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Alphaus A Williams , v. Carina Biggs , M.D., Sara Kim , M.D., The Law Offices Of Goldfarb & Gerzog, The Law Offices Of Steven M. Goldfarb, Ira D. Gerzog , Esq., Steven M. Goldfarb , Esq., Mcaloon & Friedman, P.C., Laura R. Shapiro , Esq., Li…

On March 20, 2020 a torts - other (tort) case was filed by (Subcribe to view) represented by (Subcribe to view) against (Subscribe to view) represented by (Subscribe to view) in the jurisdiction of Kings County. Judge Richard Montelione presiding.

Case Details

Case Number

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Filing Date

March 20, 2020

Last Refreshed

October 10, 2023

Filing Location

Kings County, NY

Filing Court House

Kings County Supreme Court

OTHER JUDGES ON THIS CASE

Francois A. Rivera;

Judge

Hon. Richard Montelione Trellis Spinner 👉 Discover key insights by exploring more analytics for Richard Montelione   

Category

Torts - Other (TORT)

Practice Area

Torts

Matter Type

General Torts

OTHER JUDGES ON THIS CASE

Overview

false at their client’s depositions, to wit, M&F proffered/produced/introduced a known

forged FORM B-1, entitled “INFORMED CONSENT FOR INVASIVE, DIAGNOSTIC,

MEDICAL & SURGICAL PROCEDURES” that was manufactured and fabricated by te

underlying Defendants purporting that SARA KIM’S M.D. had conversations with

Plaintiff to reinforcement their defense after the 50H hearing and examination before trial

of Plaintiff to defeat a claim of lack of informed consent and/or diminish damages.

On information and belief, it appears M&F believed that a jury would

CARINA BIGGS, M.D. lacked credibility and/or made a poor witness.

Causes of Action

STATEMENT OF FACTS RELATING TO ALL CAUSES OF ACTION ............... 26

THE FIRST CAUSE OF ACTION AGAINST ALL DEFENDANT ATTORNEYS (VIOLATION OF JUDICIARY LAW § 487 [1]) ....................................................... 120

THE SECOND CAUSE OF ACTION AGAINST GOLDFRAB & GERZOG AND THE LAW OFFICES OF STEVEN M. GOLDFARB (VIOLATION OF JUDICIARY LAW § 487 [2]) ....................................................................................... 141

THE THIRD CAUSE OF ACTION AGAINST STEVEN M. GOLDFARB, ESQ., IRA D. GERZOG, ESQ, GOLDFARB & GERZOG, THE LAW OFFICES OF STEVEN M. GOLDFARB, AND KAREN LEVINE (CONSTRUCTIVE FRAUD)

THE FOURTH CAUSE OF ACTION AGAINST CARINA BIGGS (INTENTIONAL FRAUD) ........................................................................................... 158

THE FIFTH CAUSE OF ACTION AGAINST McALOON & FRIEDMAN, CARINA BIGGS, GOLDFARB & GERZOG, LAW OFFICES OF STEVEN M.

THE EIGHTH CAUSE OF ACTION AGAINST ATTORNEYS GOLDFARB, GERZOG, SHAPIRO, GOLDSTEIN, KIVOWITZ, ROSEN, MAYNARD, KIM, AND JOHN AND JANES DOES 1-10 (AIDING AND ABETTING FRAUD) ....... 179

THE NINTH CAUSE OF ACTION AGAINST THE LAW OFFICES OF STEVEN M. GOLDFARB AND McALOON & FRIEDMAN, P.C. (INTENTIONAL OR MALICIOUS HARM TO ANOTHER (PRIMA FACIE TORT))............................ 194

THE TENTH CAUSE OF ACTION AGAINST GOLDFARB & GERZOG, THE LAW OFFICES OF STEVEN M. GOLDFARB, IRA D. GERZOG, ESQ., STEVEN M. GOLDFARB, ESQ., McALOON & FRIEDMAN P.C. (INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS) .......................................................... 200

THE ELEVENTH CAUSE OF ACTION AGAINST GOLDFARB & GERZOG, IRA D. GERZOG, AND THE LAW OFFICES OF STEVEN M. GOLDFARB (FRAUD IN THE INDUCEMENT) ............................................................................. 211

THE TWELFTH CAUSE OF ACTION AGAINST GOLDFARB & GERZOG AND THE LAW OFFICES OF STEVEN M. GOLDFARB (CONVERSION) ................ 235

THE THIRTEENTH CAUSE OF ACTION AGAINST BIGGS, KIM, GOLDFARB, GERZOG, LEVINE, GOLDSTEIN, KIVOWITZ, SHAPIRO, ROSEN,

THE FOURTEENTH CAUSE OF ACTION AGAINST ALL DEFENDANT ATTORNEYS (CONSPIRACY TO VIOLATE JUDICIARY LAW § 487) ............ 256

THE FIFTEENTH CAUSE OF ACTION AGAINST ALL DEFENDANT ATTORNEYS (AIDING AND ABETTING VIOLATION OF JUDICIARY LAW §

THE SIXTEENTH CAUSE OF ACTION AGAINST THE LAW OFFICES OF GOLDFARB & GERZOG (LEGAL MALPRACTICE) ........................................ 260

