Preview
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021
EXHIBIT K
{DN Exhibit Z - Copy.docx;! }
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021
DOR.F & NELSONllp
The International Corporate Center, 555 Theodore Fremd Avenue, Rye, NY 1 0580
Telephone: 914.381.7600 www.dorflaw.com • Facsimile: 914.967.1765
MELISSA G. ANDRIEUX, ESQ.
SENIORASSOCIATE
DIRECT DIAL: (914) 607-5927
E-MAIL: mandrieux@dorflaw.com
January 29, 2020
Via Facsimile (929) 210-7549 & First-Class Mail
Caitlin Robin & Associates, PLLC
30 Broad Street, Suite 702
New York, New York 10004
Atta. :Caitlin Robin, Esq.
Re: Bonavita v. Sayeed, et. al.
D&NFile#: 017-2118/19
Dear Ms. Robin:
We represent Dr. Syed M. Sayeed and Precision Surgery of New York, P.C. in the above-noted
matter.
Please allow this correspondence to memorialize the discovery that remains outstanding in this
matter.
1. We received a response from MagnaCare wherein the authorization you provided
was rejected. A copy of the rejection letter is enclosed for your review. In
following the directives of MagnaCare, kindly provide anew authorization which
authorizes the release of records to Choice Legal, which is the document retrieval
company that our office is using to secure records. Also, kindly ensure that section
9(a) of the authorization is duly initialed and completed.
2. With respect to plaintiff’s rejection to providing authorizations for Gail Diamond,
Eun Ryang Jang, Amanda Pero and Kevin Basile because their addresses cannot be
located, please note that these providers are listed in the plaintiff’s Greenvale
Pharmacy records. If plaintiff is unaware of the addresses of these providers,
provide the authorizations and we will investigate their addresses and send the
authorizations.
Manhattan | Westchester | Garden City | Los Angeles
{DN 00091512. DOCXjl )
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021
DO&ON
3. We received a response from Southern Glazer Wine & Spirits wherein the
authorization you provided was rejected. A copy of the rejection letter is enclosed
for your review. Per the directives of Southern Glazer please provide a new
authorization that will allow release of the plaintiff’s employment records to Dorf
and Nelson, LLP and Choice Legal, and a new Power of Attorney for release of the
employment records to Dorf and Nelson, LLP and Choice Legal.
4. Lastly, we have not received a response to our June 24, 2019 Demand for Physical
Examination pursuant to 22 NYCRR §§ 202.17 and 208.13 and CPLR §3121(b).
As you are no doubt aware, Hamilton v. Miller, 23 N.Y. 3d 592 (2014) states that
section 202.17 (b) obligates the plaintiff to obtain reports that include a recital of
what trial testimony the plaintiff will offer as to the injuries and conditions of the
plaintiff, including diagnosis and prognosis. The Court of Appeals has further
stated that the rule requires plaintiff to obtain the information from examining
physicians and treating physicians whether or not the information is contained in
existing reports. If the records of the treating and examining physicians do not
include the information on the injuries and conditions, their diagnosis and
prognosis, the plaintiffs must have the medical providers draft reports setting forth
that information. As such, kindly provide a response to this demand.
Please consider this a good faith effort to resolve these discovery issues without the need for
motion practice.
We thank you for your anticipated cooperation with regards to this matter.
Very truly yours,
Melissa G. Andrieux
Enclosures
cc: Via Facsimile: (516) 350-5579 & First-Class Mail
Rubin Patemiti Gonzalez Kaufman
1225 Franklin Avenue, Suite 200
Garden City, New York 11530
Attn: Nicole Klein, Esq.
Phone: 914.381.7600 www.dorflaw.com Fax: 914.967.1765
2
{DN 00091512. DOCX;1 }
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021
MAGNACARE'
August 19, 2019
Choice Legal
PO Box 1215
Tampa, Horida 33601
Re: Dino Bonavita
SS#: XXX-XX-2289
In response to your record request, MagnaCare requires the following:
• A release/authorization from the patient/member authorizing the release to Choice
Legal, The authorization provided indicates the release to Dorf & Nelson, LLP. We may
also release the requested documents to the attorney directly; and
• Further clarification is needed as to Paragraph 9(a) of the HIPAA authorization form.
Please be sure to check all the necessary boxes and indicate if worker’s comp related,
please do notindicate claim/identification numbers or date/type of accident in your
request. MagnaCare is not a health care provider and is unable to provide HIPAA
protected documents based on an authorization that is limited. MagnaCare is not an
insurance company. In responding to the request we are not in anyway acknowledging
that MagnaCare is an insurance company.
