Preview
FILED: SUFFOLK COUNTY CLERK 02/07/2018 11:22 AM INDEX NO. 611214/2015
NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
-------
----------------------------------------------------------X - —- ——X
ALICIA M, ARUNDEL; SUZANNA SCHULMAN, AS Index Nos. 611214/15
ADMINISTRATRIX OF THE ESTATE OF BRITTNEY 609082/15
M. SCHULMAN, DECEASED; OLGA LIPETS; MINDY 600055/16
GRABINA, AS ADMINISTRATRIX OF THE ESTATE 603536/16
OF AMY GRABINA, AND MINDY GRABINA, 003364/16
INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR 607598/16
OF THE ESTATE OF LAUREN BARUCH, DECEASED, 001831/16
AND SEVEN BARUCH, INDIVIDUALLY; JOELLE
DIMONTE; and MELISSA A. CRAI,
NOTICE FOR
Plaintiffs, DISCOVERY AND
INSPECTION TO
-against- PLAINTIFF LIPETS
ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO,
ROMEO DIMON MARINE SERVICE, INC., STEVEN
ROMEO, TOWN OF SOUTHOLD and COUNTY OF
SUFFOLK,
Defendants,
------------------------------------------------------------X
TO: OLGA LIPETS
PLEASE TAKE NOTICE, that pursuant to CPLR §§3101 and 3120, the defendant,
TOWN OF SOUTHOLD, hereby demands that you serve upon the said defendant's attorneys the
following:
1. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN
BARRETT, LLP, to obtain plaintiff's No Fault records.
2. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN
BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record
including patient's history, office notes, test results, radiology studies, films, referrals, consults,
billing records, insurance records and records sent by other health care providers from Dr.
Gelfand, with complete address and unrestricted as to date.
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NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018
3. The last name of Dr. Olga and a fully executed HIPAA compliant authorization
enabling DEVITT SPELLMAN BARRETT, LLP, to obtain full and complete copies of the
plaintiff's entire medical record including patient's history, office notes, test results, radiology
studies, films, referrals, consults, billing records, insurance records and records sent by other
health care providers from the doctor identified by plaintiff as Dr. Olga, with complete
address and unrestricted as to date.
4. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN
BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record
including patient's history, office notes, test results, radiology studies, films, referrals, consults,
billing records, insurance records, and records sent by other health care providers from Dr.
Barsi, with complete address and unrestricted as to date.
5. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN
BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record
including patient's history, office notes, test results, radiology studies, films, referrals, consults,
billing records, insurance records and records sent by other health care providers from the dental
clinic, with complete address and unrestricted as to date.
6. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN
BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record
including patient's history, office notes, test results, radiology studies, films, referrals, consults,
billing records, insurance records and records sent by other health care providers from Dr.
Kotelsky, with complete address and unrestricted as to date.
7. Fully executed HIPAA compliant authorization(s) enabling DEVI'IT
SPELLMAN BARI&TT, LLP, to obtain fall and complete copies of the plaintiff's entire
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NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018
medical record including patient's history, office notes, test results, radiology studies, films,
referrals, consults, billing records, insurance records and records sent by other health care
providers from the locations/facilities where plaintiff obtained the wheelchair, walker,
crutches, and spit sucker commode, with complete address and unrestricted as to date.
8. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN
BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record
including patient's history, office notes, test results, radiology studies, films, referrals, consults,
billing records, insurance records and records sent by other health care providers from Cigna
related to any care and treatment that plaintiff claims resulted from the incident that is the subject
of this action, with complete address and unrestricted as to date.
9. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN
BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record
including patient's history, office notes, test results, radiology studies, films, referrals, consults,
billing records, insurance records and records sent by other health care providers from Dr.
I
Epolboym, with complete name, address, and unrestricted as to date.
10. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN
BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record
including patient's history, office notes, test results, radiology studies, films, referrals, consults,
billing records, insurance records and records sent by other health care providers from Back to
Health Physical Therapy, with complete address and unrestricted as to date.