THE LOST CAUSE OF ACTION AGAINST CHRISTOPHER TURNER, M.D. (CIVIL BATTERY)....................................................................................................... 268

THE SEVENTEENTH CAUSE OF ACTION AGAINST GOLDFARB AND GERZOG AND THE LAW OFFICES OF STEVEN M. GOLDFARB (BREACH OF FIDUCIARY DUTY) .............................................................................................. 275

THE EIGHTEENTH CAUSE OF ACTION AGAINST McALOON & FRIEDMAN, ATTORNEYS SHAPIRO, KIVOWITZ, GOLDSTEIN, AND ROSEN (AIDING

THE NINETEENTH CAUSE OF ACTION AGAINST GOLDFARB AND GERZOG AND THE LAW OFFICES OF STEVEN M. GOLDFARB (DECLARATORY JUDGMENT) ............................................................................... 293

THE TWENTIETH CAUSE OF ACTION AGAINST CARINA BIGGS, M.D. (BREACH OF CONTRACT) ....................................................................................... 296

STATEMENT OF FACTS RELATING TO ALL CAUSES OF ACTION

1. AGAINST ALL DEFENDANT ATTORNEYS (VIOLATION OF JUDICIARY LAW § 487 [1])

2. AGAINST GOLDFRAB & GERZOG AND THE LAW OFFICES OF STEVEN M. GOLDFARB (VIOLATION OF JUDICIARY LAW § 487 [2])

4. AGAINST CARINA BIGGS (INTENTIONAL FRAUD)7

5. AGAINST McALOON & FRIEDMAN, CARINA BIGGS, GOLDFARB & GERZOG, LAW OFFICES OF STEVEN M. GOLDFARB, AND SARA KIM (FRAUD AND DECEIT: FORGERY)8

6. AGAINST McALOON & FRIEDMAN, P.C., ATTORNEYS SHAPIRO, GOLDSTEIN, AND KIVOWITZ (FRAUD)

8. AGAINST ATTORNEYS GOLDFARB, GERZOG, SHAPIRO, GOLDSTEIN, KIVOWITZ, ROSEN, MAYNARD, KIM, AND JOHN AND JANES DOES 1-10 (AIDING AND ABETTING FRAUD)

11. AGAINST GOLDFARB & GERZOG, IRA D. GERZOG, AND THE LAW OFFICES OF STEVEN M. GOLDFARB (FRAUD IN THE INDUCEMENT)

12. AGAINST GOLDFARB & GERZOG AND THE LAW OFFICES OF STEVEN M. GOLDFARB (CONVERSION)

13. AGAINST BIGGS, KIM, GOLDFARB, GERZOG, LEVINE, GOLDSTEIN, KIVOWITZ, SHAPIRO, ROSEN, MAYNARD, and JOHN AND JANE DOES 1-10 (CONSPIRACY TO COMMIT FRAUD)16

14. AGAINST ALL DEFENDANT ATTORNEYS (CONSPIRACY TO VIOLATE JUDICIARY LAW § 487)

15. AGAINST ALL DEFENDANT ATTORNEYS (AIDING AND ABETTING VIOLATION OF JUDICIARY LAW § 487)

16. AGAINST THE LAW OFFICES OF GOLDFARB & GERZOG (LEGAL MALPRACTICE)

cause of action against CHRISTOPHER TURNER, M.D.

LOST CAUSE OF ACTION AGAINST CHRISTOPHER TURNER, M.D. (CIVIL BATTERY)

17. AGAINST GOLDFARB AND GERZOG AND THE LAW OFFICES OF STEVEN M. GOLDFARB (BREACH OF FIDUCIARY DUTY)

18. AGAINST McALOON & FRIEDMAN, ATTORNEYS SHAPIRO, KIVOWITZ, GOLDSTEIN, AND ROSEN (AIDING AND ABETTING BREACH OF FIDUCIARY DUTY)

19. AGAINST GOLDFARB AND GERZOG AND THE LAW OFFICES OF STEVEN M. GOLDFARB (DECLARATORY JUDGMElNT)

20. AGAINST CARINA BIGGS, M.D. (BREACH OF CONTRACT)

Q. On all Causes of Action, costs and disbursements;

Parties

Plaintiffs

Alphaus A Williams ,

Attorneys for Plaintiffs

Williams, Alphaus A

Defendants

Carina Biggs , M.D.
Dawn Maynard In His Her Individual Capacity
Ira D. Gerzog , Esq.
John And Jane Does #1 Through 10.
Karen Levine
Laura R. Shapiro , Esq.
Lisa B. Goldstein , Esq.
Mcaloon & Friedman, P.C.
Michael S. Kivowitz , Esq.
Rhonda L. Rosen , Esq. In Her Individual Capacity
Sara Kim , M.D.
Steven M. Goldfarb , Esq.
The Law Offices Of Goldfarb & Gerzog
The Law Offices Of Steven M. Goldfarb

Attorneys for Defendants

Cohen, Joshua Robert
Furman, David Paul
Lilling, Caryn Leslie
O'Leary, Erin Anne
Richards, Spencer Alvin
Solomon, Katherine Herr
Song, Grace Eun Chong

