Preview
FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
THERESA ROBINSON and DEREK ROBINSON,
Index #: 717964/2018
Plaintiff,
DEMAND FOR A
-against- VERIFIED BILL OF
PARTICULARS
NORTHWELL HEALTH, INC., LONG ISLAND JEWISH
MEDICAL CENTER, DEEPAK NANDA, M.D., P.C. and
DEEPAK NANDA, M.D.,
Defendants
==--========____ ===---=====-
PLEASE TAKE NOTICE that, pursuant to Rule 3042(a) of the CPLR, you are
hereby required to serve upon the undersigned attorneys for defendant, DEEPAK
NANDA, M.D, within twenty (20) days after the service of a copy of this demand, a
Verified Bill of Particulars of the Complaint setting forth in detail the following:
1. The dates and times of the day of the alleged negligent acts and/or omissions which
will be alleged against the answering defendant herein.
2. The location of the alleged negligent acts and/or omissions charged against the
defendant herein.
3. A statement of each and every act of negligence, commission or omission which
you will claim as the basis of the alleged malpractice of the defendant herein.
4. If itis alleged that the answering defendant is vicariously liable for the negligence,
acts, commissions, or omission of others, set forth with respect to each such act, negligence,
commission or omission:
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a. The name of the person committing same or if the names are not
known, a physical description sufficient to permit ready identification;
b. The occupation of each such person and by whom employed;
c. A general statement of the negligent acts and/or omissions allegedly
committed by each such person; and
d. The dates and times of day each such negligent act or omission was
committed.
5. State each and every act or omission which will be claimed as the basis of liability
of each of the other defendants sued herein, stating separately which act or omission will
be the basis of your claim against each or attach a copy of the Bill(s) served pursuant to
their Demand.
6. State whether or not any claim is made as to improper or defective equipment and
if so identify the equipment and state the defective conditions.
a. If notice is a prerequisite, state whether actual or constructive notice
is claimed;
b. If actual notice is claimed, state the time, place and name of the
person or persons to whom such notice was given;
c. If constructive notice is claimed, state how long the condition
existed.
7. Give a statement of the accepted medical practices, customs and medical standards
which itis claimed were violated/departed from by the answering defendant. See Hawkes
v. Mount Sinai Hospital, 75 A.D.2d 509, 426 N.Y.S.2d 745 (1st Dept. 1980).
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8. If itis claiiñed that the defendant on whose behalf this demand is made fhiled to
perform his/her professional duties in accordance with any manual, rule, regulation, statute,
law or ordinance, a statement specifying the manual(s), rule(s), regulation(s), statute(s),
law(s) or ordinance(s) claimed to have been violated with specific citation to title, volume
and page number.
| 9. If the plaintiff complains that the defeñdant ignored signs, symptoms, made an
erroneous diagnosis, afforded improper treatment, administered improper and/or
contraindicated drugs in an incorrect dosage, failed to take or administer tests or improperly
took and administered tests, state:
a. the complaints, signs, symptoms that the defendant ignored;
b. in what respect the diagnosis was erroneous and incorrect, what the
claimed correct diagnosis is,the point in time that the plaintiff claims the defendant should
have made the correct diagnosis;
c. the improper treatment that was afforded and in what manner the
said treatment was improperly performed;
d. the name of each and every contraindicated drug;
e. the name of each proper drug allegedly administered incorrectly;
f. the name of each and every test the defendant failed to take or
administer;
g. the name of each and every test the defendant improperly took or
administered and the manner in which each said testwas improperly taken or administered.
10. If plaintiff claims that defendant improperly performed a physical examination or
performed a contraindicated procedure and/or uñnecessary procedure, state:
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a. in what manner the physical examination was improperly
performed;
b. the name of the surgical procedure and the date performed; and
c. in what manner the surgical procedures were improperly performed.
11. Each other act or omission not included above which plaintiff will claim constituted
negligence on the part of the defendant.
12. State the following:
a. If it isclaimed that any negligence or malpractice occurred prior to
plaintiff being treated by the answering defendant, set forth the name or names of the
individuals it isclaimed are responsible for those acts or omissions;
b. If it is claimed that any negligence or malpractice occurred
snhacquent to plaintiff being treated by the answering defendant, set forth the name or
names of the individuals itis claimed are responsible for these acts or omissions and state
specifically what those acts or omissions consisted of.
