On October 28, 2014 a
No Value
was filed
involving a dispute between
German Prado,
and
Building Dev Corp,
North Flats Llc,
The North Flats Llc,
for Tort
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 03/19/2015 02:54 PM INDEX NO. 510059/2014
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 03/19/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
·-:1
r,.. :· . -------------------------------------------------------------------------)(
GERMAN PRADO,
iJ Index No.: 510059/2014
Plaintiff,
DEMAND FORA
-against- COLLATERAL SOURCE
INFORMATION
THE NORTH FLATS, LLC, NORTH FLATS, LLC and
BUILDING DEV. CORP.,
Defendants.
-------------------------------------------------------------------------)(
PLEASE TAKE NOTICE, that a demand is hereby made upon Plaintiff to serve upon
the undersigned attorneys for defendants, THE NORTH FLATS, LLC and BUILDING DEV.
CORP. within thirty (30) days of the receipt of this demand, a statement as to whether any part of
the cost of medical care, custodial care, rehabilitation services, loss of earnings, or other economic
loss, sought to be recovered herein was replaced or indemnified, in whole or in part, from any
collateral source such as, but not limited to, the following:
1. insurance;
2. social security;
3. public or private disability insurance;
4. worker's compensation;
5. Medicaid;
6. public assistance; or
7. employee benefit programs.
If so, set forth the full name and address of each organization, agency, or program
providing such replacement or indemnification, together with an itemized statement of the
amount in which each such claimed item of economic loss was replaced or indemnified by each
such organization, agency or program.
A demand is additionally made for duly executed and properly addressed original HIP AA
compliant authorizations permitting the undersigned to inspect and copy any records reflecting
any collateral source payment identified in response to the foregoing demand.
Dated: Hawthorne, New York
March 19, 2015
Yours, etc.
TRAUB LIEBERMAN STRAUS
& SHREWSBERRY, LLP
By:
Evan B. Rudnicki, Esq.
Mid-Westchester Executive Park
Seven Skyline Drive
Hawthorne, New York 10532
(914) 347-2600
Attorneys for Defendants
The North Flats, LLC and
Building Dev. Corp.
TO: ISAACSON SCHIOWITZ & KORSON, LLP
Martin Schiowitz, Esq.
371 Merrick Road, Suite 302
Rockville Centre, New York 11570
(516) 208-1300
Attorneys for Plaintiff
2
Document Filed Date
March 19, 2015
Case Filing Date
October 28, 2014
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FILED: KINGS COUNTY CLERK 03/19/2015 02:54 PM INDEX NO. 510059/2014 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 03/19/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ·-:1 r,.. :· . -------------------------------------------------------------------------)( GERMAN PRADO, iJ Index No.: 510059/2014 Plaintiff, DEMAND FORA -against- COLLATERAL SOURCE INFORMATION THE NORTH FLATS, LLC, NORTH FLATS, LLC and BUILDING DEV. CORP., Defendants. -------------------------------------------------------------------------)( PLEASE TAKE NOTICE, that a demand is hereby made upon Plaintiff to serve upon the undersigned attorneys for defendants, THE NORTH FLATS, LLC and BUILDING DEV. CORP. within thirty (30) days of the receipt of this demand, a statement as to whether any part of the cost of medical care, custodial care, rehabilitation services, loss of earnings, or other economic loss, sought to be recovered herein was replaced or indemnified, in whole or in part, from any collateral source such as, but not limited to, the following: 1. insurance; 2. social security; 3. public or private disability insurance; 4. worker's compensation; 5. Medicaid; 6. public assistance; or 7. employee benefit programs. If so, set forth the full name and address of each organization, agency, or program providing such replacement or indemnification, together with an itemized statement of the amount in which each such claimed item of economic loss was replaced or indemnified by each such organization, agency or program. A demand is additionally made for duly executed and properly addressed original HIP AA compliant authorizations permitting the undersigned to inspect and copy any records reflecting any collateral source payment identified in response to the foregoing demand. Dated: Hawthorne, New York March 19, 2015 Yours, etc. TRAUB LIEBERMAN STRAUS & SHREWSBERRY, LLP By: Evan B. Rudnicki, Esq. Mid-Westchester Executive Park Seven Skyline Drive Hawthorne, New York 10532 (914) 347-2600 Attorneys for Defendants The North Flats, LLC and Building Dev. Corp. TO: ISAACSON SCHIOWITZ & KORSON, LLP Martin Schiowitz, Esq. 371 Merrick Road, Suite 302 Rockville Centre, New York 11570 (516) 208-1300 Attorneys for Plaintiff 2