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EXHIBIT A
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
------------------------------------- X
DINO BONAVITA
Plaintiff '
NOTICE OF MEDICAL
-against-
MALPRACTICE ACTION
Indemo.: 6H5092018
SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF
NEW YORK, P.C., NORTH SHORE UNIVERSITY HOSPITAL,
and NORTHWELL HEALTH.
Defendants.
---------- X
1. Full name, address and age of Plaintiff: Dino Bonavita, 17 Sinclair Martin Drive, Roslyn,
NY 11576, age 50.
2. Full name and address of each Defendant:
a.) Syed Mujahid Sayeed, M.D. located at 139 Plandome Road, Manhasset, NY
11030;
b.) Precision Surgery of New York, P.C., located at 139 Plandome Road,
Manhasset, NY 11030;
c.) North Shore University Hospital, located at 300 Community Drive, Manhasset,
NY 11030; and
d.) Northwell Health, located at 2000 Marcus Avenue, New Hyde Park, NY 11042.
3. Alleged medical specialty: Hand Surgery.
4. Claim is for Medical Malpractice.
5. Date and place claim arose: On or about June 21, 2017 through October 31, 2017 at the
offices of Syed Mujahid Sayeed M.D., Precision Surgery of New York, P.C., North Shore
University Hospital, and Northwell Health.
6. Substance of claim: failing to timely, properly and appropriately treat and diagnose
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plaintiff's medical condition, including hand surgery and surgical aftercare, on or about June 21,
2017 through October 31, 2017.
7a. Proof is attached that authorizations to obtain medical and hospital records have been
served upon Defendants in the action.
7b. Copies of Summons, all pleadings, Verified Bill of Particulars, Response to
Defendant's Discovery Demands are attached. Issue was joined by Answers dated September 20,
2018 and September 28, 2018.
8. Names, addresses and telephone numbers of counsel for all parties:
CAITLIN ROBIN & ASSOCIATES, PLLC
Attorneys for the Plaintiffs
30 Broad Street, Suite 702
New York, NY 10004
646-524-6026
LAW OFFICE OF BENVENUTO & SLATTERY
Atorneys for Defendants
SYED MUJAHID SAYEED, M.D., and
PRECISION SURGERY OF NEW YORK, P.C.
1800 Northern Boulevard
Roslyn, New York, 11576
(516) 775-2236
RUB1N PATERNITI GONZALEZ KAUFMAN, LLP
Attorneys for Defendant
NORTH SHORE UNIVERSITY HOSPITAL,
and NORTHWELL HEALTH
1225 Franklin Avenue, Suite 200
Garden City, New York 11530
(516) 344-6376
Dated: New York, New York
January 22, 2019
Yours, Etc.
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CAITLIN ROB1N, ESQ
CAITLIN ROBIN & ASSOCIATES PLLC
Attorneys for Plaintiff
30 Broad Street, Suite 702
New York, NY 10004
Phone: (646) 524-6026
TO:
LAW OFFICE OF BENVENUTO & SLATTERY
Attorneys for Defendants
SYED MUJAHID SAYEED, M.D., and
PRECISION SURGERY OF NEW YORK, P.C.
1800 Northern Boulevard
Roslyn, New York, 11576
(516) 775-2236
RUBIN PATERNITI GONZALEZ KAUFMAN, LLP
Attorneys for Defendant
NORTH SHORE UNIVERSITY HOSPITAL,
and NORTHWELL HEALTH
1225 Franklin Avenue, Suite 200
Garden City, New York 11530
(516) 344-6376
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AFFIDAVIT OF SERVICE
STATE OF NEW YORK, COUNTY OF NEW YORK ss.:
Sandy Sun being duly sworn, deposes and says:
I am over 18 years of age, I am not a party to the action, and I reside in Essex County in the State
of New Jersey.
I served a true copy of the annexed
NOTICE OF MEDICAL _MALPRACTICE ACTION
on January 2019
by mailing the same in a sealed envelope, with postage prepaid thereon, in a post office or official
depository of the U.S. Postal Service within the State of New York, addressed to the last known
address of the addressee as indicated below:
LAW OFFICE OF BENVENUTO & SLATTERY
1800 Northern Boulevard
Roslyn, New York, 11576
RUB1N PATERNITI GONZALEZ KAUFMAN, LLP
1225 Franklin Avenue, Suite 200
Garden City, New York 1153
Sun
Sworn to before me JanuaryÊ2019
Notary Pu c
JULIE ANNE LARSEN
NOTARY PUBLIC-STATE OF NEW YORK
No. 01LA6352111
Q ualified
in New York County
My Commission Expires 12-19-2020
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Index No. 611506/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
DINO BONAVITA,
Plaintiff,
-against-
SYED MUJAEID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH
SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH,
Defendants.