11. Color copies of any photographs that plaintiff took or had taken on the date of the
incident,
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NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018
12. Color copies of any photographs that plaintiff took or had taken of the injuries she
sustained and any scars.
13. Copies of any bills that plaintiff paid which she relates to care and treatment after
this incident.
PLEASE TAKE FURTHER NOTICE, that all authorizations are to include the proper
names, including but not limited to alternate names/alias, full addresses, and all necessary
identification numbers, including, but not limited to social security numbers, medical records
number, employee identification numbers, etc. Said authorizations should include the language
litigation."
that the authorization does not expire until the "end of
PLEASE TAKE FURTHER NOTICE, that all authorization must have the box checked
off in "Entire Medical Records, including patient histories, office notes, test results, radiology
studies, films, referrals, consults, billing records, insurance records, and records sent to you by
providers."
other health care
PLEASE TAKE FURTHER NOTICE, that said documents and information are to be
provided or copies of same served upon the offices of DEVITT SPELLMAN BARRETT, LLP,
50 Route 111, Suite 314, Smithtown, New York 11787, the attorneys for the defendant herein,
within twenty (20) days of the date of this demand.
PLEASE TAKE FURTHER NOTICE, that the foregoing are continuing demands and
that if any of the above items are obtained after the date of this demand, they are to be furnished
to the undersigned pursuant to this demand. The undersigned will object, upon the trial of this
matter, to the testimony and introduction of any items sought herein and not complied with.
Dated: Smithtown, New York
February 7, 2018 Yours, etc.,
DEVITT SPELLMAN BARRETT, LLP
Attorneys for Defendant
TOWN OF SOUTHOLD
50 Route 111, Suite 314
Smithtown, New York 11787
(631) 724-8833
Our File No. H 755 9 [J /ch]
By:
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NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018
TO: PARIS & CHAIKIN, PLLC
Attorneys for Plaintiff LIPETS
14 Penn Plaza, Suite 2202
New York, New York 10122
(646) 741-4005
CC: THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff ARUNDEL
1415 Kellum Place, Suite 205
Garden City, New York 11530
(516) 741-4170
JOHN L. JULIANO, P,C.
Attorneys for Plaintiff SCHULMAN
39 Doyle Court
East Northport, New York 11731
(631) 499-9300
FRANK J. LAINE P.C,
Attorneys for Plaintiffs GRABINA
449 South Oyster Bay Road
Plainview, New York 11803
(516) 937-1010
SULLIVAN PAPAIN BLOCK McGRATH
& CANNAVO, P.C.
Attorneys for Plaintiffs BARUCH
1140 Franklin Avenue, Suite 200
Garden City, New York 11530
(516) 742-0707
PEGALIS & ERICKSON, LLC
Attorneys for Plaintiff DiMONTE
One Hollow Lane, Suite 107
Lake Success, New York 11042
(516) 684-2939
JOSEPH J, TOCK, ESQ,
Attorneys for Plaintiff CRAI
963 Route 6
Mahopac, New York 10541
(845) 628-8080
AHMUTY DEMERS & McMANUS
Attorneys for Defendant
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NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018
ULTIMATE CLASS LIMOUSINE, INC,
and CARLOS PINO
200 I.U. Willets Road
Albertson, New York 11507
(516) 294-5433
CASCONE& KLUEPFELLLP
Attorneys for Defendant
ROMEO DIMON MARINE SERVICE, INC.
1399 Franldin Avenue, Suite 302
Garden City, New York 11530
(516) 747-1990
LEWIS JOHS AVALLONE AVILES LLP
Attorneys for Defendant
STEVEN ROMEO
One CA Plaza, Suite 225
Islandia, New York 11749
(631) 755-0101
DENNIS M. BROWN, ESQ.
Attorneys for Defendant
OI.
COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
P.O. Box 6100
Hauppauge, New York 11788
(631) 853-4055
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NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018
AFFIDAVIT OF SERVICE BY MAIL
STATE OF NEW YORK )
) ss.:
SUFFOLI<'
COUNTY OF SUFFOLK )
The undersigned being duly sworn, deposes and says:
Deponent is not a party to this action, is over 18 years of age and resides at Ronkonkoma, New
York.
That on February 7, 2018, deponent served the annexed NOTICE FOR DISCOVERY AND
INSPECTION TO PLAINTIFF OLGA LIPETS on:
AHMUTY DEMERS & McMANUS
200 LU. Willets Road
Albertson, New York 11507 PEGALIS 4 ERICKSON, LLC
One Hollow Lane, Suite 107
THE BONGIORNO LAW FIRM, PLLC Lake Success, New York 11042
1415 Kellum Place, Suite 205
Garden City, New York 11530 JOSEPH J.TOCK, ESQ.
963 Route 6
JOHN L. JULIANO, P,C, Mahopac, New York 10541
39 Doyle Court
East Northport, New York 11731 CASCONE 4 KLUEPFEL LLP
1399 Franklin Avenue, Suite 302
PARIS 4 CHAIKIN, PLLC Garden City, New York 11530
14 Penn Plaza, Suite 2202
New York, New York 10122 LEWIS JOHS AVALLONE AVILES LLP
One CA Plaza, Suite 225
FRANK J.LAINE P.C. Islandia, New York 11749
449 South Oyster Bay Road
Plainview, New York 11803 DENNIS M, BROWN, ESQ.
H. Lee Dennison Building
SULLIVAN PAPAIN BLOCK 100 Veterans Memorial Highway
McGRATH 4 CANNAVO, P.C. P,0. Box 6100
1140 Franklin Avenue, Suite- 200 Hauppauge, New York 11788
Garden City, New York 11530 .
by E-filing the Notice for Discovery and Inspection to Plaintiff OLGA LIPETS with the Suffolk County
Supreme Court through NYCEF, as agreed to by allparties,
CATiff . H EK
Sworn to before me this
7th
7 day of February, 20]8.
NOTAR PUBLIC
IWONA SWIECZKOWSKI
Notary Pubtle, State of New York
No. 01SW6152051, Suffolk oun
lb'
Tern Expires August
Expleehuguet ~
28,
7 of 7
Preview
FILED: SUFFOLK COUNTY CLERK 02/07/2018 11:22 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ------- ----------------------------------------------------------X - —- ——X ALICIA M, ARUNDEL; SUZANNA SCHULMAN, AS Index Nos. 611214/15 ADMINISTRATRIX OF THE ESTATE OF BRITTNEY 609082/15 M. SCHULMAN, DECEASED; OLGA LIPETS; MINDY 600055/16 GRABINA, AS ADMINISTRATRIX OF THE ESTATE 603536/16 OF AMY GRABINA, AND MINDY GRABINA, 003364/16 INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR 607598/16 OF THE ESTATE OF LAUREN BARUCH, DECEASED, 001831/16 AND SEVEN BARUCH, INDIVIDUALLY; JOELLE DIMONTE; and MELISSA A. CRAI, NOTICE FOR Plaintiffs, DISCOVERY AND INSPECTION TO -against- PLAINTIFF LIPETS ULTIMATE CLASS LIMOUSINE, INC., CARLOS PINO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, Defendants, ------------------------------------------------------------X TO: OLGA LIPETS PLEASE TAKE NOTICE, that pursuant to CPLR §§3101 and 3120, the defendant, TOWN OF SOUTHOLD, hereby demands that you serve upon the said defendant's attorneys the following: 1. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN BARRETT, LLP, to obtain plaintiff's No Fault records. 2. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record including patient's history, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records and records sent by other health care providers from Dr. Gelfand, with complete address and unrestricted as to date. 1 of 7 FILED: SUFFOLK COUNTY CLERK 02/07/2018 11:22 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018 3. The last name of Dr. Olga and a fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record including patient's history, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records and records sent by other health care providers from the doctor identified by plaintiff as Dr. Olga, with complete address and unrestricted as to date. 4. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record including patient's history, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records, and records sent by other health care providers from Dr. Barsi, with complete address and unrestricted as to date. 5. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record including patient's history, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records and records sent by other health care providers from the dental clinic, with complete address and unrestricted as to date. 6. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record including patient's history, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records and records sent by other health care providers from Dr. Kotelsky, with complete address and unrestricted as to date. 7. Fully executed HIPAA compliant authorization(s) enabling DEVI'IT SPELLMAN BARI&TT, LLP, to obtain fall and complete copies of the plaintiff's entire 2 of 7 FILED: SUFFOLK COUNTY CLERK 02/07/2018 11:22 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018 medical record including patient's history, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records and records sent by other health care providers from the locations/facilities where plaintiff obtained the wheelchair, walker, crutches, and spit sucker commode, with complete address and unrestricted as to date. 8. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record including patient's history, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records and records sent by other health care providers from Cigna related to any care and treatment that plaintiff claims resulted from the incident that is the subject of this action, with complete address and unrestricted as to date. 9. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record including patient's history, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records and records sent by other health care providers from Dr. I Epolboym, with complete name, address, and unrestricted as to date. 10. A fully executed HIPAA compliant authorization enabling DEVITT SPELLMAN BARRETT, LLP, to obtain full and complete copies of the plaintiff's entire medical record including patient's history, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records and records sent by other health care providers from Back to Health Physical Therapy, with complete address and unrestricted as to date. 11. Color copies of any photographs that plaintiff took or had taken on the date of the incident, 3 of 7 FILED: SUFFOLK COUNTY CLERK 02/07/2018 11:22 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018 12. Color copies of any photographs that plaintiff took or had taken of the injuries she sustained and any scars. 13. Copies of any bills that plaintiff paid which she relates to care and treatment after this incident. PLEASE TAKE FURTHER NOTICE, that all authorizations are to include the proper names, including but not limited to alternate names/alias, full addresses, and all necessary identification numbers, including, but not limited to social security numbers, medical records number, employee identification numbers, etc. Said authorizations should include the language litigation." that the authorization does not expire until the "end of PLEASE TAKE FURTHER NOTICE, that all authorization must have the box checked off in "Entire Medical Records, including patient histories, office notes, test results, radiology studies, films, referrals, consults, billing records, insurance records, and records sent to you by providers." other health care PLEASE TAKE FURTHER NOTICE, that said documents and information are to be provided or copies of same served upon the offices of DEVITT SPELLMAN BARRETT, LLP, 50 Route 111, Suite 314, Smithtown, New York 11787, the attorneys for the defendant herein, within twenty (20) days of the date of this demand. PLEASE TAKE FURTHER NOTICE, that the foregoing are continuing demands and that if any of the above items are obtained after the date of this demand, they