Case Documents

NOTICE OF ENTRY

Date: Feb 09, 2022

DECISION ORDER ON MOTION

Date: Feb 09, 2022

DECISION ORDER ON MOTION

Date: Dec 17, 2021

NOTICE OF ENTRY

Date: Dec 17, 2021

NOTICE OF APPEAL

Date: Nov 22, 2021

NOTICE OF ENTRY

Date: Nov 05, 2021

NOTICE OF ENTRY

Date: Nov 05, 2021

NOTICE OF ENTRY

Date: Oct 28, 2021

NOTICE OF ENTRY

Date: Oct 26, 2021

EXHIBIT(S) - AA

Date: Sep 30, 2021

STIPULATION - OTHER

Date: Sep 24, 2021

ORDER - OTHER

Date: Sep 24, 2021

EXHIBIT(S) - A

Date: Sep 01, 2021

EXHIBIT(S) - B

Date: Sep 01, 2021

EXHIBIT(S) - C

Date: Sep 01, 2021

EXHIBIT(S) - D

Date: Sep 01, 2021

ORDER - OTHER (Motion 1)

Date: Apr 01, 2021

ORDER - OTHER

Date: Mar 30, 2021

ORDER - OTHER

Date: Mar 22, 2021

ORDER ( PROPOSED )

Date: Mar 18, 2021

ORDER ( PROPOSED )

Date: Mar 09, 2021

EXHIBIT(S) - 123

Date: Feb 08, 2021

ORDER ( PROPOSED )

