On May 10, 2019 a
No Value
was filed
involving a dispute between
Nicholas Grant,
and
147-02 12 Liberty Ave., Llc.,
Isaac Rios Jr,
Jouvay Ny, Inc.,
Jouvay Ny, Inc. D B A Jouvay Night Club,
Professional Corporate Security Services, Inc.,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 05/26/2021 01:59 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/26/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------X
NICHOLAS GRANT,
Index No.: 510433/2019
Plaintiff,
DEMAND FOR
-against- DISCLOSURE
OF MEDICARE
147-02 /12 LIBERTY AVE., LLC., JOUVAY NY, INC. BENEFITS/
d/b/a JOUVAY NIGHT CLUB, ISAAC J. RIOS, and ELIGIBILITY
PROFESSIONAL CORPORATE SECURITY
SERVICES, INC.,
Defendants.
---------------------------------------------------------------------X
C O U N S E L O R S:
PLEASE TAKE NOTICE, that demand is hereby made that plaintiff provides the
following information pursuant to 42 U.S.C. § 1395(b)(8)(A).
1. A statement as to whether the Plaintiff has received benefits from either Medicare
or Medicaid. If so, please state:
a. Plaintiff’s date of birth;
b. Plaintiff’s Social Security number;
c. Plaintiff’s resident telephone number;
d. The Medicare/Medicaid file number;
e. The addresses of the offices handling the Plaintiff’s Medicare/Medicaid
file;
f. Copies of all documents, records, memorandums, notes, etc. in Plaintiff’s
possession pertaining to Plaintiff’s receipt of Medicare or Medicaid
benefits and/or the existence of and/or the amount of a lien.
g. A duly executed authorization bearing Plaintiff’s dates of birth and Social
Security numbers permitting this firm and/or the representative of
defendant to obtain copies of Plaintiff’s Medicaid or Medicare records.
2. If Plaintiff has been the recipient of Medicare benefits:
1 of 4
FILED: KINGS COUNTY CLERK 05/26/2021 01:59 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/26/2021
a. State Plaintiff’s full legal names under which plaintiff was receiving
Medicare and/or Social Security benefits;
b. State plaintiff’s full address, including city, state and zip code;
c. Plaintiff’s date of birth:
d. Plaintiff’s social security number;
e. State Plaintiff’s Medicare beneficiary number (HICN)
3. Is Plaintiff currently the recipient of Medicare benefits?
a. State Plaintiff’s the full legal name under which plaintiff is receiving
Medicare and/or Social Security benefits;
4. Does Plaintiff expect to receive Medicare benefits within the next five years?
5. Has Plaintiff ever applied for Social Security Disability (“SSD”) benefits?
a. State Plaintiff’s the full legal name under which plaintiff applied for
Social Security Disability (“SSD”) benefits;
b. State the dates Plaintiff applied for SSD benefits;
c. If SSD benefits were awarded:
(1) State the date SSD benefits were awarded;
(2) State the period of time for which SSD benefits were paid;
(3) State the injury claimed that resulted in the award;
(4) State the date the injury accorded for which SSD benefit were
awarded.
d. If SSD benefits were not awarded:
(1) State the date the date of denial of the application;
(2) State the reason for the denial as provided by the Social Security
Administration;
(3) State of the date of any appeal;
(4) Provide the status of any appeal.
6. Does Plaintiff have End-Stage Renal Disease?
a. If yes, state the date of diagnosis.
7. Does Plaintiff have any form of kidney disease?
a. If yes, state the type of disease.
b. State the date of diagnoses.
c. Describe Plaintiff’s treatment for the disease.
d. State the medical prognosis for the disease.
2
2 of 4
FILED: KINGS COUNTY CLERK 05/26/2021 01:59 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/26/2021
8. Does Plaintiff have Amyorophic Lateral Sclerosis (Lou Gehrig’s Disease)?
a. If yes, state the date of diagnosis.
9. If Plaintiff has not received Medicare benefits in the past or is not receiving
Medicare benefits now, state whether plaintiff is eligible to receive Medicare benefits.
10. If Plaintiff has been receiving Medicare benefits and is now deceased, please
provide the following:
a. Relationship of the administrator of Plaintiff’s estate to Plaintiff’s
decedent;
b. Name and address of Plaintiff’s administrator;
c. Social Security number of Plaintiff’s administrator;
d. State whether any bills related to medical bills for treatment allegedly
arising out of this litigation have been submitted to Medicare;
e. State whether Medicare has paid for any of the medical treatment that
Plaintiff claims are related to this litigation.
PLEASE TAKE FURTHER NOTICE that failure to comply with this demand may
result in the necessity of a motion to compel discovery accompanied by a request for the
appropriate costs.
Dated: Elmsford, New York
May 26, 2021
BLACK MARJIEH & SANFORD LLP
Attorneys for Defendant
147-02/12 Liberty Ave., LLC
By:
John W. Bieder, Esq.
100 Clearbrook Road
Elmsford, New York 10523
Tel. No. (914) 704-4400
3
3 of 4
FILED: KINGS COUNTY CLERK 05/26/2021 01:59 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/26/2021
TO:
LAW OFFICES OF BRYAN BARENBAUM
Attorneys for Plaintiff
Nicholas Grant
2060 Eastern Parkway
Brooklyn, New York 11207
Tel. No. (718) 421-1111
JOUVAY NY, INC.
147-02 Liberty Avenue
Jamaica, New York 11435
PROFESSIONAL CORPORATE SECURITY
SERVICES, INC.