13. Set forth the dates on which plaintiff sought and received medical treatment with
respect to the injuries claimed, setting forth the names of the doctors, or hospitals rendering
same and their addresses, and the nature of the treatment rendered with specific dates:
a. Prior to the date of the occurrence herein;
b. Subsequent to the date of the occurrence herein
14. State the injuries which plaintiff allegedly sustained as a result of the alleged
negligence anil/or medical malpractice of the defendant.
15. State which of the injuries listed above are claimed to be permanent.
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16. If itwill be claimed that the alleged injuries required hospitalization state the name
of each and every hospital with dates of confinement or outpatient treatment.
17. Ifit will be claimed that the alleged injuries required confinement to bed or home
state the period plaintiff was confined to bed, and period plaintiff was confined to home.
18. State separately the total amounts claimed by plaintiff as special damages for each
of the following:
a. physician services (with the names and addresses of treating
physician);
nurses'
b. services (including names and address of private duty nurse
or agency);
c. medicine (with name and address of pharmacy);
d. hospital expenses (with the names and addresses of allhospitals);
e. Ambulance services;
f. X-ray services;
g. Surgical services; psychiatric therapy and rehabilitation;
h. Physiotherapy and rehabilitation; and
i. Any other professional health services together with the nature of
said services.
19. If loss of earmngs will be claimed to have resulted from the alleged malpractice set
forth:
a. the amount of lost earnings claimed;
b. the plaintiff's gross earnings for the last calendar year prior to the
alleged negligence;
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c. the plaintiff's gross earnings for any calendar year during which it
will be claimed she was incapacitated from work;
d. Other income the plaintiff was receiving;
e. name and address of employer(s) at the time plaintiff was
incapacitated; and
f. name of last employer(s) and occupation, if different from 18(e).
20. If itwill be claimed that plaintiff lost profits from a business or enterprise as a
result of the defendant's negligence, state the following:
a. name of business and address;
b. state plaintiff's ownership capacity and interest in business;
c. state amount of profits and/or revenues itis claimed were lost as a result of
defendant's negligence;
d. state amount of net profit recorded by business in the two years prior to
the alleged negligence.
21. With respect to the plaintiff spouse, set forth:
a. Type of business or occupation;
b. If self-employed,·name of business and address; and
c. If not self-employed, name and address of employer.
22. State whether or not plaintiff has been reimbursed for physician and/or hospital
expenses,
a. If the answer is in the affirmative, state for which such claims plaintiff has
been reimbursed, the amount of reimbursement received for each element of
special damages and the name of the person, firm or organization that made such
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reimbursement.
b. If such reimbursement was made by an insurance company, state the
number of the policy under which paid.
23. If further medical expenses are anticipated as a result of the alleged malpractice set
forth the expense and the anticipated period of time the expense will be incurred for the
following:
a. physician expenses;
b. hospital expenses;
c. expenses for medicine;
d. nursing expenses;
i
e. other (specify).
24. If a derivative claim for loss of services is asserted by a plaintiff, provide the
following particulars:
a. The date and place of the marriage;
b. State whether the plaintiffs were living together as husband and wife
immediately prior to the alleged malpractice;
c. The basis for the claim of loss of consortium, services, love and
affection of which William Martin was allegedly deprived;
d. An itemized statement of all monetary sums claims as part of the
loss of services claim,
e. An itemized statement of all future monetary damages claimed as
part of the loss of services cause of action;
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f. Identify and state each element of the plaintiff's (William Martin's)
loss of services claim which itis claimed is a permanent condition.
25. Each and every other item or damage claimed by the plaintiff.
26. Whether plaintiff has made a claim or claims against any party, other than those
nanied in this lawsuit, individual or entity arising out of the facts and circumstances giving
rise to the within suit, specifying the following:
a. The name or names of each such parties against whom additional
claim(s) were made;
b. Whether or not those claim(s) have been placed into suit, and if so,
state the titleof the action and the venue of the action; index number of said action, ifany;
c. Attach copies of any pleadings served in said action or actions;
d. Whether or not such claim or action has been settled or otherwise,
and if so, state the amount of such settlement, the parties with whom such settlement was
entered into, ifotherwise resolved, set forth a statement of the manner in which it was
otherwise resolved, and attach copies of General Releases and Stipulations of
Discontinuance evidencing such settlement, resolution or discontinuance.
27. State whether any state or federal agency, i.e.,Medicare, Medicaid, Social Services,
etc. has any interest in the proceeds of any recovery, jury verdict or settlement any plaintiff
may receive in this action.
