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  • Berton Forman Md v. Mercy Medical Center, Catholic Health Services Of Long Island Commercial Division document preview
  • Berton Forman Md v. Mercy Medical Center, Catholic Health Services Of Long Island Commercial Division document preview
						
                                

Preview

INDEX NO. 156138/2014 ert TZ6o4 Fe RERHETHROTNER, ES NYSCEF Sse NO. 6 RECEIVED NYSEEF :?6 2/19/2015 Law Offices of Kenneth L, Kutner 1185 Avenue of the Americas 18th Floor New York, NY 10036 Ph: (212) 684-0088 Fax: (212) 684-7390 kkutner@kenkutner.com January 21, 2015 VIA ECE FAX The Honorable Eileen Bransten, J.8.C. Supreme Coutt of the State of New York Supreme Court, NY County 60 Centre Street, Submissions Room 130 New York, NY 10007 Re: Berton Forman, M.D. v. Mercy Medical Center and, Catholic Heaith Services of Long Island and Iron Mountain Inc. d/b/a Iron Mountain New York. Index No. 156138/2014 Dear Justice Bransten: Tam the attomey for Plaintiff, Berton Forman, MLD., in the above caption ed matter. On, January 7, 2015 undersigned counsel appeared before you in connection with Defendants* respective motions to dismiss the complaint. The Court directed that an amended complaint be filed today if Plaintiff desired to continue the lawsuit. I am respectfully request ing that the Court grant an extension to file said amended complaint for one week up to and includi ng January 28, 2015. This requested is necessitated by unanticipated circumstances that have arisen which have made filing today unfeasible. Thave conferred with Thomas D. Antonio, Esq., attorney for Mercy Medical Center and Catholic Health Services of Long Island, who advised that he didnot Oppose my request, In addition, I conferred with Frank McGinn, Esq., attorney for Defendant, Iron Mountain Inc. who bas consented to my request. Thank you for your attention to this mater. Amended Complan* bla fh toy Semuerry MPVS, Mo Respectfully Submitted 4 Dated . Queer BODE MEANS UM tee gfe Sanuery 2 a5 Be WO" Yeeson Kenneth L. Kutner KLK/ag ce: Thomas D. Antonio, Esq. (via e-mail) So Ordead , Frank McGinn, Esq. (via e-mail) \ — Menachem M. Besiniger, Esq. (via e-mail) Dr. Forman (via e-mail) — HON. EILEEN BRANSTE V2.0, N