Preview
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
--------- ----------------------------------------------------X
DINO BONAVITA,
Plaintiff,
-against-
POST-DEPOSITION
DEMANDS
Index No.:611506/2018
SYED MUJAHID SAYEED, M.D., PRECISION
SURGERY OF NEW YORK, P.C., NORTH SHORE
UNIVERSITY HOSPITAL, and NORTHWELL HEALTH,
Defendants.
X
PLEASE TAKE NOTICE, that Plaintiff DINO BONAVITA, by its attorneys Caitlin
Robin and Associates, PLLC hereby demands of Defendant SYED MUJAHID SAYEED, M.D.,
and PRECISION SURGERY OF NEW YORK, P.C. the following within twenty (20) days :
1. Screenshots of any and alltext messages between Dr. Sayeed and Dino Bonavita.
2. Copies of any discharge instructions provided to Dino Bonavita.
3. Copy of the April 10, 2018 letter from the insurance company referenced in Dr. Sayeed's
letter.
4. Copy of the dated letter response to the insurance company, a draft of which appears on
page 48 of Precision Surgery of New York P.C.'s Certified Records.
5. Names and employment status, and if no longer employed, lastknown address of all
billers and coders involved in the billing of Dino Bonavita's account.
6. Name and employment status, and if no longer employed, last known address of the
resident who took photographs that were made a part of the Precision Surgery of New
York P.C.'s Certified Records.
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021
7. Any and all emails sent from Dr. Sayeed and Precision Surgery of New York P.C. to Dr.
Greenberg.
8. Any and all emails sent from Dr. Sayeed and Precision Surgery of New York P.C. to any
radiologists who performed imaging of Dino Bonavita.
PLEASE TAIC FURTHER NOTICE that the foregoing are continuing demands and that
if any of the above items are obtained or come into the possession of the Defendant, their agents,
servants, employees and/or attorneys after the date of this demand, they are to be furnished
pursuant to this demand.
Dated: New York, New York
September 23, 2020
Yours, etc.,
Caitlin Robin, Esq.
CAITLIN ROBIN & ASSOCIATES PLLC
Attorneys for Plaintiff
30 Broad Street, Suite 702
New York, New York 10004
Phone: (646) 524-6026
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021
AFFIDAVIT OF SERVICE
STATE OF NEW YORK, COUNTY OF NEW YORK ss.:
Arjeta Albani 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 Kings York County in
the State of New York.
I served a true copy of the annexed
POST-DEPOSITION DEMANDS
On September 23, 2020
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:
Dorf & Nelson
555 Theodore Fremd Avenue
Rye, New York 10580
Rubin Paterniti Gonzalez & Kaufman
6th
555 Fifth Avenue, FlOOr
New York, New York 10017
A
Arjeta Albani
Sworn to before me September 23, 2020
Notary Public
KEVlN SCOTT VOLKOMMER
Notary State
Public, of NewYork
Reg. No. 02V06403337
Qualifiedin QueensCounty
Commission Expires01/21/2024
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021
Index No.: 611506/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
DINO BONAVITA,
Plaintiff,
-against-
SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH
SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH,
Defendants.
POST-DEPOSITION DEMANDS
Cainin Robin & Associates, PLLC
Attorneys for Plaintiffs
DINO BONAVITA
30 Broad Street, Suite 702
New York, NY 10004
(646) 524-6026
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
----- --------------------------------X
DINO BONAVITA,
Plaintiff,
POST-DEPOSITION
-against-
NOTICE FOR
DISCOVERY AND
INSPECTION
SYED MUJAHID SAYEED, M.D., PRECISION
SURGERY OF NEW YORK, P.C., NORTH SHORE
Index No.:611506/2018
UNIVERSITY HOSPITAL, and NORTHWELL HEALTH,
Defendants.
----------- ------------------- X
PLEASE TAKE NOTICE, that pursuant to CPLR § 3120, Defendant SYED MUJAHID
SAYEED, M.D., and PRECISION SURGERY OF NEW YORK, P.C. are hereby required to
produce, furnish and permit discovery by the Plaintiff, its attorneys, or someone acting on their
behalf, the following items or documents for inspection within thirty (30) days :
1. A copy of the native digital files,including system metadata, of the ten photographs taken
of Dino Bonavita at the time of his Emergency Room surgery.
PLEASE TAKE FURTHER NOTICE that the foregoing are continuing demands and that
if any of the above items are obtained or come into the possession of the Defendant, their agents,
servants, employees and/or attorneys after the date of this demand, they are to be furnished
pursuant to this demand.
Dated: New York, New York
September 23, 2020
Yours, etc.,
Caitlin Robin, Esq.
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021
Caitlin Robin, Esq.
CAITLIN ROBIN & ASSOCIATES PLLC
Attorneys for Plaintiffs
30 Broad Street, Suite 702
New York, New York 10004
Phone: (646) 524-6026
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021
AFFIDAVIT OF SERVICE
STATE OF NEW YORK, COUNTY OF NEW YORK ss.:
Arjeta Albani 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 Kings York County in
the State of New York.
I served a true copy of the annexed
POST-DEPOSITION NOTICE FOR DISCOVERY AND INSPECTION
On September 23, 2020
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:
Dorf & Nelson
555 Theodore Fremd Avenue
Rye, New York 10580
Rubin Paterniti Gonzalez & Kaufman
6"'
555 Fifth Avenue, Floor
New York, New York 10017
Arjeta Albani
Sworn to before me September 23, 2020
Notary Public
KEVIN SCOTT ygg
NotaryPuMig,
RegA
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021
Index No.: 611506/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
DINO BONAVITA,
Plaintiff,
-against-
SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH
SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH,
Defendants.