Date: Feb 04, 2021

NOTICE OF MOTION

Date: Jan 21, 2021

SUMMONS COMPLAINT

Date: Mar 20, 2020

Case Events

Type Description
LETTER / CORRESPONDENCE TO JUDGE (Motion #13)
Letter withdrawing Motion to Settle Record
EXHIBIT(S) - B (Motion #13)
Emails between Plaintiff and Furman
EXHIBIT(S) - G (Motion #13)
Proposed Record on Appeal as to Goldfarb Defendants
EXHIBIT(S) - F (Motion #13)
Proposed Record on Appeal as to Goldfarb Defendants
EXHIBIT(S) - E (Motion #13)
Proposed Record on Appeal as to Goldfarb Defendants
NOTICE OF MOTION (Motion #13)
Notice of Motion
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #13)
Affidavit in Support of Motion/Petition to Settle the Record as to Goldfarb Defendants
EXHIBIT(S) - A (Motion #13)
Proposed Record on Appeals as to the Law Office(s) of Goldfarb & Gerzog
EXHIBIT(S) - C (Motion #13)
NYSCEF Doc. Nos. 153, 213, 219, 220, 246, 359, 380, 383, 386
NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE
Notice of Appeal/Informational Statement/Copy of Order
NOTICE OF ENTRY
DECISION + ORDER ON MOTION
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION
NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE
Notice of Appeal Motion Sequence 10
LETTER / CORRESPONDENCE TO JUDGE (Motion #9)
Letter to Court Regarding Motion Sequences 4 and 9
DECISION + ORDER ON MOTION
NOTICE OF ENTRY
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #10)
Aff. in Reply and Aff. of Service on G&G
LETTER / CORRESPONDENCE TO JUDGE
Letter to Court Regarding Motion to Recuse
NOTICE OF APPEAL
NOTICES OF APPEAL/INFORMATIONAL STATEMENTS/COPY OF ORDERS/NOTICES OF ENTRIES
AFFIRMATION/AFFIDAVIT OF SERVICE
Affidavits of Service Motion # 12
Notice of Entry March 29, 2021 Order
Notice of Entry December 22, 2020 Order
ORDER TO SHOW CAUSE-SIGNED
NOTICE OF ENTRY
Decision and Order With Notice of Entry
NOTICE OF ENTRY
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #10)
Affidavit in Reply as to Rosen, Biggs, and Maynard
ORDER ( PROPOSED ) (Motion #4)
Proposed Order MS #4
ORDER ( PROPOSED ) (Motion #9)
Proposed Order MS # 9
EXHIBIT(S) - A-D (Motion #11)
Exhibits A, B, C, D
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #11)
Affidavit in Support
NOTICE OF MOTION (Motion #11) Notice of Motion w Supporting Documents, Exhibits A1-A15 Submitted Via Email to General Clerk's Offi
Notice of Motion w Supporting Documents, Exhibits A1-A15 Submitted Via Email to General Clerk's Offi ... show more
DECISION + ORDER ON MOTION (Motion #2)
MOTION SEQ. 2, 3 & 8
EXHIBIT(S) - A (Motion #10)
Deft's Nov. 3rd Motion
EXHIBIT(S) - C (Motion #10)
Defendant's Reply
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion #10)
Affirmation in Opposition
EXHIBIT(S) - B (Motion #10)
Co-Defts Mx to Dismiss
EXHIBIT(S) - D (Motion #10)
Order Dismissing Co-Deft
LETTER / CORRESPONDENCE TO JUDGE
Letter to Justice Rivera Withdrawing Proposed OSC as to Ira D. Gerzog, Esq.
ORDER TO SHOW CAUSE ( PROPOSED )
Proposed Order to Show Cause
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP
Affidavit in Support of Proposed OSC
EXHIBIT(S) - AA
Emails to Attorneys Erin O'Leary and Joshua Cohen
LETTER / CORRESPONDENCE TO JUDGE Letter to Court Regarding Request to Extend Filing Date of Note of Issue from October 1, 2021 to Dec
Letter to Court Regarding Request to Extend Filing Date of Note of Issue from October 1, 2021 to Dec ... show more
OTHER COURT FILED DOCUMENT
STIPULATION - OTHER
ORDER - OTHER
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION
LETTER / CORRESPONDENCE TO JUDGE
Letter to Justice Rivera Re: Withdrawl of Branch of Motion with Respect to MCF Defendants
EXHIBIT(S) - A
Order to Show Cause Signed by the Hon. Francois Rivera, J.S.C.
EXHIBIT(S) - B
Proposed Order dated December 22, 2020
ORDER TO SHOW CAUSE ( PROPOSED )
Order to Show Cause (Proposed)
AFFIDAVIT OR AFFIRMATION IN SUPPORT
Affidavit in Support of Motion Pursuant to CPLR 2219; 5019 and 22 NYCRR 202.48
EXHIBIT(S) - C
Transcript of the Proceedings held before the Hon. Francois Rivera, J.S.C. on December 22, 2020.
EXHIBIT(S) - D
Order of the Hon. Francois Rivera, J.S.C. dated March 4, 2021 and entered April 1, 2021
EXHIBIT(S) - 118 (Motion #10)
Plaintiff's Aff. in Opp. to Gerzog's Motion and in Support of Sanctions with Supplemental Exhibits
EXHIBIT(S) - 117 (Motion #10)
Stipulation Extending Gerzog's Time to Appear (Individually)
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #10)
Affidavit in Support of Motion for Default Judgment
EXHIBIT(S) - 138 (Motion #10)
Formal Opinion No. 96-Fl2