We apologize for the inconvenience.
Very truly yours,
Victims Lm/
Victoria Lai, Corporate Paralegal
Legal Department
Please submit allfuture requests to recordrequests@maqnacare.com
1
| |
800.235.7267www.magnacare.com
2421 Atlantic Avenue, Ste 202, Wall Township, New Jersey 08736
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021
JACQUELYN ROGERS
Paralegal -Litigation, Labor & Employment
Southern Glazer’s Wine and Spirits
14911 Quorum Dr., Suite 150
Dallas, TX 75254
Office: 972.392.8384
IM
jacquelyn.rogers@sgws.com
December 23, 2019
VIA EMAIL
Choice Legal
9204 King Palm Drive
Tampa, FL 33619
records@choicelegal.com
RE; Request for Records Regarding Dino Bonavita
Dear Sir or Madam:
This letter is in response to your correspondence directed to “Southern Glazer Wine & Spirits”
seeking records pertaining to Dino Bonavita. Mr. Bonavita’s employer, Southern Glazer’s Wine and
Spirits of New York, LLC (misidentified in your request), is owned by Southern Glazer’s Wine and
Spirits, LLC (“SGWS” or the “Company”).
SGWS cannot provide the records requested in your letter. SGWS owns all employee records,
and it is the policy of SGWS not to release personnel or employment records without a subpoena or court
order, notwithstanding the provision of an authorization for release of those records by the employee
whose records are sought. Moreover, the authorization enclosed with your request is for the release of
health information pursuant to HIPAA, but purports to authorize the release of employment records as
a type of health information to be disclosed under the form. Likewise, the enclosed power of attorney
references only the HIPAA medical authorization, but makes no reference to release of employment
records. Further, neither the power of attorney nor the authorization provide for the release of records
to either DOPF, P.C. or Choice Legal. For those and other reasons, SGWS does not consider the
authorization form valid for the release of employment or personnel records, even setting aside the
Company’s policy not to release such records without a subpoena or court order.
If you would like to serve a subpoena for Mr. Bonavita’s records, any valid subpoena may be
sent to my attention at the address above.
If you have any questions, please feel free to contact me,
Sincerely,
Jacquelyn Rogers
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021
The International Corporate Center
555 Theodore Fremd Avenue, Suite C-201
Rye, New York 10580 DORF& NELSON LLP
Telephone: (914) 381-7600
Fax.: (914)967-1765
Fax
To: Caitlin Robin, Esq. From: Melissa G. Andrieux, Esq.
Caitlin Robin & Associates, PLLC
Fax: 929.210.7549 Pages: 5 - including cover page
Date: 1.29.20 Cc: Nicole Klein, Esq.
Rubin Patemiti Gonzalez Kaufman
Re: Bonavita v. Sayeed, et. al. Fax: 516.350.5579
D&NFile#: 017-2118/19
Urgent For Review Please Comment Please Reply Please Recycle
• Comments:
With regard to the above-noted matter, please see attached.
This message is intended only for the use ofthe individual or entity to which it is addressed, and may contain information that is
PRIVILEGED, CONFIDENTIAL and exempt from disclosure under applicable law. If the reader of this message is not the
intended recipient or the employee or agent responsible for delivering the message to the intended recipient you are hereby
notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this
communication in error, please notify us immediately by telephone, andretum the original to us by mail without making a copy.
Tharikyou.
