Preview
INDEX NO. 805132/2012
(FILED: NEW YORK COUNTY CLERK 1070372014 02:26 PM
NYSCEF DOC. NO. 107 RECEIVED NYSCEF: 10/03/2014
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
eee =X Index No.: 805132/2012
EDWARD SCARANO and SUSAN SCARANO,
Plaintiffs,
-against- RESPONSE TO VARIOUS
DEMANDS AS TO DEFENDANT
GARY RUTH, M.D.
DEAN VAFIADIS, D.D.S., Individually and d/b/a
NEW YORK SMILE INSTITUTE, GARY
GOLDSTEIN, D.D.S., GARY RUTH, D.D.S.,
MAXILLOFACIAL SURGERY SERVICES, L.L.C.,
GEORGE ANASTRASSOV, M.D., D.D.S.,
BABAK GHALILI, D.D.S. and MARK
KOVALEVSKIY,
Defendants.
cece er nen enna nana nanan nnn nn nnn ceneneeneneneenensenenceneeaneeeneeennnne!
Plaintiff, by his attorney VALERIE J. CROWN, ATTORNEY AT LAW, P.C. responding
to the demands of the defendants, respectfully sets forth as follows:
1-2. Annexed hereto are copies of canceled checks and/or credit card statements in
plaintiff's position, reflecting a portion of plaintiff’s special damages. Plaintiffs will continue to search
for additional proof of special damages and reserve the right to supplement this response.
3 Annexed hereto are bills and/or invoices plaintiffs received from Dr. Ruth.
4 Supporting documents regarding out of pocket expenses are attached. See
paragraphs 1-2 above.
5 Plaintiffs object to the demand for correspondence with Amex, as it is overbroad,
unduly burdensome, privileged, prejudicial, irrelevant, and not reasonably calculated to lead to
discovery of evidence material to the defense or prosecution of this action. Notwithstanding the
foregoing, to the extent, plaintiff received written statements and bills from Amex, relating to defendant
Anastossov, same are annexed hereto.
6 Annexed hereto are the records of Dr. Ruth in plaintiff’s possession.
7. Plaintiff objects to the demand for the deposition given in his matrimonial
action, as it is overbroad, unduly burdensome, privileged, prejudicial, irrelevant, and not reasonably
calculated to lead to discovery of evidence material to the defense or prosecution of this action.
Medco
255 Phillipi Road
Columbus, OH 43228
Corum
555 17th Street, Suite 1500
Denver, CO 80202
New York-Presbyterian/Columbia University Medical Center
622 West 168th Street
New York, NY 10032
Lab Corp., HIPAA Privacy Officer
531 South Spring Street
Burlington, NC 27215
Home Healthcare Laboratory
320 Premier Court, Suite 220
Franklin, TN, 37067
Dated: New City, New York
October 3, 2014
Yours, etc.
VALERIE J. CROWN, ATTORNEY AT LAW, P.C
By
Valerie, . Crown, ESQ.
ATTORNEYS FOR PLAINTIFF
Office and Post Office Address
151 North Main Street, 4" Floor
New City, NY 10956
(845) 708-5900
TO: CARROLL MCNULTY & KULL, LLC
Attorneys for Defendant
GARY RUTH, D.D.S.
570 Lexington Avenue — 8th Floor
New York, New York 10022
(212) 252-0004
LAW OFFICES OF CHARLES J. SIEGEL
Attorneys for Defendant
DEAN VAFIADIS, D.D.S.
125 Broad Street ~ 7"" Floor
New York, New York 10004
(212) 440-2350
LANDMAN, CORSI, BALLAINE & FORD, P.C.
Attorneys for Defendant
GARY GOLDSTEIN and BABAK GHALILI, D.D.S.
120 Broadway — 27" Floor
New York, New York 10271
(212) 238-4800
KOLENOVSKY SPIEGEL, LLP
Attorneys for Defendants
GEORGE E. ANASTASSOVE, M.D., D.D.S
and MAXILLOFACIAL SURGERY SERVICES, LLC.
135 West 29" Street — Suite 801
New York, New York 10001
(212) 760-2222
PATRICK F. ADAMS, P.L.L.C.
Attorney for Defendant
MARK KOVALEVSKIY, M.D.