28. If lack of informed consent is claimed state each and every manner and respect that
the answering defendant allegedly failed to disclose to the plaintiff such altematives to
treatment or diagnosis and the reasonably foreseeable risks and benefits involved as a
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reasonable medical practitioner under similar circumstances would have disclosed, in a
manner permitting the plaintiff to make a knowledgeable evaluation.
29. State whether itis claimed that the procedure or procedures for which the plaintiff
allegedly did not give an informed consent were:
a. non-emergency treatment, procedure or surgery; or
b. a diagnostic procedure which involved invasion or disruption of the
integrity of the body.
30. Identify each and every procedure which is or will be claimed to have been
performed on the plaintiff and for which the plaintiff will claim that they were not
informed of the alternatives thereto and the reasonably foreseeable risks and benefits
involved in the procedure.
31, For the procedure or procedures identified in paragraph 29:
a. state whether itis claimed that a reasonably prudent person in the
plaintiff's position would not have undergone treatment or diagnosis if he
or she has been fully informed; and
b. identify each and every maññêr in which itis claimed that the alleged lack
of informed consent proximately caused the injuries for which the plaintiff
seeks recovery in the complaint.
32. With regard to the lack of informed consent claim, set forth what information the
answering defendant failed to provide plaintiff's decedent, that allegedly should have
been provided, with regard to:
a. The procedures;
b. risks; and
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c. alternatives.
plaintiffs'
33. The date and place of birth for both Theresa Robinson and Derek
Robinson, including name at birth.
34. State the residence address of the plaintiffs
a. At the time the action arose;
b. At the present time.
35. Set forth the Social Security number of each of the plaintiffs.
Dated: White Plains, New York
March 20, 2019
Yours, etc.,
BROWN, GAUJEAN, KRAUS & SASTOW,
PLLC
: Ginette M. Portera
tto eys for Defendant
EPAK NANDA, M.D.
One North - Suite 1010
Broadway
White Plains, New York 10601 .
(914) 949-5300
TO: Munawar & Andrews-Santillo, LLP
Attorneys for Plaintiffs
420 Lexington Avenue - Suite 2601
New York, New York 10170
212- 400-4000
!
Law Offices of Benvenuto & Slattery
Attorneys for Defendants
Long Island Jewish Medical Center
& Northwell Health, Inc.
1800 Northern Boulevard
Roslyn, New York 11576
516-775-2236
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Preview
FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS THERESA ROBINSON and DEREK ROBINSON, Index #: 717964/2018 Plaintiff, DEMAND FOR A -against- VERIFIED BILL OF PARTICULARS NORTHWELL HEALTH, INC., LONG ISLAND JEWISH MEDICAL CENTER, DEEPAK NANDA, M.D., P.C. and DEEPAK NANDA, M.D., Defendants ==--========____ ===---=====- PLEASE TAKE NOTICE that, pursuant to Rule 3042(a) of the CPLR, you are hereby required to serve upon the undersigned attorneys for defendant, DEEPAK NANDA, M.D, within twenty (20) days after the service of a copy of this demand, a Verified Bill of Particulars of the Complaint setting forth in detail the following: 1. The dates and times of the day of the alleged negligent acts and/or omissions which will be alleged against the answering defendant herein. 2. The location of the alleged negligent acts and/or omissions charged against the defendant herein. 3. A statement of each and every act of negligence, commission or omission which you will claim as the basis of the alleged malpractice of the defendant herein. 4. If itis alleged that the answering defendant is vicariously liable for the negligence, acts, commissions, or omission of others, set forth with respect to each such act, negligence, commission or omission: 1 of 10 FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 a. The name of the person committing same or if the names are not known, a physical description sufficient to permit ready identification; b. The occupation of each such person and by whom employed; c. A general statement of the negligent acts and/or omissions allegedly committed by each such person; and d. The dates and times of day each such negligent act or omission was committed. 5. State each and every act or omission which will be claimed as the basis of liability of each of the other defendants sued herein, stating separately which act or omission will be the basis of your claim against each or attach a copy of the Bill(s) served pursuant to their Demand. 6. State whether or not any claim is made as to improper or defective equipment and if so identify the equipment and state the defective conditions. a. If notice is a prerequisite, state whether actual or constructive notice is claimed; b. If actual notice is claimed, state the time, place and name of the person or persons to whom such notice was given; c. If constructive notice is claimed, state how long the condition existed. 7. Give a statement of the accepted medical practices, customs and medical standards which itis claimed were violated/departed from by the answering defendant. See Hawkes v. Mount Sinai Hospital, 75 A.D.2d 509, 426 N.Y.S.2d 745 (1st Dept. 1980). 