C/O 153 Tee Avenue
Central Islip, New York 11722
ISAAC J. RIOS
4
4 of 4
Document Filed Date
May 26, 2021
Case Filing Date
May 10, 2019
Category
Torts - Motor Vehicle
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FILED: KINGS COUNTY CLERK 05/26/2021 01:59 PM INDEX NO. 510433/2019 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/26/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------------X NICHOLAS GRANT, Index No.: 510433/2019 Plaintiff, DEMAND FOR -against- DISCLOSURE OF MEDICARE 147-02 /12 LIBERTY AVE., LLC., JOUVAY NY, INC. BENEFITS/ d/b/a JOUVAY NIGHT CLUB, ISAAC J. RIOS, and ELIGIBILITY PROFESSIONAL CORPORATE SECURITY SERVICES, INC., Defendants. ---------------------------------------------------------------------X C O U N S E L O R S: PLEASE TAKE NOTICE, that demand is hereby made that plaintiff provides the following information pursuant to 42 U.S.C. § 1395(b)(8)(A). 1. A statement as to whether the Plaintiff has received benefits from either Medicare or Medicaid. If so, please state: a. Plaintiff’s date of birth; b. Plaintiff’s Social Security number; c. Plaintiff’s resident telephone number; d. The Medicare/Medicaid file number; e. The addresses of the offices handling the Plaintiff’s Medicare/Medicaid file; f. Copies of all documents, records, memorandums, notes, etc. in Plaintiff’s possession pertaining to Plaintiff’s receipt of Medicare or Medicaid benefits and/or the existence of and/or the amount of a lien. g. A duly executed authorization bearing Plaintiff’s dates of birth and Social Security numbers permitting this firm and/or the representative of defendant to obtain copies of Plaintiff’s Medicaid or Medicare records. 2. If Plaintiff has been the recipient of Medicare benefits: 1 of 4 FILED: KINGS COUNTY CLERK 05/26/2021 01:59 PM INDEX NO. 510433/2019 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/26/2021 a. State Plaintiff’s full legal names under which plaintiff was receiving Medicare and/or Social Security benefits; b. State plaintiff’s full address, including city, state and zip code; c. Plaintiff’s date of birth: d. Plaintiff’s social security number; e. State Plaintiff’s Medicare beneficiary number (HICN) 3. Is Plaintiff currently the recipient of Medicare benefits? a. State Plaintiff’s the full legal name under which plaintiff is receiving Medicare and/or Social Security benefits; 4. Does Plaintiff expect to receive Medicare benefits within the next five years? 5. Has Plaintiff ever applied for Social Security Disability (“SSD”) benefits? a. State Plaintiff’s the full legal name under which plaintiff applied for Social Security Disability (“SSD”) benefits; b. State the dates Plaintiff applied for SSD benefits; c. If SSD benefits were awarded: (1) State the date SSD benefits were awarded; (2) State the period of time for which SSD benefits were paid; (3) State the injury claimed that resulted in the award; (4) State the date the injury accorded for which SSD benefit were awarded. d. If SSD benefits were not awarded: (1) State the date the date of denial of the application; (2) State the reason for the denial as provided by the Social Security Administration; (3) State of the date of any appeal; (4) Provide the status of any appeal. 6. Does Plaintiff have End-Stage Renal Disease? a. If yes, state the date of diagnosis. 7. Does Plaintiff have any form of kidney disease? a. If yes, state the type of disease. b. State the date of diagnoses. c. Describe Plaintiff’s treatment for the disease. d. State the medical prognosis for the disease. 2 2 of 4 FILED: KINGS COUNTY CLERK 05/26/2021 01:59 PM INDEX NO. 510433/2019 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/26/2021 8. Does Plaintiff have Amyorophic Lateral Sclerosis (Lou Gehrig’s Disease)? a. If yes, state the date of diagnosis. 9. If Plaintiff has not received Medicare benefits in the past or is not receiving Medicare benefits now, state whether plaintiff is eligible to receive Medicare benefits. 10. If Plaintiff has been receiving Medicare benefits and is now deceased, please provide the following: a. Relationship of the administrator of Plaintiff’s estate to Plaintiff’s decedent; b. Name and address of Plaintiff’s administrator; c. Social Security number of Plaintiff’s administrator; d. State whether any bills related to medical bills for treatment allegedly arising out of this litigation have been submitted to Medicare; e. State whether Medicare has paid for any of the medical treatment that Plaintiff claims are related to this litigation. PLEASE TAKE FURTHER NOTICE that failure to comply with this demand may result in the necessity of a motion to compel discovery accompanied by a request for the appropriate costs. Dated: Elmsford, New York May 26, 2021 BLACK MARJIEH & SANFORD LLP Attorneys for Defendant 147-02/12 Liberty Ave., LLC By: John W. Bieder, Esq. 100 Clearbrook Road Elmsford, New York 10523 Tel. No. (914) 704-4400 3 3 of 4 FILED: KINGS COUNTY CLERK 05/26/2021 01:59 PM INDEX NO. 510433/2019 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 05/26/2021 TO: LAW OFFICES OF BRYAN BARENBAUM Attorneys for Plaintiff Nicholas Grant 2060 Eastern Parkway Brooklyn, New York 11207 Tel. No. (718) 421-1111 JOUVAY NY, INC. 147-02 Liberty Avenue Jamaica, New York 11435 PROFESSIONAL CORPORATE SECURITY SERVICES, INC. C/O 153 Tee Avenue Central Islip, New York 11722 ISAAC J. RIOS 4 4 of 4