NOTICE OF MEDICAL MALPRACTICE ACTION
CAITLIN ROBIN & ASSOCIATES PLLC
Attorneys for Plaintiff
DINO BONAVITA
30 Broad Street, Suite 702
New York, NY 10004
(646) 524-6026
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SUPREME COURT OF THE STATE OF NEW YORK
Index No.:
COUNTY OF NASSAU
Date Filed:
_____________.______..------------------------- X
DINO BONAVITA,
SUMMONS
Plaintiff'
Plaintiff designates Nassau
County as the place of trial
-against-
The basis of the venue is:
Defendant's Practice
SYED MUJAHID SAYEED, M.D., PREÖISION
SURGERY OF NEW YORK, P.C., NORTH SHORE
Defendant s practice is
UNIVERSITY HOSPITAL, and NORTHWELL HEALTH,
located at 139 Plandome Rd,
Manhasset, NY 11030
Defendants.
-------------------------------- --------------------------X
TO THE ABOVE NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED to answer the complaint in this action, and
to serve a copy of your answer, or if the complaint is not served with this summons, to
Plaintiffs'
serve a notice of appearance, on the Attorney(s) within twenty (20) days after
the service of this summons, exclusive of the day of service, where service is made by
delivery upon you personally within the state, or within thirty (30) days after the
completion of service where service is made in any other manner. In case of your failure
to appear or answer, judgment will be taken against you by default for the relief
demanded in the complaint.
Dated: New York, NY
August 24, 2018
CAITLIN ROBIN & ASSOCIATES, PLLC
Caitlin Robin
Attorneys for Plaintiffs
DINO BONAVITA
30 Broad Street, Suite 702
New York, New York 10004
Phone: (646) 524-6026
Fax: (929) 210-7549
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DEFENDANT'S ADDRESS
SYED MUJAHID SAYEED, D.
139 Plandome Road
Manhasset, NY 11030
PRECISION SURGERY OF NEW YORK, P.C.
139 Plandome Road
Manhasset, NY 11030
NORTH SHORE UNIVERSITY HOSPITAL
300 Community Dr
Manhasset, NY 11030
NORTHWELL HEALTH
2000 Marcus Avenue
New Hyde Park, NY 11042
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
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DINO BONAVITA,
Plaintift
VERIFIED COMPLAINT
-againsk
Index No.:
SYED MUJAHID SAYEED, M.D., PRECISION
SURGERY OF NEW YORK, P.C., NORT.H SHORE
UNIVERSITY HOSPITAL, and NORTHWELL HEALTH,
Defendants.
____..___________________________________----------- X
Plaintiffs, by their attorneys, CAITLIN ROBIN & ASSOCIATES, PLLC, as and
for their Verified Complaint, alleges upon infonnation and belief as follows:
1. At all times hereinafter mentioned, Plaintiff, DINO BONAVITA, was and
is a resident of 17 Sinclair Martin Drive, Roslyn, NY 11576.
2. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., was and stillis a duly licensed physician
in the State of New York engaged in the practice of his profession in the County of
Nassau, State of New York, with a principal place of business located at139 Plaiidailic
Road, Manhasset, NY 11030.
3. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAH1D SAYEED, M.D., acted upon the scope as an agent, servant
and/or employee of PRECISION SURGERY OF NEW YORK, P.C. to render medical
evaluation, assessiiiciit, diagnosis, care, treatment, services, testing, surgery and/or
consultation to DINO BONAVITA.
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4. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID acted upon the scope as a principal
SAYEED, M.D.,
member, shareholder and/orownerofthe Defendant PRECISION SURGERY OF NEW
YORK, P.C., to render medical evaluation, assessment, diagnosis, care, treatment,
services, testing, surgery and/or consultation to DINO BONAVITA.
5. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant
and/or employee of Defendant NORTH SHORE UNIVERSITY HOSPITAL to render
medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery
and/or consultation to DINO BONAVITA.
