Preview
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021
EXHIBIT A
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021
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
IndexNo.: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 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021
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 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021
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
TION
POST-DEPOSITION NOTICE FOR DISCOVERY AND INSPEC
On September 23, 2020
in a sealed envelope, with postage prepaid thereon, in a post office or
by mailing the same
York, addressed to the last
official depository of the U.S. Postal Service within the State of New
known address of the addressee as indicated below:
Dorf & Nelson
555 Theodore Fremd Avenue
Rye, New York 10580
Rubin Patemiti Gonzalez & Kaufman
555 Fifth Avenue, 6th Floor
New York, New York 10017
Arjeta Albani
Sworn to before me September 23, 2020
——
Notary Public
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021
IndexNo.: 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 NORTHW ELL 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 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021 EXHIBIT A FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021 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 IndexNo.: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 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021 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 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021 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 TION POST-DEPOSITION NOTICE FOR DISCOVERY AND INSPEC On September 23, 2020 in a sealed envelope, with postage prepaid thereon, in a post office or by mailing the same York, addressed to the last official depository of the U.S. Postal Service within the State of New known address of the addressee as indicated below: Dorf & Nelson 555 Theodore Fremd Avenue Rye, New York 10580 Rubin Patemiti Gonzalez & Kaufman 555 Fifth Avenue, 6th Floor New York, New York 10017 Arjeta Albani Sworn to before me September 23, 2020 —— Notary Public FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 11/05/2021 IndexNo.: 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 NORTHW ELL 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