Preview
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 08/20/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
------------------------------X
DINO BONAVITA,
Plaintiff, PARTIAL RESPONSE TO
PLAINTIFF'S
POST DEPOSITION
DEMANDS
-against-
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
COUNSELORS:
PLEASE TAKE NOTICE, that defendants SYED MUJAHID SAYEED, M.D. and
PRECISION SURGERY OF NEW YORK, P.C., by their attorneys DORF & NELSON LLP, 555
Theodore Fremd Avenue, Rye, New York 10580, hereby partially respond to Plaintiff's Combined
Demands as follows:
1. Screenshots of any and all text messages between Dr. Sayeed and Dino
Bonavita: The responding Defendants have made a search and are not in
possession of any text messages between Dr. Sayeed and Dino Bonavita.
2. Copies of any discharge instructions provided to Dino Bonavita: The
responding Defendants are unaware of the existence of any discharge
instructions other than what is contained in Plaintiff's medical records.
3. Copy of the April 10, 2018 letter from the insurance company referenced in
Dr. Sayeed's letter: The Responding Defendants are making a search for this
information and to the extent it exists, will be supplied under separate cover.
4. Copy of 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: The responding Defendants have made a search and are unaware of
{DN 00140696.DOCX;1 }
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 08/20/2021
the existence of any letter other than the undated letter contained in Plaintiff's
medical records.
5. Names and employment status, and if no longer employed, last known
address of all billers and coders involved in the billing of Dino Bonavita's
account: The responding Defendants are making a search for this information
and, to the extent it exists, will be provided under separate cover.
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: The responding
Defendants are unaware of the name and employment status of the resident who
took photographs that were made a part of the Precision Surgery of New York
P.C.'s Certified Records. Further, the responding defendants are not in
possession of the native digital files, including system metadata of the ten
photographs taken of Dino Bonavita at the time of his Emergency Room surgery.
7. Any and all emails sent from Dr. Sayeed and Precision Surgery of New York
P.C. to Dr. Greenberg. The responding defendants are making a search for this
information and, to the extent it exists, will be provided under separate cover.
8. Any and all emails sent from Dr. Sayeed and Precision surgery of New York
P.C. to any radiologist who preformed imaging of Dino Bonavita. The
responding defendants are making a search for this information and, to the extent
it exists, will be provided under separate cover.
PLEASE TAKE NOTICE that defendants reserve the right to modify, chañge, amend or
supplement this response at any time up to and including the time of trial.
Dated: Rye, New York
November 10, 2020
Yours, etc.
DORF & NELSON LLP
By: .
Clare McKenna
Attorneys for Defendan s
SYED MUJAHID SAYEED, M.D.
and PRECISION SURGERY OF
NEW YORK, P.C.
{DN 00140696.DOCX;1 }
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 08/20/2021
The International Corporate Center
555 Theodore Fremd Avenue
Rye, New York 10580
(914) 381-7600
TO:
CAITLIN ROBIN & ASSOCIATES, PLLC
Attorneys for Plaintiff
30 Broad Street, Suite 702
New York, New York 10004
(646) 524-6026
Attn. : Arjeta Albani, Esq.
RUBIN PATERNITI GONZALEZ KAUFMAN
1225 Franklin Avenue, Suite 200
Garden City, New York 11530
(516) 344-6376
Attn. : Monica Ward, Esq.
Attn. : Nicole Klein, Esq.
{DN 00140696.DOCX;1 }
Preview
FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 08/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ------------------------------X DINO BONAVITA, Plaintiff, PARTIAL RESPONSE TO PLAINTIFF'S POST DEPOSITION DEMANDS -against- 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 COUNSELORS: PLEASE TAKE NOTICE, that defendants SYED MUJAHID SAYEED, M.D. and PRECISION SURGERY OF NEW YORK, P.C., by their attorneys DORF & NELSON LLP, 555 Theodore Fremd Avenue, Rye, New York 10580, hereby partially respond to Plaintiff's Combined Demands as follows: 1. Screenshots of any and all text messages between Dr. Sayeed and Dino Bonavita: The responding Defendants have made a search and are not in possession of any text messages between Dr. Sayeed and Dino Bonavita. 2. Copies of any discharge instructions provided to Dino Bonavita: The responding Defendants are unaware of the existence of any discharge instructions other than what is contained in Plaintiff's medical records. 3. Copy of the April 10, 2018 letter from the insurance company referenced in Dr. Sayeed's letter: The Responding Defendants are making a search for this information and to the extent it exists, will be supplied under separate cover. 4. Copy of 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: The responding Defendants have made a search and are unaware of {DN 00140696.DOCX;1 } FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 08/20/2021 the existence of any letter other than the undated letter contained in Plaintiff's medical records. 5. Names and employment status, and if no longer employed, last known address of all billers and coders involved in the billing of Dino Bonavita's account: The responding Defendants are making a search for this information and, to the extent it exists, will be provided under separate cover. 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: The responding Defendants are unaware of the name and employment status of the resident who took photographs that were made a part of the Precision Surgery of New York P.C.'s Certified Records. Further, the responding defendants are not in possession of the native digital files, including system metadata of the ten photographs taken of Dino Bonavita at the time of his Emergency Room surgery. 7. Any and all emails sent from Dr. Sayeed and Precision Surgery of New York P.C. to Dr. Greenberg. The responding defendants are making a search for this information and, to the extent it exists, will be provided under separate cover. 8. Any and all emails sent from Dr. Sayeed and Precision surgery of New York P.C. to any radiologist who preformed imaging of Dino Bonavita. The responding defendants are making a search for this information and, to the extent it exists, will be provided under separate cover. PLEASE TAKE NOTICE that defendants reserve the right to modify, chañge, amend or supplement this response at any time up to and including the time of trial. Dated: Rye, New York November 10, 2020 Yours, etc. DORF & NELSON LLP By: . Clare McKenna Attorneys for Defendan s SYED MUJAHID SAYEED, M.D. and PRECISION SURGERY OF NEW YORK, P.C. {DN 00140696.DOCX;1 } FILED: NASSAU COUNTY CLERK 08/20/2021 03:36 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 08/20/2021 The International Corporate Center 555 Theodore Fremd Avenue Rye, New York 10580 (914) 381-7600 TO: CAITLIN ROBIN & ASSOCIATES, PLLC Attorneys for Plaintiff 30 Broad Street, Suite 702 New York, New York 10004 (646) 524-6026 Attn. : Arjeta Albani, Esq. RUBIN PATERNITI GONZALEZ KAUFMAN 1225 Franklin Avenue, Suite 200 Garden City, New York 11530 (516) 344-6376 Attn. : Monica Ward, Esq. Attn. : Nicole Klein, Esq. {DN 00140696.DOCX;1 }