EXHIBIT(S) - 139 (Motion #10)
Plaintiff's Aff. in Opposition to Goldfarb Defendants Motion to Dismiss with Supplemental Exhibits
NOTICE OF MOTION (Motion #10)
Notice of Motion
EXHIBIT(S) - 137 (Motion #10)
Bill Jacket, L 1978 ch 640
EXHIBIT(S) - 112 (Motion #10) Plaintiff's Aff. in Opp. to Rosen's, Biggs' and Maynard's Motion to Dismiss with Supplemental Exhibi
Plaintiff's Aff. in Opp. to Rosen's, Biggs' and Maynard's Motion to Dismiss with Supplemental Exhibi ... show more
NOTICE OF ENTRY (Motion #7)
Service of Notice of Entry 202.5-b(h)(2)
NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE
Notices of Appeal
NOTICE OF ENTRY (Motion #1)
Service of Notice of Entry 202.5-b(h)(2)
LETTER / CORRESPONDENCE TO JUDGE
Letter to Justice Rivera Regarding Interm Order Dated March 29, 2021 and Entered March 30, 2021
ORDER - OTHER (Motion #1)
dated 3/4/21
ORDER - OTHER
ORDER - OTHER
ORDER ( PROPOSED )
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO CROSS-MOTION AND IN FURTHER SUPPORT OF MOTION
MEMORANDUM OF LAW IN OPPOSITION TO CROSS-MOTION AND IN FURTHER SUPPORT OF MOTION
EXHIBIT(S) - 66 (Motion #8) Email of Nov. 26, 2018 From Plaintiff to Goldfarb and Gerzog Headed "Preliminary Statement of Profes
Email of Nov. 26, 2018 From Plaintiff to Goldfarb and Gerzog Headed "Preliminary Statement of Profes ... show more
EXHIBIT(S) - 120 (Motion #8)
Affidavit in Opposition to the Law Offices of Goldfarb & Gerzog's Motion by OSC
EXHIBIT(S) - 123 (Motion #8)
Executed General Release
EXHIBIT(S) - 40 (Motion #8)
Examination Before Trial Transcript of Christopher Turner, M.D.
EXHIBIT(S) - 126 (Motion #8) Furman Memorandum of Law in Support of Motion to Dismiss Plaintiffs Verified Complaint of February 2
Furman Memorandum of Law in Support of Motion to Dismiss Plaintiffs Verified Complaint of February 2 ... show more
EXHIBIT(S) - 41 (Motion #8)
Examination Before Trial of Henry Talus, M.D.
EXHIBIT(S) - 93 (Motion #8)
Summons and Verified Complaint
EXHIBIT(S) - 128 (Motion #8)
Affidavit of Donald Frangipani Certified Forensic Expert
EXHIBIT(S) - 111 (Motion #8) Affirmation in Support of Order to Show Cause of Robert N. Swetnick, Esq. of August 27, 2010 and Dec
Affirmation in Support of Order to Show Cause of Robert N. Swetnick, Esq. of August 27, 2010 and Dec ... show more
EXHIBIT(S) - 52 (Motion #8)
Goldfarb's Letter of June 14, 2019 to Plaintiff Via Certified Mail Return Receipt Requested
EXHIBIT(S) - 127 (Motion #8)
Email of June 21, 2019 at 3:55 PM
EXHIBIT(S) - 119 (Motion #8)
Affirmation in Support of Spencer Richards, Esq. November 23, 2020
EXHIBIT(S) - 3 (Motion #8)
Text Message Exchange of October 11, 2018 Between Goldfarb and Plaintiff
EXHIBIT(S) - 130 (Motion #8)
Reply Affirmation of Caryn Lilling, Esq. of December 16, 2020
EXHIBIT(S) - 70 (Motion #8)
Catherine Patsos', Esq. Letter Dated May 22, 2020 (Informing of USB w Proof of Mailing)
EXHIBIT(S) - 51 (Motion #8)
Goldfarb's Letter of February 5, 2019 to Plaintiff Via Certified Mail Return Receipt Requested
EXHIBIT(S) - 136 (Motion #8)
Affidavit of Service of EBT Transcript of April 6, 2017 on Christopher Turner, M.D.
EXHIBIT(S) - 39 (Motion #8)
Examination Before Trial of Carina Biggs, M.D.
EXHIBIT(S) - 80 (Motion #8)
Letter of June 18, 2020 from HHS-OCR to Plaintiff and Patsos
EXHIBIT(S) - 118 (Motion #8) Plaintiff's Aff. in Opposition to Gerzogs Motion to Dismiss the Verified Complaint of November 17, 2
Plaintiff's Aff. in Opposition to Gerzogs Motion to Dismiss the Verified Complaint of November 17, 2 ... show more
EXHIBIT(S) - 54 (Motion #8)
Consent to Change Attorney Forms Goldfarb to Plaintiff, Pro Se
EXHIBIT(S) - 53 (Motion #8)
Goldfarbs Letter of June 14, 2019 to Plaintiff Via Certified and Regular Mail
EXHIBIT(S) - 135 (Motion #8)
Plaintiff's Affidavit in Reply of February 10, 2021
EXHIBIT(S) - 131 (Motion #8)
Furman Kornfeld & Brennan LLP New York State Bar Association White Paper 2019
EXHIBIT(S) - 29 (Motion #8)
Certified Transcript of Colloquy Between Gerzog and Plaintiff on June 24, 2019
EXHIBIT(S) - 50 (Motion #8)
Goldfarb's Letter of December 18, 2018 to Plaintiff Via FedEx
EXHIBIT(S) - 122 (Motion #8)
Plaintiff's Proposed Order to Vacate G&G Order of December 22, 2020
EXHIBIT(S) - 30 (Motion #8)
Retainer Agreement
EXHIBIT(S) - 125 (Motion #8)
Furman Affirmation in Support of Motion to Dismiss of February 2, 2021
EXHIBIT(S) - 78 (Motion #8)
Stipulation of Discontinuance with Prejudice filed By Attorney Kivowitz
MEMORANDUM OF LAW IN OPPOSITION (Motion #8)
Memorandum of Law
EXHIBIT(S) - 25 (Motion #8)