2 of 10 FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 8. If itis claiiñed that the defendant on whose behalf this demand is made fhiled to perform his/her professional duties in accordance with any manual, rule, regulation, statute, law or ordinance, a statement specifying the manual(s), rule(s), regulation(s), statute(s), law(s) or ordinance(s) claimed to have been violated with specific citation to title, volume and page number. | 9. If the plaintiff complains that the defeñdant ignored signs, symptoms, made an erroneous diagnosis, afforded improper treatment, administered improper and/or contraindicated drugs in an incorrect dosage, failed to take or administer tests or improperly took and administered tests, state: a. the complaints, signs, symptoms that the defendant ignored; b. in what respect the diagnosis was erroneous and incorrect, what the claimed correct diagnosis is,the point in time that the plaintiff claims the defendant should have made the correct diagnosis; c. the improper treatment that was afforded and in what manner the said treatment was improperly performed; d. the name of each and every contraindicated drug; e. the name of each proper drug allegedly administered incorrectly; f. the name of each and every test the defendant failed to take or administer; g. the name of each and every test the defendant improperly took or administered and the manner in which each said testwas improperly taken or administered. 10. If plaintiff claims that defendant improperly performed a physical examination or performed a contraindicated procedure and/or uñnecessary procedure, state: 3 of 10 FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 a. in what manner the physical examination was improperly performed; b. the name of the surgical procedure and the date performed; and c. in what manner the surgical procedures were improperly performed. 11. Each other act or omission not included above which plaintiff will claim constituted negligence on the part of the defendant. 12. State the following: a. If it isclaimed that any negligence or malpractice occurred prior to plaintiff being treated by the answering defendant, set forth the name or names of the individuals it isclaimed are responsible for those acts or omissions; b. If it is claimed that any negligence or malpractice occurred snhacquent to plaintiff being treated by the answering defendant, set forth the name or names of the individuals itis claimed are responsible for these acts or omissions and state specifically what those acts or omissions consisted of. 13. Set forth the dates on which plaintiff sought and received medical treatment with respect to the injuries claimed, setting forth the names of the doctors, or hospitals rendering same and their addresses, and the nature of the treatment rendered with specific dates: a. Prior to the date of the occurrence herein; b. Subsequent to the date of the occurrence herein 14. State the injuries which plaintiff allegedly sustained as a result of the alleged negligence anil/or medical malpractice of the defendant. 15. State which of the injuries listed above are claimed to be permanent. 4 of 10 FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 16. If itwill be claimed that the alleged injuries required hospitalization state the name of each and every hospital with dates of confinement or outpatient treatment. 17. Ifit will be claimed that the alleged injuries required confinement to bed or home state the period plaintiff was confined to bed, and period plaintiff was confined to home. 18. State separately the total amounts claimed by plaintiff as special damages for each of the following: a. physician services (with the names and addresses of treating physician); nurses' b. services (including names and address of private duty nurse or agency); c. medicine (with name and address of pharmacy); d. hospital expenses (with the names and addresses of allhospitals); e. Ambulance services; f. X-ray services; g. Surgical services; psychiatric therapy and rehabilitation; h. Physiotherapy and rehabilitation; and i. Any other professional health services together with the nature of said services. 19. If loss of earmngs will be claimed to have resulted from the alleged malpractice set forth: a. the amount of lost earnings claimed; b. the plaintiff's gross earnings for the last calendar year prior to the alleged negligence; 5 of 10 FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 c. the plaintiff's gross earnings for any calendar year during which it will be claimed she was incapacitated from work; d. Other income the plaintiff was receiving; e. name and address of employer(s) at the time plaintiff was incapacitated; and f. name of last employer(s) and occupation, if different from 18(e). 20. If itwill be claimed that plaintiff lost profits from a business or enterprise as a result of the defendant's negligence, state the following: a. name of business and address; b. state plaintiff's ownership capacity and interest in business; c. state amount of profits and/or revenues itis claimed were lost as a result of defendant's negligence; d. state amount of net profit recorded by business in the two years prior to the alleged negligence. 21. With respect to the plaintiff spouse, set forth: a. Type of business or occupation; b. If self-employed,·name of business and address; and c. If not self-employed, name and address of employer. 