, NY 11755, on day of May of2024 at 9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid: physicians' Copies of all medical records, medical reports, medical charts, offices records, offices notes, written notes, nurses' notes, laboratory reports, x-rays/radiographic films and reports, MM films and reports, CT scans and reports, bone scans and reports, ENTs, EEGs, EKGs, myelograms, ultrasounds, sonograms, diagnostic tests and reports, hospital charts, hospital records, emergency room records, in-patientrecords, out-patient records, progress records, operative reports, bills/statements, memos, correspondence, and any and all other records, reports or documents with respect to the treatment of the following: Patient: Susan Piazza Date of Birth: 05/31/62 Date of Accident: 8/25/21 now in your custody, and all other deeds, evidences and writings, which you have in your custody or power, concerning the premises. The records demanded in this subpoena must be provided only if accompanied by written authorization for their release, or if accompanied by court order directing production of the documents.7 Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of your failure to comply. Witness, Honorable Presiding Justice, one of the Justices of said rt, at Suffolk County Supreme Court, on April 8, 2024. You do not need to appear. T 1 ÅIMON O LAW FIRM You maycomply with this subpoena y: MICHAEL A. RAIMONDO by sending certified copy of the records to: Attorneys for Plaintiff THE RAIMONDO LAW FIRM 2780 Middle Country Road, Suite 312 2780 Middle Country Road, Suite 312 Lake Grove, NY 11755 Lake Grove, NY 11755 631-471-1222 Please melude a copy of subpoena.1 7 CPLR 2305(d) providing that where a trial subpoena directs service of the subpoenaed documents to the attorney or self-represented party at the retum address set forth in the subpoena, a copy of the subpoena shall be served upon all parties simultaneously and the party receiving such subpoenaed records, in any format, shall deliver a complete copy of such records in the same format to all opposing counsel and self-represented parties where applicable, forthwith. 7 of 21 FILED: SUFFOLK COUNTY CLERK 04/08/2024 04:36 PM INDEX NO. 619418/2021 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 04/08/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK __________________________________________________________________________Ç Index No.: 619418/21 SUSAN PIAZZA Calendar No.: 202400393MV Plaintiffs, -against- JUDICIAL SUBPOENA DUCES TECUM CARA F. VINCI, EAN HOLDINGS, LLC, d/b/a Enterprise Rent-A-Car, SNORAC, LLC, d/b/a Enterprise Rent-A-Car. ASURION LLC, d /a New Asurion Corporation, Defendants. _______________________________________________________________________Ç TO: Dr. Eric Klein 250 E. Main Street Bay Shore, NY 1 1706 WE COMMAND YOU, that all business and excuses being laid aside, you and each of you appear and attend before THE RAIMONDO LAW FIRM, 2780 Middle Country Road, Suite312, NY 11755, on 15th day of May of 2024 at 9:30 a.m. in the forenoon of that day and at any recessed or adjourned date to give testimony or provide records in this action on the part of the plaintiff and that you bring with you, and produce at the time and place aforesaid: physicians' Copies o