Certified Transcript of Colloquy Between Karen Levine and Plaintiff on Oct. 17, 2018
EXHIBIT(S) - 19 (Motion #8)
Patsos Letter of May 21, 2020 Accompanying Medical Records Provided Pursuant to HHS-OCR Directive
EXHIBIT(S) - 24 (Motion #8)
Certified Transcript of Colloquy Between Goldfarb and Plaintiff on Oct. 17, 2018
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion #8)
Affidavit in Opposition to Goldfarb Defendants Motion to Dismiss
EXHIBIT(S) - 27 (Motion #8)
Certified Transcript of Colloquy Between Goldfarb and Plaintiff on November 29, 2018
EXHIBIT(S) - 116 (Motion #8)
Denial of Motion by OSC to Remove Goldfarb Due to Case Being Disposed and CPLR 2217
EXHIBIT(S) - 42 (Motion #8)
Examination Before Trial of Muthukumar Muthusamy, M.D.
EXHIBIT(S) - 28 (Motion #8)
Certified Transcript of Colloquy Between Karen Levine and Plaintiff on Dec. 12, 2018
EXHIBIT(S) - 26 (Motion #8)
Certified Transcript of Colloquy Between Goldfarb and Plaintiff on Oct. 25, 2018
ORDER ( PROPOSED )
Proposed Order to Dismiss
STATEMENT OF AUTHORIZATION FOR ELECTRONIC FILING
EXHIBIT(S) - 134 (Motion #5)
Web Civil Supreme Case Type COMM-Contract
EXHIBIT(S) - 133 (Motion #5)
Plaintiffs Affidavit in Opposition to MCF Defendants Motion to Dismiss of November 17, 2020
EXHIBIT(S) - 87 (Motion #5)
Affirmation in Support of Caryn Lilling, Esq. of October 1, 2020
EXHIBIT(S) - 130 (Motion #5)
Reply Affirmation of Caryn Lilling, Esq. of December 16, 2020
EXHIBIT(S) - 123 (Motion #5)
Executed General Release
EXHIBIT(S) - 78 (Motion #5)
Stipulation of Discontinuance
EXHIBIT(S) - 116 (Motion #5)
Kings Supreme Court Part 72 / Ex Parte
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #5)
Affidavit in Reply
AFFIDAVIT OR AFFIRMATION IN REPLY
EXHIBIT(S) - 132 (Motion #4)
Affirmation in Opp. to Plaintiff's Cross-Motion for Sanctions
EXHIBIT(S) - 93 (Motion #4)
Summons & Verified Complaint
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #4)
Plaintiff's Affidavit in Reply
EXHIBIT(S) - 78 (Motion #4)
Stipulation of Discontinuance
EXHIBIT(S) - 123 (Motion #4)
Executed Gnereal Release
EXHIBIT(S) - 88 (Motion #4)
Affirmation in Support of Erin O'Leary, Esq of October 15, 2020
EXHIBIT(S) - 116 (Motion #4) Justice Sherman's Determination of December 5, 2019 that the "Case [was] Marked Disposed" on October
Justice Sherman's Determination of December 5, 2019 that the "Case [was] Marked Disposed" on October ... show more
EXHIBIT(S) - 134 (Motion #4)
Web Civil Supreme Case Type "COMM-Contract"
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion #9) Affirmation in Opposition to Plaintiff's Cross Motion for Sanctions against Ira D. Gerzog, Esq. and
Affirmation in Opposition to Plaintiff's Cross Motion for Sanctions against Ira D. Gerzog, Esq. and ... show more
NOTICE OF MOTION (Motion #9)
Notice of Cross-Motion for Sanctions
EXHIBIT(S) - 124 (Motion #9)
Reply Affirmation of Joshua Cohe, Esq. of December 16, 2020
EXHIBIT(S) - 92 (Motion #9)
Affirmation in Support of Joshua Cohen, Esq. of November 3, 2020
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #9)
Plaintiff's Affidavit in Support of Cross-Motion for Sanctions
EXHIBIT(S) - 123 (Motion #9)
Executed General Release
EXHIBIT(S) - 129 (Motion #9)
Plantiff's Aff. In Opp. to Defs. Rosen's, Biggs', and Maynard's Motion of Nov. 17, 2020
AFFIDAVIT OR AFFIRMATION IN REPLY
EXHIBIT(S) - 123
Executed General Release
ORDER ( PROPOSED )
EXHIBIT(S) - A (Motion #7)
Gubernatorial Executive Order 202.8
EXHIBIT(S) - B (Motion #7)
Administrative Order 115/20
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION
MEMORANDUM OF LAW IN SUPPORT
EXHIBIT(S) - A (Motion #8)
Summons & Complaint
EXHIBIT(S) - B (Motion #8)
Malpractice Retainer
NOTICE OF MOTION (Motion #8)
EXHIBIT(S) - C (Motion #8)
Underlying Complaint
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION
EXHIBIT(S) - 121 (Motion #7)
Goldfarb & Gerzog's Proposed Order
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #7)
Affidavit In Support of Motion to Vacate Order of December 22, 2020
EXHIBIT(S) - 120 (Motion #7)
Plaintiff's Affidavit in Opposition
EXHIBIT(S) - 119 (Motion #7)
Affirmation in Support of Spencer Richards, Esq. of Nov. 23, 2020
NOTICE OF MOTION
EXHIBIT(S) - 101 (Motion #7)
Administrative Orders of Chief Administrative Judge Lawrence Marks 115/20
EXHIBIT(S) - 122 (Motion #7)
Plaintiff's Proposed Order Vacating the Order of December 22, 2020
hearing (Motion #002)
MOTION TRIAL TERM 52
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Judge: FRANCOIS A. RIVERA (PT. 52)