30 Vesey Street — 12th Floor
New York, NY 10007
(212) 791-9730
Preview
INDEX NO. 805132/2012 (FILED: NEW YORK COUNTY CLERK 1070372014 02:26 PM NYSCEF DOC. NO. 107 RECEIVED NYSCEF: 10/03/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK eee =X Index No.: 805132/2012 EDWARD SCARANO and SUSAN SCARANO, Plaintiffs, -against- RESPONSE TO VARIOUS DEMANDS AS TO DEFENDANT GARY RUTH, M.D. DEAN VAFIADIS, D.D.S., Individually and d/b/a NEW YORK SMILE INSTITUTE, GARY GOLDSTEIN, D.D.S., GARY RUTH, D.D.S., MAXILLOFACIAL SURGERY SERVICES, L.L.C., GEORGE ANASTRASSOV, M.D., D.D.S., BABAK GHALILI, D.D.S. and MARK KOVALEVSKIY, Defendants. cece er nen enna nana nanan nnn nn nnn ceneneeneneneenensenenceneeaneeeneeennnne! Plaintiff, by his attorney VALERIE J. CROWN, ATTORNEY AT LAW, P.C. responding to the demands of the defendants, respectfully sets forth as follows: 1-2. Annexed hereto are copies of canceled checks and/or credit card statements in plaintiff's position, reflecting a portion of plaintiff’s special damages. Plaintiffs will continue to search for additional proof of special damages and reserve the right to supplement this response. 3 Annexed hereto are bills and/or invoices plaintiffs received from Dr. Ruth. 4 Supporting documents regarding out of pocket expenses are attached. See paragraphs 1-2 above. 5 Plaintiffs object to the demand for correspondence with Amex, as it is overbroad, unduly burdensome, privileged, prejudicial, irrelevant, and not reasonably calculated to lead to discovery of evidence material to the defense or prosecution of this action. Notwithstanding the foregoing, to the extent, plaintiff received written statements and bills from Amex, relating to defendant Anastossov, same are annexed hereto. 6 Annexed hereto are the records of Dr. Ruth in plaintiff’s possession. 7. Plaintiff objects to the demand for the deposition given in his matrimonial action, as it is overbroad, unduly burdensome, privileged, prejudicial, irrelevant, and not reasonably calculated to lead to discovery of evidence material to the defense or prosecution of this action. Medco 255 Phillipi Road Columbus, OH 43228 Corum 555 17th Street, Suite 1500 Denver, CO 80202 New York-Presbyterian/Columbia University Medical Center 622 West 168th Street New York, NY 10032 Lab Corp., HIPAA Privacy Officer 531 South Spring Street Burlington, NC 27215 Home Healthcare Laboratory 320 Premier Court, Suite 220 Franklin, TN, 37067 Dated: New City, New York October 3, 2014 Yours, etc. VALERIE J. CROWN, ATTORNEY AT LAW, P.C By Valerie, . Crown, ESQ. ATTORNEYS FOR PLAINTIFF Office and Post Office Address 151 North Main Street, 4" Floor New City, NY 10956 (845) 708-5900 TO: CARROLL MCNULTY & KULL, LLC Attorneys for Defendant GARY RUTH, D.D.S. 570 Lexington Avenue — 8th Floor New York, New York 10022 (212) 252-0004 LAW OFFICES OF CHARLES J. SIEGEL Attorneys for Defendant DEAN VAFIADIS, D.D.S. 125 Broad Street ~ 7"" Floor New York, New York 10004 (212) 440-2350 LANDMAN, CORSI, BALLAINE & FORD, P.C. Attorneys for Defendant GARY GOLDSTEIN and BABAK GHALILI, D.D.S. 120 Broadway — 27" Floor New York, New York 10271 (212) 238-4800 KOLENOVSKY SPIEGEL, LLP Attorneys for Defendants GEORGE E. ANASTASSOVE, M.D., D.D.S and MAXILLOFACIAL SURGERY SERVICES, LLC. 135 West 29" Street — Suite 801 New York, New York 10001 (212) 760-2222 PATRICK F. ADAMS, P.L.L.C. Attorney for Defendant MARK KOVALEVSKIY, M.D. 30 Vesey Street — 12th Floor New York, NY 10007 (212) 791-9730