On February 28, 2013 a
Letter,Correspondence
was filed
involving a dispute between
Gilbert Barona,
Theresa Barona,
and
Maimonides Medical Center,
Montefiore Medical Center,
Nuan Cui,
Samantha Cohen,
for Medical Malpractice
in the District Court of Bronx County.
Preview
KD
KRAMER &
LENORE KRAMER
DENISE M, DUNLE, VY
DUNLEAVY JONATHAN R. RATCHIK
April 27, 2016
By Hand
Honorable Douglas E. McKeon
Supreme Court of the State of New York
County of Bronx
851 Grand Concourse, Room 600
Bronx, New York 10451
Re: Barona v. Maimonides Med. Ctr., et al.
Index No.: 20740/2013
Dear Judge McKeon:
This office represents the plaintiffs, Theresa and Gilbert Barona, in the above-referenced
medical malpractice action.
Enclosed herein please find unredacted affidavits of plaintiffs’ expert colorectal surgeon and
interventional radiologist which were previously submitted in opposition to defendant
Montefiore Medical Center’s motion for summary judgment. I am also enclosing a certificate
from the Secretary of State of the State of Illinois certifying that Erwin Tolentino was a licensed
notary public in that state. The subject documents were inadvertently submitted to Judge
Green back on February 25, 2016.
Thank you for the Court’s attention to this matter.
Very truly yours,
KRAMER & DUNLEAVY, L.L.P.
a
Jonatiian RK. Ratchik
he
Enc, YJ
cc:
McAloon & Friedman, P.C.
Aaronson, Rappaport, Feinstein & Deutsch, LLP
(via ECF and w/o affidavits)
Kramer& Dunleavy, L.L.P., 61 Broadway, Suite 2220, New York, NY 10006 Tel: (212) 226-6662 Fax: (212) 226-8089
lof 1
Preview
KD KRAMER & LENORE KRAMER DENISE M, DUNLE, VY DUNLEAVY JONATHAN R. RATCHIK April 27, 2016 By Hand Honorable Douglas E. McKeon Supreme Court of the State of New York County of Bronx 851 Grand Concourse, Room 600 Bronx, New York 10451 Re: Barona v. Maimonides Med. Ctr., et al. Index No.: 20740/2013 Dear Judge McKeon: This office represents the plaintiffs, Theresa and Gilbert Barona, in the above-referenced medical malpractice action. Enclosed herein please find unredacted affidavits of plaintiffs’ expert colorectal surgeon and interventional radiologist which were previously submitted in opposition to defendant Montefiore Medical Center’s motion for summary judgment. I am also enclosing a certificate from the Secretary of State of the State of Illinois certifying that Erwin Tolentino was a licensed notary public in that state. The subject documents were inadvertently submitted to Judge Green back on February 25, 2016. Thank you for the Court’s attention to this matter. Very truly yours, KRAMER & DUNLEAVY, L.L.P. a Jonatiian RK. Ratchik he Enc, YJ cc: McAloon & Friedman, P.C. Aaronson, Rappaport, Feinstein & Deutsch, LLP (via ECF and w/o affidavits) Kramer& Dunleavy, L.L.P., 61 Broadway, Suite 2220, New York, NY 10006 Tel: (212) 226-6662 Fax: (212) 226-8089 lof 1