are to be furnished to the undersigned pursuant to this demand. The undersigned will object, upon the trial of this matter, to the testimony and introduction of any items sought herein and not complied with. Dated: Smithtown, New York February 7, 2018 Yours, etc., DEVITT SPELLMAN BARRETT, LLP Attorneys for Defendant TOWN OF SOUTHOLD 50 Route 111, Suite 314 Smithtown, New York 11787 (631) 724-8833 Our File No. H 755 9 [J /ch] By: 4 of 7 FILED: SUFFOLK COUNTY CLERK 02/07/2018 11:22 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018 TO: PARIS & CHAIKIN, PLLC Attorneys for Plaintiff LIPETS 14 Penn Plaza, Suite 2202 New York, New York 10122 (646) 741-4005 CC: THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff ARUNDEL 1415 Kellum Place, Suite 205 Garden City, New York 11530 (516) 741-4170 JOHN L. JULIANO, P,C. Attorneys for Plaintiff SCHULMAN 39 Doyle Court East Northport, New York 11731 (631) 499-9300 FRANK J. LAINE P.C, Attorneys for Plaintiffs GRABINA 449 South Oyster Bay Road Plainview, New York 11803 (516) 937-1010 SULLIVAN PAPAIN BLOCK McGRATH & CANNAVO, P.C. Attorneys for Plaintiffs BARUCH 1140 Franklin Avenue, Suite 200 Garden City, New York 11530 (516) 742-0707 PEGALIS & ERICKSON, LLC Attorneys for Plaintiff DiMONTE One Hollow Lane, Suite 107 Lake Success, New York 11042 (516) 684-2939 JOSEPH J, TOCK, ESQ, Attorneys for Plaintiff CRAI 963 Route 6 Mahopac, New York 10541 (845) 628-8080 AHMUTY DEMERS & McMANUS Attorneys for Defendant 5 of 7 FILED: SUFFOLK COUNTY CLERK 02/07/2018 11:22 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018 ULTIMATE CLASS LIMOUSINE, INC, and CARLOS PINO 200 I.U. Willets Road Albertson, New York 11507 (516) 294-5433 CASCONE& KLUEPFELLLP Attorneys for Defendant ROMEO DIMON MARINE SERVICE, INC. 1399 Franldin Avenue, Suite 302 Garden City, New York 11530 (516) 747-1990 LEWIS JOHS AVALLONE AVILES LLP Attorneys for Defendant STEVEN ROMEO One CA Plaza, Suite 225 Islandia, New York 11749 (631) 755-0101 DENNIS M. BROWN, ESQ. Attorneys for Defendant OI. COUNTY OF SUFFOLK H. Lee Dennison Building 100 Veterans Memorial Highway P.O. Box 6100 Hauppauge, New York 11788 (631) 853-4055 6 of 7 FILED: SUFFOLK COUNTY CLERK 02/07/2018 11:22 AM INDEX NO. 611214/2015 NYSCEF DOC. NO. 389 RECEIVED NYSCEF: 02/07/2018 AFFIDAVIT OF SERVICE BY MAIL STATE OF NEW YORK ) ) ss.: SUFFOLI<' COUNTY OF SUFFOLK ) The undersigned being duly sworn, deposes and says: Deponent is not a party to this action, is over 18 years of age and resides at Ronkonkoma, New York. That on February 7, 2018, deponent served the annexed NOTICE FOR DISCOVERY AND INSPECTION TO PLAINTIFF OLGA LIPETS on: AHMUTY DEMERS & McMANUS 200 LU. Willets Road Albertson, New York 11507 PEGALIS 4 ERICKSON, LLC One Hollow Lane, Suite 107 THE BONGIORNO LAW FIRM, PLLC Lake Success, New York 11042 1415 Kellum Place, Suite 205 Garden City, New York 11530 JOSEPH J.TOCK, ESQ. 963 Route 6 JOHN L. JULIANO, P,C, Mahopac, New York 10541 39 Doyle Court East Northport, New York 11731 CASCONE 4 KLUEPFEL LLP 1399 Franklin Avenue, Suite 302 PARIS 4 CHAIKIN, PLLC Garden City, New York 11530 14 Penn Plaza, Suite 2202 New York, New York 10122 LEWIS JOHS AVALLONE AVILES LLP One CA Plaza, Suite 225 FRANK J.LAINE P.C. Islandia, New York 11749 449 South Oyster Bay Road Plainview, New York 11803 DENNIS M, BROWN, ESQ. H. Lee Dennison Building SULLIVAN PAPAIN BLOCK 100 Veterans Memorial Highway McGRATH 4 CANNAVO, P.C. P,0. Box 6100 1140 Franklin Avenue, Suite- 200 Hauppauge, New York 11788 Garden City, New York 11530 . by E-filing the Notice for Discovery and Inspection to Plaintiff OLGA LIPETS with the Suffolk County Supreme Court through NYCEF, as agreed to by allparties, CATiff . H EK Sworn to before me this 7th 7 day of February, 20]8. NOTAR PUBLIC IWONA SWIECZKOWSKI Notary Pubtle, State of New York No. 01SW6152051, Suffolk oun lb' Tern Expires August Expleehuguet ~ 28, 7 of 7