6. That upon information and belief, at all times herein mentioned
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal,
member, shareholder and/or owner of the Defendant NORTH SHORE UNIVERSITY
HOSPITAL, to render medical evaluation, assessment, diagnosis, care, treatment,
services, testing, surgery and/or consultation to DINO BONAVITA.
7. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant
and/or employee of Defendant NORTHWELL HEALTH to render medical evaluation,
assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to
DINO BONAVITA.
8. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal,
member, shareholder and/or owner of the Defendant NORTHWELL HEALTH, to render
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medical evaluation, assessment, diagnoàis, care, treatment, servicest testing, surgery
and/or consultation to DIN0 BONAVITA.
9c That Apon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., was and stillis a domestic
professional corporation duly organized and existing under and by the laws of the State of
New York with itsprinciple place of business located at 139 Plandome Road, Manhasset,
NY 11030.
10. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., was and still is a foreign
limited liability company existing under and by the laws of the State of New York with
itspriiiciplc place of business located at 139 Plandome Road, Manhasset, NY 11030.
11. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., through itsagents, servants,
employees and/or other medical personnel or other individuals acting under its agency,
supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held
itself out as a provider offering profesennal health care services to the members of the
general public, including Plaintiff, DINO BONAVITA.
12. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., through its agents, servants,
employees and/or other medical persoiisicl or other individuals acting under its agency,
supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held
itselfout as duly qualified to render proper medical evaluation, assessment, diagiiusis,
care, treatment, services, testing and/or consultation in accordance with good and
5 af 21
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accepted standards of practice in the community to the members of the general public,
including Plaintiff, DINO BONAVITA,
13. That upon information and at all times herein mentioned,.
belief,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., owned, operated,
maintained supervised, managed, and controlled certain medical facilities known as
PRECISION SURGERY OF NEW YORK, P.C., where it employed such agents,
servants and/or employees for the purpose of rending diagnosis, care, treatment, surgical
services and advice to members of the general public, including Plaintiff, DINO
BONAVITA.
14. That upon information and belief, at all times herein mentioned,
Defendant PRECISION SURGERY OF NEW YORK, P.C., hired, engaged and/or
otherwise took responsibility for the actions of healthcare professionals, staff and
pasanuel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D.
15. That upon information and belief, at all times herein mentioned,
Defendant, PRECISION SURGERY OF NEW YORK, P.C., is vicariously liable for the
actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D.
16. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, was and still is a domestic
professional corporation duly organized and existing under and by the laws of the State of
New York with its principle place of business located at 300 Community Drive,
Manhasset, NY 11030.
17. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, was and still is a foreign
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limited liability company eñsting under and by the lawa of the State of New York with
itsprincijile pleâe of business located at 300 Community Drive, Manhasset, W NU30.
1& That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, through its agents, servants,
employees and/or other medical personnel or other individuals acting under itsagency,
supervision and control, including Defendant SYED MUJAHlD SAYEED, M.D., held
itself out as a provider offering professional health care services to the members of the
general public, including Plaintiff, DINO BONAVITA.
19. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, through its agents, servants,
employees and/or other medical personnel or other individuals acting under its agency,
supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held
itself out as duly qualified to render proper medical evaluation, asse«ment, diagnosis,
care, treatment, services, testing and/or consultation in accordance with good and
accepted standards of practice in the community to the members of the general public,
including Plaintiff,DINO BONAVITA.
20. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, owned, operated, maintained,
supervised, managed, and controlled certain medical facilities known as NORTH SHORE
UNIVERSITY HOSPITAL, where it employed such agents, servants and/or employees
for the purpose of rending diagnosis, care, treatment, surgical services and advice to
members of the general public, including Plaintiff, DINO BONAVITA.
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2L That upon inforntation and belief, at all times herein rnentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, hired, engaged and/or
otherwise took responsibility for the actions of healthcare professionals, staff and
personnel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D.
22. That upon information and belief, at all times herein mentioned,
Defendant, NORTH SHORE UNIVERSITY HOSPITAL, is vicariously liable for the
actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D.
23. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, was and still is a domestic professional
corporation duly organized and existing under and by the laws of the State of New York
. with itsprinciple place of business located at 2000 Marcus Avenue, New Hyde Park, NY
11042.
24. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, was and stillis a foreign limited liability company
existing under and by the laws of the State of New York with its principle place of
business located at 2000 Marcus Avenue, New Hyde Park, NY 11042.
25. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, through its agents, servants, employees and/or
other medical personnel or other individuals acting under its agency, supervision and
control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as a
provider offering professional health care services to the members of the general public,
including Plaintiff, DINO BONAVITA.
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26. That upon information and belief, at all times herein meñtióned,
Defendant, NOldBWER HEALTH, through its agents, servants, employees and/or
other anedical personnel or other individuals acting under its agency, supervision and
control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as duly
qualified to render proper medical evaluation, assessment, diagnosis, care, treatment,
services, testing and/or consultation in accordance with good and accepted standards of
practice in the community to the mcmbers of the general public, including Plaintiff,
DINO BONAVITA.
27. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL owned, operated, maintained supervised,
HEALTH,
managed, and controlled certain medical facilities known as NORTHWELL HEALTH,
where it employed such agents, servants and/or employees for the purpose of rending
diagnosis, care, treatment, surgical services and advice to members of the general public,
including Plaintiff, DINO BONAVITA.
28. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, hired, engaged and/or otherwise took
responsibility for the actions of healthcare professionals, staff and personnel, including
but not limited to Defendant SYED MUJAHID SAYEED, M.D.
29. That upon information and belief, at all times herein mentioned,
Defendant, NORTHWELL HEALTH, is vicariously liable for the actions and/or
omissions of the Defendant, SYED MUJAHID SAYEED, M.D.
30. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., held himself out as duly qualified to
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render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing
and/or consultation in accordance with good and accepted standâ¾ds of practice in th#
community to the members of the general public, including Plaintiff, DINO BONAVITA.
31. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., held himself out as a provider offering
professional health care services to the members of the general public, including Plaintiff,
DINO BONAVITA.
32. That upon information and belief, at all times herein mentioned,
Defendant, SYED MUJAHID SAYEED, M.D., through its agents, servants, employees
and/or other medical personnel or other individuals acting under his agency, supervision
and control, held himself out as duly qualified to render proper medical evaluation,
assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance
with good and accepted standards of practice in the community to the members of the
general public, including Plaintiff, DINO BONAVITA.
33. That upon information and belief, at all times herein mentioned,
Defend ant, SYED MUJAHID SAYEED, M.D., hired, engaged and/or otherwise took
responsibility for the actions of healthcare professionals, staff and personnel, and had a
duty to manage, control and otherwise supervise their work during the care, treatment and
services of persons such as Plaintiff, DINO BONAVITA.
34. That upon information and belief, at all times herein mentioned,
Defendants, PRECISION SURGERY OF NEW YORK, P.C. and SYED MUJAHID
SAYEED, M.D. individually and by and through their agents, servants and/or employees
agreed to, undertook to and did render certain medical evaluation, assessinent, diagnosis,
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care, treatment, testing, and surgical services, and/or consultation to Plaintiff, DINO
BONAVITA, beginning on or about July 21, 2017 through October 31, 2017.
3 That upon information and belief, at all tirnes herein rnentioned,
Defendants, PRECISION SURGERY OLNEW YORK BYED MUlkH1D
TE$ǾE individúan es rs$harehede
a dingi 0 iQáfQehtinent, te nd surgica id/or con i ties
D feh s NORTIRS) RE UNIVERSH OSPIT id SYED D
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38. That upon information and belief, at call tunes herein mentioned,
Defendants, NORTHWELL HEALTH and SYED MUJAHID SAYEED, M.D.
individually and by and through their agents, servants and/or employees agreed to,
undertook to and did render certain medical evaluation, assessment, diagnosis, care,
treatment, testing, and surgical services, and/or consultation to Plaintiff, DINO
BONAVITA, beginning on or about July 21, 2017 through October 31, 2017.
