On August 24, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Dino Bonavita,
and
North Shore University Hospital,
Northwell Health,
Precision Surgery Of New York, Pc,
Syed Mujahid Sayeed Md,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Nassau County.
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FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 11/05/2021
EXHIBIT M
FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018
NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 11/05/2021
DOKF & NELSONllp
The International Corporate Center, 555 Theodore Fremd Avenue, Rye, NY 1 0580
Telephone: 914.381.7600 • www.dorflaw.com Facsimile: 914.967.1765
DEBORAH A. DYCKMAN, ESQ.
COUNSEL
DIRECT DIAL: (914) 607-5935
E-MAIL: ddvckman@dorflaw.com
June 14, 2021
Via E-Mail: arieta@robinandassociates.com and First-Class Mail
Caitlin Robin & Associates, PLLC
30 Broad Street, Suite 702
New York, New York 10004
Attn.: Arjeta Albani, Esq.
Re: Bonavita v. Sayeed, et. al.
Index#: 611506/2018
D&NFile#: 017-2118/19
Dear Ms. Albani:
I am writing to follow-up with regard to our June 24, 2019 demand for physical examination
discovery. We sent a follow up letter and you responded via letter dated February 8, 2021 that you
had not yet had your client examined. I am writing to inquire as to whether you have had your
client examined up to the present time and if so I would ask that you please provide us with the
reports. We need to determine whether we need to have your client examined or not, so I would
appreciate your prompt response. Copies of our prior demand and correspondence are annexed
hereto.
Thank you for your attention to this matter.
Very truly yours,
Deborah A. Dyckman
Enclosures
cc: Via E-Mail: Klein@rpgrklaw.com and First-Class Mail
Rubin Patemiti Gonzalez Rizzo Kaufman LLP
1225 Franklin Avenue, Suite 200
Garden City, New York 11530
Attn.: Nicole Klein, Esq.
Manhattan | Westchester | Garden City | Los Angeles
{DN 00159634. DOCX;1 }
Document Filed Date
November 05, 2021
Case Filing Date
August 24, 2018
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 11/05/2021 EXHIBIT M FILED: NASSAU COUNTY CLERK 11/05/2021 01:12 PM INDEX NO. 611506/2018 NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 11/05/2021 DOKF & NELSONllp The International Corporate Center, 555 Theodore Fremd Avenue, Rye, NY 1 0580 Telephone: 914.381.7600 • www.dorflaw.com Facsimile: 914.967.1765 DEBORAH A. DYCKMAN, ESQ. COUNSEL DIRECT DIAL: (914) 607-5935 E-MAIL: ddvckman@dorflaw.com June 14, 2021 Via E-Mail: arieta@robinandassociates.com and First-Class Mail Caitlin Robin & Associates, PLLC 30 Broad Street, Suite 702 New York, New York 10004 Attn.: Arjeta Albani, Esq. Re: Bonavita v. Sayeed, et. al. Index#: 611506/2018 D&NFile#: 017-2118/19 Dear Ms. Albani: I am writing to follow-up with regard to our June 24, 2019 demand for physical examination discovery. We sent a follow up letter and you responded via letter dated February 8, 2021 that you had not yet had your client examined. I am writing to inquire as to whether you have had your client examined up to the present time and if so I would ask that you please provide us with the reports. We need to determine whether we need to have your client examined or not, so I would appreciate your prompt response. Copies of our prior demand and correspondence are annexed hereto. Thank you for your attention to this matter. Very truly yours, Deborah A. Dyckman Enclosures cc: Via E-Mail: Klein@rpgrklaw.com and First-Class Mail Rubin Patemiti Gonzalez Rizzo Kaufman LLP 1225 Franklin Avenue, Suite 200 Garden City, New York 11530 Attn.: Nicole Klein, Esq. Manhattan | Westchester | Garden City | Los Angeles {DN 00159634. DOCX;1 }