On November 22, 2018 a
Order
was filed
involving a dispute between
Derek Robinson,
Theresa Robinson,
and
Deepak Nanda M.D.,
Deepak Nanda, M.D., P.C.,
Emmanuel M. Pafos M.D.,
Long Island Jewish Medical Center,
Northwell Health, Inc.,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Queens County.
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FILED: QUEENS COUNTY CLERK 12/19/2019 02:23 PM INDEX NO. 717964/2018
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 12/19/2019
118-21 Queens Blvd.
THE PAGLINAWAN FIRM P.C. Suite 501
Forest Hills, NY 11375
T: (718) 576-2544
ATTORNEYS AT LAW F: (718) 576-2545
www.paglinawanfirm.com
James S. Paglinawan, Esq.
Email: jamesp@paglinawanfirm.com
December 19, 2019
VIA ECF
BROWN, GAUJEAN, KRAUS & SASTOW, PLLC
One North Broadway, Suite 1010
White Plains, NY 10601
GALVANO & XANTHAKIS, P.C.
358 St. Marks Place, Suite 202
Staten Island, NY 10301
GORDON & SILBER, P.C.
355 Lexington Avenue, 7th Floor
New York, NY 10017
RE: Robinson v. Northwell Health, Inc.
Index number 717964/2018
Dear Counsel:
As you are aware, this firm represents Plaintiffs in this matter. On July 16, 2019, all parties
appeared for a Preliminary Conference (“PC”), which resulted in an order directing Defendant to
respond within 30 days to Plaintiffs’ discovery demands and demand for bill of particulars as to
affirmative defenses dated July 2, 2019. Almost five months after these responses were due, I
still have not received any response from you.
Please treat this letter as my good faith effort to obtain your full compliance with the PC
order. Kindly provide a response to the above outstanding discovery as soon as possible to
avoid unnecessary motion practice. If you have any questions or wish to discuss this matter
further.
Sincerely,
James S. Paglinawan
JP/ll
1 of 1
Document Filed Date
December 19, 2019
Case Filing Date
November 22, 2018
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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FILED: QUEENS COUNTY CLERK 12/19/2019 02:23 PM INDEX NO. 717964/2018 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 12/19/2019 118-21 Queens Blvd. THE PAGLINAWAN FIRM P.C. Suite 501 Forest Hills, NY 11375 T: (718) 576-2544 ATTORNEYS AT LAW F: (718) 576-2545 www.paglinawanfirm.com James S. Paglinawan, Esq. Email: jamesp@paglinawanfirm.com December 19, 2019 VIA ECF BROWN, GAUJEAN, KRAUS & SASTOW, PLLC One North Broadway, Suite 1010 White Plains, NY 10601 GALVANO & XANTHAKIS, P.C. 358 St. Marks Place, Suite 202 Staten Island, NY 10301 GORDON & SILBER, P.C. 355 Lexington Avenue, 7th Floor New York, NY 10017 RE: Robinson v. Northwell Health, Inc. Index number 717964/2018 Dear Counsel: As you are aware, this firm represents Plaintiffs in this matter. On July 16, 2019, all parties appeared for a Preliminary Conference (“PC”), which resulted in an order directing Defendant to respond within 30 days to Plaintiffs’ discovery demands and demand for bill of particulars as to affirmative defenses dated July 2, 2019. Almost five months after these responses were due, I still have not received any response from you. Please treat this letter as my good faith effort to obtain your full compliance with the PC order. Kindly provide a response to the above outstanding discovery as soon as possible to avoid unnecessary motion practice. If you have any questions or wish to discuss this matter further. Sincerely, James S. Paglinawan JP/ll 1 of 1