{DN 00091704.DQC;1 }
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021
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FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021
p. 1 1
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Preview
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021 EXHIBIT K {DN Exhibit Z - Copy.docx;! } FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021 DOR.F & NELSONllp The International Corporate Center, 555 Theodore Fremd Avenue, Rye, NY 1 0580 Telephone: 914.381.7600 www.dorflaw.com • Facsimile: 914.967.1765 MELISSA G. ANDRIEUX, ESQ. SENIORASSOCIATE DIRECT DIAL: (914) 607-5927 E-MAIL: mandrieux@dorflaw.com January 29, 2020 Via Facsimile (929) 210-7549 & First-Class Mail Caitlin Robin & Associates, PLLC 30 Broad Street, Suite 702 New York, New York 10004 Atta. :Caitlin Robin, Esq. Re: Bonavita v. Sayeed, et. al. D&NFile#: 017-2118/19 Dear Ms. Robin: We represent Dr. Syed M. Sayeed and Precision Surgery of New York, P.C. in the above-noted matter. Please allow this correspondence to memorialize the discovery that remains outstanding in this matter. 1. We received a response from MagnaCare wherein the authorization you provided was rejected. A copy of the rejection letter is enclosed for your review. In following the directives of MagnaCare, kindly provide anew authorization which authorizes the release of records to Choice Legal, which is the document retrieval company that our office is using to secure records. Also, kindly ensure that section 9(a) of the authorization is duly initialed and completed. 2. With respect to plaintiff’s rejection to providing authorizations for Gail Diamond, Eun Ryang Jang, Amanda Pero and Kevin Basile because their addresses cannot be located, please note that these providers are listed in the plaintiff’s Greenvale Pharmacy records. If plaintiff is unaware of the addresses of these providers, provide the authorizations and we will investigate their addresses and send the authorizations. Manhattan | Westchester | Garden City | Los Angeles {DN 00091512. DOCXjl ) FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021 DO&ON 3. We received a response from Southern Glazer Wine & Spirits wherein the authorization you provided was rejected. A copy of the rejection letter is enclosed for your review. Per the directives of Southern Glazer please provide a new authorization that will allow release of the plaintiff’s employment records to Dorf and Nelson, LLP and Choice Legal, and a new Power of Attorney for release of the employment records to Dorf and Nelson, LLP and Choice Legal. 4. Lastly, we have not received a response to our June 24, 2019 Demand for Physical Examination pursuant to 22 NYCRR §§ 202.17 and 208.13 and CPLR §3121(b). As you are no doubt aware, Hamilton v. Miller, 23 N.Y. 3d 592 (2014) states that section 202.17 (b) obligates the plaintiff to obtain reports that include a recital of what trial testimony the plaintiff will offer as to the injuries and conditions of the plaintiff, including diagnosis and prognosis. The Court of Appeals has further stated that the rule requires plaintiff to obtain the information from examining physicians and treating physicians whether or not the information is contained in existing reports. If the records of the treating and examining physicians do not include the information on the injuries and conditions, their diagnosis and prognosis, the plaintiffs must have the medical providers draft reports setting forth that information. As such, kindly provide a response to this demand. Please consider this a good faith effort to resolve these discovery issues without the need for motion practice. We thank you for your anticipated cooperation with regards to this matter. Very truly yours, Melissa G. Andrieux Enclosures cc: Via Facsimile: (516) 350-5579 & First-Class Mail Rubin Patemiti Gonzalez Kaufman 1225 Franklin Avenue, Suite 200 Garden City, New York 11530 Attn: Nicole Klein, Esq. Phone: 914.381.7600 www.dorflaw.com Fax: 914.967.1765 2 {DN 00091512. DOCX;1 } FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021 MAGNACARE' August 19, 2019 Choice Legal PO Box 1215 Tampa, Horida 33601 Re: Dino Bonavita SS#: XXX-XX-2289 In response to your record request, MagnaCare requires the following: • A release/authorization from the patient/member authorizing the release to Choice Legal, The authorization provided indicates the release to Dorf & Nelson, LLP. We may also release the requested documents to the attorney directly; and • Further clarification is needed as to Paragraph 9(a) of the HIPAA authorization form. Please be sure to check all the necessary boxes and indicate if worker’s comp related, please do notindicate claim/identification numbers or date/type of accident in your request. MagnaCare is not a health care provider and is unable to provide HIPAA protected documents based on an authorization that is limited. MagnaCare is not an insurance company. In responding to the request we are not in