hearing ADJOURNED (Motion #004)
SUBSEQUENT MOTION PART Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

hearing ADJOURNED (Motion #002)
MOTION TRIAL TERM 52
ADM Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

hearing ADJOURNED (Motion #001)
MOTION TRIAL TERM 52
ADM Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

hearing ADJOURNED (Motion #002)
SUBSEQUENT MOTION PART Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

hearing ADJOURNED (Motion #001)
MOTION PART Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

Motion SANCTIONS (Motion #004)
Before Justice: FRANCOIS A\. RIVERA (PT. 52)
Answer demanded: Yes Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

Motion SANCTIONS (Motion #005)
Before Justice: FRANCOIS A\. RIVERA (PT. 52)
Answer demanded: Yes Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

Motion DISMISS (Motion #003)
Before Justice: FRANCOIS A\. RIVERA (PT. 52)
Answer demanded: Yes Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

Motion DISMISS (Motion #002)
Before Justice: FRANCOIS A\. RIVERA (PT. 52)
Answer demanded: Yes Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

Motion DISMISS (Motion #001)
Before Justice: FRANCOIS A\. RIVERA (PT. 52)
Answer demanded: Yes Trellis Spinner 👉 Discover key insights by exploring more analytics for FRANCOIS A. RIVERA (PT. 52)

Judge: FRANCOIS A. RIVERA (PT. 52)

