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. 7 RECEIVED NYSCEF: 03/19/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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GERMAN PRADO,
Index No.: 510059/2014
Plaintiff,
-against- DEMAND FOR
DISLCOSURE AS TO
THE NORTH FLATS, LLC, NORTH FLATS, LLC and MEDICAID/MEDICARE
BUILDING DEV. CORP., LIEN
Defendants.
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PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and
Rules, Demand is made that the Plaintiff furnish within (30) days of the service of this notice the
following:
1. A statement as to whether the Plaintiff has received benefits from either Medicare
or Medicaid. If so, please state:
a. Plaintiffs date of birth;
b. Plaintiffs Social Security number;
c. Plaintiffs resident telephone number;
·-.. ,:
d. The Medicare/Medicaid file number;
e. The address of the office handling the Plaintiffs Medicare/Medicaid file;
f. Copies of all documents, records, memorandums, notes, etc. in Plaintiffs
possession pertaining to Plaintiffs receipt of Medicare or Medicaid
benefits and/or the existence of and/or the amount of a lien .
.-...:
g. A duly executed authorization bearing Plaintiffs date of birth and Social
Security number permitting this firm and/or the representative of
defendant to obtain copies of Plaintiffs Medicaid or Medicare records.
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR, this is a continuing
demand and that you are required to serve the demanded information within 30 days of the date
of this demand.
Dated: Hawthorne, New York
March 19,2015
Yours, etc.
TRAUB LIEBERMAN STRAUS
& SHREWSBERR LP
By:
Evan B. Rudnicki, Esq.
Mid-Westchester Executive Park
Seven Skyline Drive
Hawthorne, New Ynrk 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
Document Filed Date
March 19, 2015
Case Filing Date
October 28, 2014
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