anyway acknowledging that MagnaCare is an insurance company. We apologize for the inconvenience. Very truly yours, Victims Lm/ Victoria Lai, Corporate Paralegal Legal Department Please submit allfuture requests to recordrequests@maqnacare.com 1 | | 800.235.7267www.magnacare.com 2421 Atlantic Avenue, Ste 202, Wall Township, New Jersey 08736 FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021 JACQUELYN ROGERS Paralegal -Litigation, Labor & Employment Southern Glazer’s Wine and Spirits 14911 Quorum Dr., Suite 150 Dallas, TX 75254 Office: 972.392.8384 IM jacquelyn.rogers@sgws.com December 23, 2019 VIA EMAIL Choice Legal 9204 King Palm Drive Tampa, FL 33619 records@choicelegal.com RE; Request for Records Regarding Dino Bonavita Dear Sir or Madam: This letter is in response to your correspondence directed to “Southern Glazer Wine & Spirits” seeking records pertaining to Dino Bonavita. Mr. Bonavita’s employer, Southern Glazer’s Wine and Spirits of New York, LLC (misidentified in your request), is owned by Southern Glazer’s Wine and Spirits, LLC (“SGWS” or the “Company”). SGWS cannot provide the records requested in your letter. SGWS owns all employee records, and it is the policy of SGWS not to release personnel or employment records without a subpoena or court order, notwithstanding the provision of an authorization for release of those records by the employee whose records are sought. Moreover, the authorization enclosed with your request is for the release of health information pursuant to HIPAA, but purports to authorize the release of employment records as a type of health information to be disclosed under the form. Likewise, the enclosed power of attorney references only the HIPAA medical authorization, but makes no reference to release of employment records. Further, neither the power of attorney nor the authorization provide for the release of records to either DOPF, P.C. or Choice Legal. For those and other reasons, SGWS does not consider the authorization form valid for the release of employment or personnel records, even setting aside the Company’s policy not to release such records without a subpoena or court order. If you would like to serve a subpoena for Mr. Bonavita’s records, any valid subpoena may be sent to my attention at the address above. If you have any questions, please feel free to contact me, Sincerely, Jacquelyn Rogers FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021 The International Corporate Center 555 Theodore Fremd Avenue, Suite C-201 Rye, New York 10580 DORF& NELSON LLP Telephone: (914) 381-7600 Fax.: (914)967-1765 Fax To: Caitlin Robin, Esq. From: Melissa G. Andrieux, Esq. Caitlin Robin & Associates, PLLC Fax: 929.210.7549 Pages: 5 - including cover page Date: 1.29.20 Cc: Nicole Klein, Esq. Rubin Patemiti Gonzalez Kaufman Re: Bonavita v. Sayeed, et. al. Fax: 516.350.5579 D&NFile#: 017-2118/19 Urgent For Review Please Comment Please Reply Please Recycle • Comments: With regard to the above-noted matter, please see attached. This message is intended only for the use ofthe individual or entity to which it is addressed, and may contain information that is PRIVILEGED, CONFIDENTIAL and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone, andretum the original to us by mail without making a copy. Tharikyou. {DN 00091704.DQC;1 } FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021 p. 1 t I Communication Result Report ( Jan. 29. 2020 5:06PM) * * 2 i Date/Time: Jan. 29. 2020 5:04PM File Page No. Mode Destination Pg (s) Result Not Sent 2534 Memory TX 819292107549 P. 5 OK 1 Reason for error 1) Hang up or line fa i 1 E.2, Busy E‘3 No answer E.4, No fac s I m I 1 e connect I on E.5 Exceeded max. E-ma 1 1size E.6. Destlnatlos n does not support IP-Fax IhtletamdMriCbipoNMOatW SSiTitBiato'etlmtAmw^SliR* 0-201 Xy^ewYckJOnO DORI- & NELSON I I..F Wtaue(»U]3ll.7tte itKWyrtT'TMs Fax To: CaidlaRobbuBsq. ifrowi MfilkjaG.Andriaix^Es^. didafaltoMn Associates, H1C Ta: 929210/7549 Pigesj 5-ifldudihgnavtrjagc Drto: 1.2920 Cd Nlcolc Klein, Esq. RiibiitBaiettiiti GanzalezKauftmm Ro: ‘itaj W50.5379 Bcaavitn y. Snyeed, M, al, D&NTiloflt 017-2118/19 ParRrvW nnaaoCDruwtr HumlUpfy • OonuntnSK WMnegmtl to tUabOT^dtedmaUo; jilMM bm sitatfiEd. MlgslltU tended «s4itotf, arfa aylope 6«»*fMi«p6niMo^ Wv«ir«ltoJnaa|aWlIieintadd ,yr*lrtK,_, SMEMIliUny aam&uKorv dMtetteneCKjijiutflftHl annnudco&nii tfAty wmMHayt, , Ww itvaieotadfUi flit 4aroutteKNitoem>;s!<^°"^uifa!inMM^l¥td^^adn4Un(lieorfginiJto'tMto’aulL'wlttnitnuUi>£ftCcft>' I to tu tyflulhvlfautnuHiigtiajv. WOOWtTMDOO.Hj FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 11/05/2021 p. 1 1 x x Communication Result Report ( Jan, 29. 2020 5:09PM ) * x 1 2 Date/Time: Jan,29, 2020 5:07PM File Page No. Mode Destination Pg (s) Result Not Sent 2535 Memory TX 815163505579 P, 5 OK I i ! Reasonn for error E. 1) Hang up or line fall E,2, Busy E.3) No answer E,4. No facsimile connect I o n E,5 Exceeded max. E-ma i 1size E. 6. 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