Docket Event LETTER / CORRESPONDENCE TO JUDGE
Letter requesting extension of time to respond to complaint
Docket Event AFFIRMATION/AFFIDAVIT OF SERVICE
Carina Biggs, M.D.
Docket Event AFFIRMATION/AFFIDAVIT OF SERVICE
Karen Levine / Proof of Delivery / 8/20/2020
Docket Event AFFIRMATION/AFFIDAVIT OF SERVICE
Steven M. Goldfarb, Esq., Goldfarb & Gerzog, and the Law Offices of Steven M. Goldfarb / Proof of De
Docket Event AFFIRMATION/AFFIDAVIT OF SERVICE
Ira D. Gerzog, Esq. and Goldfarb & Gerzog
Docket Event AFFIRMATION/AFFIDAVIT OF SERVICE
McAloon & Friedman, P.C.
Docket Event EXHIBIT(S) - 80
Letter of June 18, 2020 from HHS-OCR to Plaintiff and Patsos Advising of the Closing of Investigatio
Docket Event EXHIBIT(S) - 20D
Medical Records Reproduced by NYCHHC/KCHC Pursuant to OCR Directive (Scanned Hard Copies)
Docket Event EXHIBIT(S) - 79
NYCHHC No Fee Authorization Letter to County Clerk filed by Attorney Kivowitz
Docket Event EXHIBIT(S) - 78
Stipulation of Discontinuance with Prejudice filed By Attorney Kivowitz
Docket Event EXHIBIT(S) - 20C
Medical Records Reproduced on 05/19/2020 by NYCHHC/KCHC Pursuant to OCR Directive (Encrypted USB)
Docket Event EXHIBIT(S) - 20B
Medical Records Reproduced on 05/19/2020 by NYCHHC/KCHC Pursuant to OCR Directive (Encrypted USB)
Docket Event EXHIBIT(S) - 20A
Medical Records Reproduced on 05/19/2020 by NYCHHC/KCHC Pursuant to OCR Directive (Encrypted USB)
Docket Event EXHIBIT(S) - 75
Plaintiff's Response to Combined Demands
Docket Event EXHIBIT(S) - 74
NYCHHC/KCHC/M&F "Accounting of Disclosures" Styled as an "Accounting of Records"
Docket Event EXHIBIT(S) - 73
Plaintiff's June 5, 2020 letter to Catherine Patsos, Esq. w Proof of Mailing
Docket Event EXHIBIT(S) - 72
Plaintiff's June 3, 2020 Letter to Catherine Patsos, Esq. w Proof of Mailing
Docket Event EXHIBIT(S) - 76
KCHC Consent Forms Provided Pursuant to OCR Directive
Docket Event EXHIBIT(S) - 71
Catherine Patsos', Esq. Letter Dated May 22, 2020 (Informing of Password w Proof of Mailing)
Docket Event EXHIBIT(S) - 70
Catherine Patsos', Esq. Letter Dated May 22, 2020 (Informing of USB w Proof of Mailing)
Docket Event EXHIBIT(S) - 69
Email of January 22, 2019 From Plaintiff to LOSMG Headed "Happy New Year to all!"
Docket Event EXHIBIT(S) - 68
Email Series of Dec. 12, 2018-Dec. 14, 2018 Headed "Documents"
Docket Event EXHIBIT(S) - 67
Email of November 30, 2018 From Plaintiff to LOSMG Headed "Followup of Conversation of November 29,
Docket Event EXHIBIT(S) - 66
Email of Nov. 26, 2018 From Plaintiff to Goldfarb and Gerzog Headed "Preliminary Statement of Profes
Docket Event EXHIBIT(S) - 65
Email of Nov. 19, 2018 From Plaintiff to the LOSMG Headed "Outstanding requested documents"
Docket Event EXHIBIT(S) - 64
Email of Nov. 8, 2018-Nov. 9, 2018 From Plaintiff to LOSMG Headed "Documents request reminder"
Docket Event EXHIBIT(S) - 63
Note of Issue, Index No.: 500113/2015
Docket Event EXHIBIT(S) - 62
Notice of Medical Malpractice
Docket Event EXHIBIT(S) - 61
Verified Answer of NYCHHC
Docket Event EXHIBIT(S) - 60
Verified Answer of Muthukumar Muthusamy, M.D.
Docket Event EXHIBIT(S) - 59
Verified Answer of Henry Talus, M.D.
Docket Event EXHIBIT(S) - 58
Verified Answer of Christopher Turner, M.D.
Docket Event EXHIBIT(S) - 57
Verified Answer of Carina Biggs, M.D.
Docket Event EXHIBIT(S) - 56
Underlying Summons and Verified Complaint, Index No.: 500113/2015
Docket Event EXHIBIT(S) - 55
Plaintiff's Email of Dec. 11, 2018 to Goldfarb Headed "I need to speak with you!"
Docket Event EXHIBIT(S) - 54
Consent to Change of Attorneys from LOSMG to Plaintiff Attorney Pro Se
Docket Event EXHIBIT(S) - 53
Goldfarb's Letter of June 14, 2019 to Plaintiff Via Regular Mail
Docket Event EXHIBIT(S) - 52
Goldfarb's Letter of June 14, 2019 to Plaintiff Via Certified Mail Return Receipt Requested
Docket Event EXHIBIT(S) - 51
Goldfarb's Letter of February 5, 2018 to Plaintiff Via Certified Mail Return Receipt Requested
Docket Event EXHIBIT(S) - 50
Goldfarb's Letter of December 18, 2018 to Plaintiff Via FedEx
Docket Event EXHIBIT(S) - 49
Consent to Change of Attorneys G&G to the LOSMG
Docket Event EXHIBIT(S) - 48
Goldfarb's Letter of July 23, 2018 to Plaintiff
Docket Event EXHIBIT(S) - 47
Email of June 22, 2018 From Plaintiff to Goldfarb Headed "Continuation of Representation"
Docket Event EXHIBIT(S) - 46
Series of Emails of June 3, 2018 Between Plaintiff and Gerzog Headed "Hello"
Docket Event EXHIBIT(S) - 45
Firm Overview of M&F
Docket Event EXHIBIT(S) - 44
Firm Overview of the LOSMG
Docket Event EXHIBIT(S) - 43
Firm Overview of G&G
Docket Event EXHIBIT(S) - 42
Examination Before Trial of Muthukumar Muthusamy, M.D.
Docket Event EXHIBIT(S) - 41
Examination Before Trial of Henry Talus, M.D.
Docket Event EXHIBIT(S) - 40
Examination Before Trial of Christopher Turner, M.D.
Docket Event EXHIBIT(S) - 39
Examination Before Trial of Carina Biggs, M.D.
Docket Event EXHIBIT(S) - 38
Transcript of Proceedings of July 10, 2018 - Gerzog v Goldfarb, Index No. 653432/2018 (Sup. Ct. NY C
Docket Event EXHIBIT(S) - 37
Goldfarb Aff. of August 7, 2018
Docket Event EXHIBIT(S) - 36
Gerzog Aff. of August 27, 2018
Docket Event EXHIBIT(S) - 35
Gerzog Aff. of July 9, 2018
Docket Event EXHIBIT(S) - 34
Levine Aff. of August 2, 2018
Docket Event EXHIBIT(S) - 33
Dinhofer Aff. of August 1, 2018
Docket Event EXHIBIT(S) - 32
General Release
Docket Event EXHIBIT(S) - 31
LOSMG'S Disbursements Sheet
Docket Event EXHIBIT(S) - 30
Malpractice Retainer Agreement (G&G)
Docket Event EXHIBIT(S) - 29
Certified Transcript of Colloquy Between Gerzog and Plaintiff on June 24, 2019
Docket Event EXHIBIT(S) - 28
Certified Transcript of Colloquy Between Karen Levine and Plaintiff on December 12, 2018
Docket Event EXHIBIT(S) - 27
Certified Transcript of Colloquy Between Goldfarb and Plaintiff on November 29, 2018
Docket Event EXHIBIT(S) - 26
Certified Transcript of Colloquy Between Goldfarb and Plaintiff on October 25, 2018
Docket Event EXHIBIT(S) - 25
Certified Transcript of Colloquy Between Karen Levine and Plaintiff on or About October 17, 2018
Docket Event EXHIBIT(S) - 23
Certified Transcript of Colloquy Between Goldfarb and Plaintiff on October 17, 2018
Docket Event EXHIBIT(S) - 23
Kings County Hospital Center Nursing Discharge Summary of August 29, 2013
Docket Event EXHIBIT(S) - 22
Certified Ambulance Call Report of 07/09/2013 Reproduced by FDNY on 7/14/2014
Docket Event EXHIBIT(S) - 21
Ambulance Call Report of 07/09/2013 Provided by NYCHHC/KCHC Pursuant to OCR Directive
Docket Event EXHIBIT(S) - 19
Patsos Letter of April 21, 2020 Accompanying Medical Records Provided Pursuant to HHS-OCR Directive
Docket Event EXHIBIT(S) - 18
Medical Records Reproduced by NYCHHC/KCHC on March 1, 2019
Docket Event EXHIBIT(S) - 17
Medical Records Reproduced by NYCHHC/KCHC on February 12, 2019
Docket Event EXHIBIT(S) - 16
Medical Records Reproduced by NYCHHC/KCHC on January 22, 2019
Docket Event EXHIBIT(S) - 15
Certified Operative Report of 07/09/2013 Reproduced on November 1, 2016
Docket Event EXHIBIT(S) - 14
Certified Pathology Report Reproduced on July 28, 2014
Docket Event EXHIBIT(S) - 13
LOSMG'S Email of November 20, 2018 to Plaintiff
Docket Event EXHIBIT(S) - 12
Pathology Report Reproduced by NYCHHC/KCHC on June 13, 2014 Produced by Goldfarb on October 17, 2018
Docket Event EXHIBIT(S) - 11
Medical Records reproduced by NYCHHC/KCHC on June 13, 2014 Produced by Goldfarb on October 17, 2018
Docket Event EXHIBIT(S) - 10
Email Series of October 17, 2018 from LOSMG to Plaintiff Headed "Kings County Records"
Docket Event EXHIBIT(S) - 9
Actual Discharge Summary of August 29, 2013
Docket Event EXHIBIT(S) - 8
Email of October 17, 2018 from LOSMG to Plaintiff Headed "Transcripts"
Docket Event EXHIBIT(S) - 7
Medical Records Reproduced by NYCHHC/KCHC on 12/3/2013 (sent to NYSOTDA/SSA)
Docket Event EXHIBIT(S) - 6
Goldfarb's Memorandum of Termination With Cause
Docket Event EXHIBIT(S) - 5
Email Series of October 12, 2018 From Plaintiff to LOSMG
Docket Event EXHIBIT(S) - 4
Email of October 11, 2018 From Plaintiff to the LOSMG
Docket Event EXHIBIT(S) - 3
Text Message Exchange of October 11, 2018 Between Goldfarb and Plaintiff
Docket Event EXHIBIT(S) - 2
Email Series of May 22, 2017 Headed "Hi"
Docket Event EXHIBIT(S) - 1
Email of March 27, 2017 from Plaintiff to Goldfarb & Gerzog
Docket Event SUMMONS + COMPLAINT

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