22. State whether or not plaintiff has been reimbursed for physician and/or hospital expenses, a. If the answer is in the affirmative, state for which such claims plaintiff has been reimbursed, the amount of reimbursement received for each element of special damages and the name of the person, firm or organization that made such 6 of 10 | FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 reimbursement. b. If such reimbursement was made by an insurance company, state the number of the policy under which paid. 23. If further medical expenses are anticipated as a result of the alleged malpractice set forth the expense and the anticipated period of time the expense will be incurred for the following: a. physician expenses; b. hospital expenses; c. expenses for medicine; d. nursing expenses; i e. other (specify). 24. If a derivative claim for loss of services is asserted by a plaintiff, provide the following particulars: a. The date and place of the marriage; b. State whether the plaintiffs were living together as husband and wife immediately prior to the alleged malpractice; c. The basis for the claim of loss of consortium, services, love and affection of which William Martin was allegedly deprived; d. An itemized statement of all monetary sums claims as part of the loss of services claim, e. An itemized statement of all future monetary damages claimed as part of the loss of services cause of action; 7 of 10 FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 f. Identify and state each element of the plaintiff's (William Martin's) loss of services claim which itis claimed is a permanent condition. 25. Each and every other item or damage claimed by the plaintiff. 26. Whether plaintiff has made a claim or claims against any party, other than those nanied in this lawsuit, individual or entity arising out of the facts and circumstances giving rise to the within suit, specifying the following: a. The name or names of each such parties against whom additional claim(s) were made; b. Whether or not those claim(s) have been placed into suit, and if so, state the titleof the action and the venue of the action; index number of said action, ifany; c. Attach copies of any pleadings served in said action or actions; d. Whether or not such claim or action has been settled or otherwise, and if so, state the amount of such settlement, the parties with whom such settlement was entered into, ifotherwise resolved, set forth a statement of the manner in which it was otherwise resolved, and attach copies of General Releases and Stipulations of Discontinuance evidencing such settlement, resolution or discontinuance. 27. State whether any state or federal agency, i.e.,Medicare, Medicaid, Social Services, etc. has any interest in the proceeds of any recovery, jury verdict or settlement any plaintiff may receive in this action. 28. If lack of informed consent is claimed state each and every manner and respect that the answering defendant allegedly failed to disclose to the plaintiff such altematives to treatment or diagnosis and the reasonably foreseeable risks and benefits involved as a 8 of 10 FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 reasonable medical practitioner under similar circumstances would have disclosed, in a manner permitting the plaintiff to make a knowledgeable evaluation. 29. State whether itis claimed that the procedure or procedures for which the plaintiff allegedly did not give an informed consent were: a. non-emergency treatment, procedure or surgery; or b. a diagnostic procedure which involved invasion or disruption of the integrity of the body. 30. Identify each and every procedure which is or will be claimed to have been performed on the plaintiff and for which the plaintiff will claim that they were not informed of the alternatives thereto and the reasonably foreseeable risks and benefits involved in the procedure. 31, For the procedure or procedures identified in paragraph 29: a. state whether itis claimed that a reasonably prudent person in the plaintiff's position would not have undergone treatment or diagnosis if he or she has been fully informed; and b. identify each and every maññêr in which itis claimed that the alleged lack of informed consent proximately caused the injuries for which the plaintiff seeks recovery in the complaint. 32. With regard to the lack of informed consent claim, set forth what information the answering defendant failed to provide plaintiff's decedent, that allegedly should have been provided, with regard to: a. The procedures; b. risks; and 9 of 10 FILED: QUEENS COUNTY CLERK 03/20/2019 03:43 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/20/2019 c. alternatives. plaintiffs' 33. The date and place of birth for both Theresa Robinson and Derek Robinson, including name at birth. 34. State the residence address of the plaintiffs a. At the time the action arose; b. At the present time. 35. Set forth the Social Security number of each of the plaintiffs. Dated: White Plains, New York March 20, 2019 Yours, etc., BROWN, GAUJEAN, KRAUS & SASTOW, PLLC : Ginette M. Portera tto eys for Defendant EPAK NANDA, M.D. One North - Suite 1010 Broadway White Plains, New York 10601 . (914) 949-5300 TO: Munawar & Andrews-Santillo, LLP Attorneys for Plaintiffs 420 Lexington Avenue - Suite 2601 New York, New York 10170 212- 400-4000 ! Law Offices of Benvenuto & Slattery Attorneys for Defendants Long Island Jewish Medical Center & Northwell Health, Inc. 1800 Northern Boulevard Roslyn, New York 11576 516-775-2236 10 of 10