POST-DEPOSITION NOTICE FOR DISCOVERY AND INSPECTION
Caitlin Robin & Associates, PLLC
Attorneys for Plaintiffs
DINO BONAVITA
30 Broad Street, Suite 702
New York, NY 10004
(646) 524-6026
Preview
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU --------- ----------------------------------------------------X DINO BONAVITA, Plaintiff, -against- POST-DEPOSITION DEMANDS Index No.:611506/2018 SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, Defendants. X PLEASE TAKE NOTICE, that Plaintiff DINO BONAVITA, by its attorneys Caitlin Robin and Associates, PLLC hereby demands of Defendant SYED MUJAHID SAYEED, M.D., and PRECISION SURGERY OF NEW YORK, P.C. the following within twenty (20) days : 1. Screenshots of any and alltext messages between Dr. Sayeed and Dino Bonavita. 2. Copies of any discharge instructions provided to Dino Bonavita. 3. Copy of the April 10, 2018 letter from the insurance company referenced in Dr. Sayeed's letter. 4. Copy of the dated letter response to the insurance company, a draft of which appears on page 48 of Precision Surgery of New York P.C.'s Certified Records. 5. Names and employment status, and if no longer employed, lastknown address of all billers and coders involved in the billing of Dino Bonavita's account. 6. Name and employment status, and if no longer employed, last known address of the resident who took photographs that were made a part of the Precision Surgery of New York P.C.'s Certified Records. FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021 7. Any and all emails sent from Dr. Sayeed and Precision Surgery of New York P.C. to Dr. Greenberg. 8. Any and all emails sent from Dr. Sayeed and Precision Surgery of New York P.C. to any radiologists who performed imaging of Dino Bonavita. PLEASE TAIC FURTHER NOTICE that the foregoing are continuing demands and that if any of the above items are obtained or come into the possession of the Defendant, their agents, servants, employees and/or attorneys after the date of this demand, they are to be furnished pursuant to this demand. Dated: New York, New York September 23, 2020 Yours, etc., Caitlin Robin, Esq. CAITLIN ROBIN & ASSOCIATES PLLC Attorneys for Plaintiff 30 Broad Street, Suite 702 New York, New York 10004 Phone: (646) 524-6026 FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021 AFFIDAVIT OF SERVICE STATE OF NEW YORK, COUNTY OF NEW YORK ss.: Arjeta Albani 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 Kings York County in the State of New York. I served a true copy of the annexed POST-DEPOSITION DEMANDS On September 23, 2020 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: Dorf & Nelson 555 Theodore Fremd Avenue Rye, New York 10580 Rubin Paterniti Gonzalez & Kaufman 6th 555 Fifth Avenue, FlOOr New York, New York 10017 A Arjeta Albani Sworn to before me September 23, 2020 Notary Public KEVlN SCOTT VOLKOMMER Notary State Public, of NewYork Reg. No. 02V06403337 Qualifiedin QueensCounty Commission Expires01/21/2024 FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021 Index No.: 611506/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU DINO BONAVITA, Plaintiff, -against- SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, Defendants. POST-DEPOSITION DEMANDS Cainin Robin & Associates, PLLC Attorneys for Plaintiffs DINO BONAVITA 30 Broad Street, Suite 702 New York, NY 10004 (646) 524-6026 FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ----- --------------------------------X DINO BONAVITA, Plaintiff, POST-DEPOSITION -against- NOTICE FOR DISCOVERY AND INSPECTION SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH SHORE Index No.:611506/2018 UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, Defendants. ----------- ------------------- X PLEASE TAKE NOTICE, that pursuant to CPLR § 3120, Defendant SYED MUJAHID SAYEED, M.D., and PRECISION SURGERY OF NEW YORK, P.C. are hereby required to produce, furnish and permit discovery by the Plaintiff, its attorneys, or someone acting on their behalf, the following items or documents for inspection within thirty (30) days : 1. A copy of the native digital files,including system metadata, of the ten photographs taken of Dino Bonavita at the time of his Emergency Room surgery. PLEASE TAKE FURTHER NOTICE that the foregoing are continuing demands and that if any of the above items are obtained or come into the possession of the Defendant, their agents, servants, employees and/or attorneys after the date of this demand, they are to be furnished pursuant to this demand. Dated: New York, New York September 23, 2020 Yours, etc., Caitlin Robin, Esq. FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021 Caitlin Robin, Esq. CAITLIN ROBIN & ASSOCIATES PLLC Attorneys for Plaintiffs 30 Broad Street, Suite 702 New York, New York 10004 Phone: (646) 524-6026 FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021 AFFIDAVIT OF SERVICE STATE OF NEW YORK, COUNTY OF NEW YORK ss.: Arjeta Albani 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 Kings York County in the State of New York. I served a true copy of the annexed POST-DEPOSITION NOTICE FOR DISCOVERY AND INSPECTION On September 23, 2020 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: Dorf & Nelson 555 Theodore Fremd Avenue Rye, New York 10580 Rubin Paterniti Gonzalez & Kaufman 6"' 555 Fifth Avenue, Floor New York, New York 10017 Arjeta Albani Sworn to before me September 23, 2020 Notary Public KEVIN SCOTT ygg NotaryPuMig, RegA FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/20/2021 Index No.: 611506/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU DINO BONAVITA, Plaintiff, -against- SYED MUJAHID SAYEED, M.D., PRECISION SURGERY OF NEW YORK, P.C., NORTH SHORE UNIVERSITY HOSPITAL, and NORTHWELL HEALTH, Defendants. POST-DEPOSITION NOTICE FOR DISCOVERY AND INSPECTION Caitlin Robin & Associates, PLLC Attorneys for Plaintiffs DINO BONAVITA 30 Broad Street, Suite 702 New York, NY 10004 (646) 524-6026