39. That upon information and belief,
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FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 01/22/2019 EXHIBIT A FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 01/22/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ------------------------------------- X DINO BONAVITA Plaintiff ' NOTICE OF MEDICAL -against- MALPRACTICE ACTION Indemo.: 6H5092018 SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH. Defendants. ---------- X 1. Full name, address and age of Plaintiff: Dino Bonavita, 17 Sinclair Martin Drive, Roslyn, NY 11576, age 50. 2. Full name and address of each Defendant: a.) Syed Mujahid Sayeed, M.D. located at 139 Plandome Road, Manhasset, NY 11030; b.) Precision Surgery of New York, P.C., located at 139 Plandome Road, Manhasset, NY 11030; c.) North Shore University Hospital, located at 300 Community Drive, Manhasset, NY 11030; and d.) Northwell Health, located at 2000 Marcus Avenue, New Hyde Park, NY 11042. 3. Alleged medical specialty: Hand Surgery. 4. Claim is for Medical Malpractice. 5. Date and place claim arose: On or about June 21, 2017 through October 31, 2017 at the offices of Syed Mujahid Sayeed M.D., Precision Surgery of New York, P.C., North Shore University Hospital, and Northwell Health. 6. Substance of claim: failing to timely, properly and appropriately treat and diagnose FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 01/22/2019 plaintiff's medical condition, including hand surgery and surgical aftercare, on or about June 21, 2017 through October 31, 2017. 7a. Proof is attached that authorizations to obtain medical and hospital records have been served upon Defendants in the action. 7b. Copies of Summons, all pleadings, Verified Bill of Particulars, Response to Defendant's Discovery Demands are attached. Issue was joined by Answers dated September 20, 2018 and September 28, 2018. 8. Names, addresses and telephone numbers of counsel for all parties: CAITLIN ROBIN & ASSOCIATES, PLLC Attorneys for the Plaintiffs 30 Broad Street, Suite 702 New York, NY 10004 646-524-6026 LAW OFFICE OF BENVENUTO & SLATTERY Atorneys for Defendants SYED MUJAHID SAYEED, M.D., and PRECISION SURGERY OF NEW YORK, P.C. 1800 Northern Boulevard Roslyn, New York, 11576 (516) 775-2236 RUB1N PATERNITI GONZALEZ KAUFMAN, LLP Attorneys for Defendant NORTH SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH 1225 Franklin Avenue, Suite 200 Garden City, New York 11530 (516) 344-6376 Dated: New York, New York January 22, 2019 Yours, Etc. FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 01/22/2019 CAITLIN ROB1N, ESQ CAITLIN ROBIN & ASSOCIATES PLLC Attorneys for Plaintiff 30 Broad Street, Suite 702 New York, NY 10004 Phone: (646) 524-6026 TO: LAW OFFICE OF BENVENUTO & SLATTERY Attorneys for Defendants SYED MUJAHID SAYEED, M.D., and PRECISION SURGERY OF NEW YORK, P.C. 1800 Northern Boulevard Roslyn, New York, 11576 (516) 775-2236 RUBIN PATERNITI GONZALEZ KAUFMAN, LLP Attorneys for Defendant NORTH SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH 1225 Franklin Avenue, Suite 200 Garden City, New York 11530 (516) 344-6376 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 01/22/2019 AFFIDAVIT OF SERVICE STATE OF NEW YORK, COUNTY OF NEW YORK ss.: Sandy Sun being duly sworn, deposes and says: I am over 18 years of age, I am not a party to the action, and I reside in Essex County in the State of New Jersey. I served a true copy of the annexed NOTICE OF MEDICAL _MALPRACTICE ACTION on January 2019 by mailing the same in a sealed envelope, with postage prepaid thereon, in a post office or official depository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressee as indicated below: LAW OFFICE OF BENVENUTO & SLATTERY 1800 Northern Boulevard Roslyn, New York, 11576 RUB1N PATERNITI GONZALEZ KAUFMAN, LLP 1225 Franklin Avenue, Suite 200 Garden City, New York 1153 Sun Sworn to before me JanuaryÊ2019 Notary Pu c JULIE ANNE LARSEN NOTARY PUBLIC-STATE OF NEW YORK No. 01LA6352111 Q ualified in New York County My Commission Expires 12-19-2020 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 01/22/2019 Index No. 611506/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU DINO BONAVITA, Plaintiff, -against- SYED MUJAEID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, Defendants. NOTICE OF MEDICAL MALPRACTICE ACTION CAITLIN ROBIN & ASSOCIATES PLLC Attorneys for Plaintiff DINO BONAVITA 30 Broad Street, Suite 702 New York, NY 10004 (646) 524-6026 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: INDEX NO.01/22/2019 611506/2018 |FILED: NASSAU COUNTY CLERK 08/24/2018 01:01 PM) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF NASSAU Date Filed: _____________.______..------------------------- X DINO BONAVITA, SUMMONS Plaintiff' Plaintiff designates Nassau County as the place of trial -against- The basis of the venue is: Defendant's Practice SYED MUJAHID SAYEED, M.D., PREÖISION SURGERY OF NEW YORK, P.C., NORTH SHORE Defendant s practice is UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, located at 139 Plandome Rd, Manhasset, NY 11030 Defendants. -------------------------------- --------------------------X TO THE ABOVE NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED to answer the complaint in this action, and to serve a copy of your answer, or if the complaint is not served with this summons, to Plaintiffs' serve a notice of appearance, on the Attorney(s) within twenty (20) days after the service of this summons, exclusive of the day of service, where service is made by delivery upon you personally within the state, or within thirty (30) days after the completion of service where service is made in any other manner. In case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: New York, NY August 24, 2018 CAITLIN ROBIN & ASSOCIATES, PLLC Caitlin Robin Attorneys for Plaintiffs DINO BONAVITA 30 Broad Street, Suite 702 New York, New York 10004 Phone: (646) 524-6026 Fax: (929) 210-7549 1 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: INDEX NO. 01/22/2019 61150 6/ 2018 |FILED NASSAU CO ITY CLERK 08/24/2018 01:01 PM| NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 DEFENDANT'S ADDRESS SYED MUJAHID SAYEED, D. 139 Plandome Road Manhasset, NY 11030 PRECISION SURGERY OF NEW YORK, P.C. 139 Plandome Road Manhasset, NY 11030 NORTH SHORE UNIVERSITY HOSPITAL 300 Community Dr Manhasset, NY 11030 NORTHWELL HEALTH 2000 Marcus Avenue New Hyde Park, NY 11042 2 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF INDEX NO. 01/22/2019 61150622018 LED : DOC. NARRAUNO.COUNTY 20 CLERK 0 8 /24 /2018 01:01 PM| RECEIVED NYSCEF: NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ---------------- -- ----- X DINO BONAVITA, Plaintift VERIFIED COMPLAINT -againsk Index No.: SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORT.H SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, Defendants. ____..___________________________________----------- X Plaintiffs, by their attorneys, CAITLIN ROBIN & ASSOCIATES, PLLC, as and for their Verified Complaint, alleges upon infonnation and belief as follows: 1. At all times hereinafter mentioned, Plaintiff, DINO BONAVITA, was and is a resident of 17 Sinclair Martin Drive, Roslyn, NY 11576. 2. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., was and stillis a duly licensed physician in the State of New York engaged in the practice of his profession in the County of Nassau, State of New York, with a principal place of business located at139 Plaiidailic Road, Manhasset, NY 11030. 3. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAH1D SAYEED, M.D., acted upon the scope as an agent, servant and/or employee of PRECISION SURGERY OF NEW YORK, P.C. to render medical evaluation, assessiiiciit, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 3 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF FILED: DOC. NASSAUNO. COUNTY 20 CLERK 08/_2422018 01:01 PM) RECEIVED NYSCEF: INDEX NO. 01/22/2019 6115Ò6/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 4. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID acted upon the scope as a principal SAYEED, M.D., member, shareholder and/orownerofthe Defendant PRECISION SURGERY OF NEW YORK, P.C., to render medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 5. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant and/or employee of Defendant NORTH SHORE UNIVERSITY HOSPITAL to render medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 6. That upon information and belief, at all times herein mentioned Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal, member, shareholder and/or owner of the Defendant NORTH SHORE UNIVERSITY HOSPITAL, to render medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 7. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as an agent, servant and/or employee of Defendant NORTHWELL HEALTH to render medical evaluation, assessment, diagnosis, care, treatment, services, testing, surgery and/or consultation to DINO BONAVITA. 8. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., acted upon the scope as a principal, member, shareholder and/or owner of the Defendant NORTHWELL HEALTH, to render 4 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF [FILED: DOC. NASSAUNO.COUNTY 20 CLERK 08/24/2018 01:01 RECEIVED INDEX NO. 01/22/2019 NYSCEF: 61150 6/2018 PM) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 medical evaluation, assessment, diagnoàis, care, treatment, servicest testing, surgery and/or consultation to DIN0 BONAVITA. 9c That Apon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., was and stillis a domestic professional corporation duly organized and existing under and by the laws of the State of New York with itsprinciple place of business located at 139 Plandome Road, Manhasset, NY 11030. 10. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., was and still is a foreign limited liability company existing under and by the laws of the State of New York with itspriiiciplc place of business located at 139 Plandome Road, Manhasset, NY 11030. 11. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., through itsagents, servants, employees and/or other medical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as a provider offering profesennal health care services to the members of the general public, including Plaintiff, DINO BONAVITA. 12. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., through its agents, servants, employees and/or other medical persoiisicl or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itselfout as duly qualified to render proper medical evaluation, assessment, diagiiusis, care, treatment, services, testing and/or consultation in accordance with good and 5 af 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF [FILED: DOC. NASSAUNO.COUNTY 20 CLERK 08724/2018 01:01 RECEIVED INDEX NO. 01/22/2019 NYSCEF: 611506/2018 PM) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 accepted standards of practice in the community to the members of the general public, including Plaintiff, DINO BONAVITA, 13. That upon information and at all times herein mentioned,. belief, Defendant, PRECISION SURGERY OF NEW YORK, P.C., owned, operated, maintained supervised, managed, and controlled certain medical facilities known as PRECISION SURGERY OF NEW YORK, P.C., where it employed such agents, servants and/or employees for the purpose of rending diagnosis, care, treatment, surgical services and advice to members of the general public, including Plaintiff, DINO BONAVITA. 14. That upon information and belief, at all times herein mentioned, Defendant PRECISION SURGERY OF NEW YORK, P.C., hired, engaged and/or otherwise took responsibility for the actions of healthcare professionals, staff and pasanuel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D. 15. That upon information and belief, at all times herein mentioned, Defendant, PRECISION SURGERY OF NEW YORK, P.C., is vicariously liable for the actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D. 16. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, was and still is a domestic professional corporation duly organized and existing under and by the laws of the State of New York with its principle place of business located at 300 Community Drive, Manhasset, NY 11030. 17. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, was and still is a foreign 6 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF [ILED: DOC. NASSAUNO.COUNTY 20 CLERK 08f24 2-0-18 01:01 RECEIVED INDEX NO. 01/22/2019 NYSCEF: 611506/2018 PM| NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 limited liability company eñsting under and by the lawa of the State of New York with itsprincijile pleâe of business located at 300 Community Drive, Manhasset, W NU30. 1& That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, through its agents, servants, employees and/or other medical personnel or other individuals acting under itsagency, supervision and control, including Defendant SYED MUJAHlD SAYEED, M.D., held itself out as a provider offering professional health care services to the members of the general public, including Plaintiff, DINO BONAVITA. 19. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, through its agents, servants, employees and/or other medical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as duly qualified to render proper medical evaluation, asse«ment, diagnosis, care, treatment, services, testing and/or consultation in accordance with good and accepted standards of practice in the community to the members of the general public, including Plaintiff,DINO BONAVITA. 20. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, owned, operated, maintained, supervised, managed, and controlled certain medical facilities known as NORTH SHORE UNIVERSITY HOSPITAL, where it employed such agents, servants and/or employees for the purpose of rending diagnosis, care, treatment, surgical services and advice to members of the general public, including Plaintiff, DINO BONAVITA. 7 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF FILED: DOC. NASSAUNO.COUNTY 20 CLERK 08/24/2018 01:01 RECEIVED INDEX NO. 01/22/2019 NYSCEF: 611506/2018 PM| NYSCEF DOC, NO. 1 RECEIVED NYSCEF: 08/24/2018 2L That upon inforntation and belief, at all times herein rnentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, hired, engaged and/or otherwise took responsibility for the actions of healthcare professionals, staff and personnel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D. 22. That upon information and belief, at all times herein mentioned, Defendant, NORTH SHORE UNIVERSITY HOSPITAL, is vicariously liable for the actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D. 23. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, was and still is a domestic professional corporation duly organized and existing under and by the laws of the State of New York . with itsprinciple place of business located at 2000 Marcus Avenue, New Hyde Park, NY 11042. 24. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, was and stillis a foreign limited liability company existing under and by the laws of the State of New York with its principle place of business located at 2000 Marcus Avenue, New Hyde Park, NY 11042. 25. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, through its agents, servants, employees and/or other medical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as a provider offering professional health care services to the members of the general public, including Plaintiff, DINO BONAVITA. 8 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF FILED : DOC. NAS NO.COUNTY SAU 20 CLERK 08724 20I8 01 RECEIVED INDEX NO. 01/22/2019 NYSCEF: 611506/2018 0ϯ¯_Pl_ NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 26. That upon information and belief, at all times herein meñtióned, Defendant, NOldBWER HEALTH, through its agents, servants, employees and/or other anedical personnel or other individuals acting under its agency, supervision and control, including Defendant SYED MUJAHID SAYEED, M.D., held itself out as duly qualified to render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance with good and accepted standards of practice in the community to the mcmbers of the general public, including Plaintiff, DINO BONAVITA. 27. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL owned, operated, maintained supervised, HEALTH, managed, and controlled certain medical facilities known as NORTHWELL HEALTH, where it employed such agents, servants and/or employees for the purpose of rending diagnosis, care, treatment, surgical services and advice to members of the general public, including Plaintiff, DINO BONAVITA. 28. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, hired, engaged and/or otherwise took responsibility for the actions of healthcare professionals, staff and personnel, including but not limited to Defendant SYED MUJAHID SAYEED, M.D. 29. That upon information and belief, at all times herein mentioned, Defendant, NORTHWELL HEALTH, is vicariously liable for the actions and/or omissions of the Defendant, SYED MUJAHID SAYEED, M.D. 30. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., held himself out as duly qualified to 9 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF FILED : DOC. NASSAUNO. COU 20 TY CLERK 08 /24 /2018 01: 01 PM) . RECEIVED NYSCEF: INDEX NO.01/22/2019 611506/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance with good and accepted standâ¾ds of practice in th# community to the members of the general public, including Plaintiff, DINO BONAVITA. 31. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., held himself out as a provider offering professional health care services to the members of the general public, including Plaintiff, DINO BONAVITA. 32. That upon information and belief, at all times herein mentioned, Defendant, SYED MUJAHID SAYEED, M.D., through its agents, servants, employees and/or other medical personnel or other individuals acting under his agency, supervision and control, held himself out as duly qualified to render proper medical evaluation, assessment, diagnosis, care, treatment, services, testing and/or consultation in accordance with good and accepted standards of practice in the community to the members of the general public, including Plaintiff, DINO BONAVITA. 33. That upon information and belief, at all times herein mentioned, Defend ant, SYED MUJAHID SAYEED, M.D., hired, engaged and/or otherwise took responsibility for the actions of healthcare professionals, staff and personnel, and had a duty to manage, control and otherwise supervise their work during the care, treatment and services of persons such as Plaintiff, DINO BONAVITA. 34. That upon information and belief, at all times herein mentioned, Defendants, PRECISION SURGERY OF NEW YORK, P.C. and SYED MUJAHID SAYEED, M.D. individually and by and through their agents, servants and/or employees agreed to, undertook to and did render certain medical evaluation, assessinent, diagnosis, 10 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF FILED: DOC. NASSAUNO.COUNTY 20 CLERK 68/24/201.8 01:01 RECEIVED INDEX NO. 01/22/2019 NYSCEF: 611506/2018 PM| NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 care, treatment, testing, and surgical services, and/or consultation to Plaintiff, DINO BONAVITA, beginning on or about July 21, 2017 through October 31, 2017. 3 That upon information and belief, at all tirnes herein rnentioned, Defendants, PRECISION SURGERY OLNEW YORK BYED MUlkH1D TE$ǾE individúan es rs$harehede a dingi 0 iQáfQehtinent, te nd surgica id/or con i ties D feh s NORTIRS) RE UNIVERSH OSPIT id SYED D 11 of 21 FILED: NASSAU COUNTY CLERK 01/22/2019 04:30 PM INDEX NO. 611506/2018 NYSCEF IFILED : DOC. NASSAUNO.COUNTY 20 CLERK 08/24/2018 01:01 Pli RECEIVED NYSCEF: INDEX NO. 01/22/2019 611506/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/24/2018 38. That upon information and belief, at call tunes herein mentioned, Defendants, NORTHWELL HEALTH and SYED MUJAHID SAYEED, M.D. individually and by and through their agents, servants and/or employees agreed to, undertook to and did render certain medical evaluation, assessment, diagnosis, care, treatment, testing, and surgical services, and/or consultation to Plaintiff, DINO BONAVITA, beginning on or about July 21, 2017 through October 31, 2017. 39. That upon information and belief,