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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
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;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
Attorneys for Plaintiffs
Defendants
Attorneys for Defendants
Case Documents
LETTER / CORRESPONDENCE TO JUDGE (Motion 13)
Date: Jun 26, 2023EXHIBIT(S) - B (Motion 13)
Date: Jun 21, 2023EXHIBIT(S) - G (Motion 13)
Date: Jun 21, 2023EXHIBIT(S) - F (Motion 13)
Date: Jun 21, 2023EXHIBIT(S) - E (Motion 13)
Date: Jun 21, 2023NOTICE OF MOTION (Motion 13)
Date: Jun 21, 2023AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 13)
Date: Jun 21, 2023EXHIBIT(S) - A (Motion 13)
Date: Jun 21, 2023EXHIBIT(S) - C (Motion 13)
Date: Jun 21, 2023NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE
Date: Mar 02, 2022NOTICE OF ENTRY
Date: Feb 09, 2022DECISION ORDER ON MOTION
Date: Feb 09, 2022AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION
Date: Jan 27, 2022NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE
Date: Jan 03, 2022LETTER / CORRESPONDENCE TO JUDGE (Motion 9)
Date: Dec 21, 2021DECISION ORDER ON MOTION
Date: Dec 17, 2021NOTICE OF ENTRY
Date: Dec 17, 2021AFFIDAVIT OR AFFIRMATION IN REPLY (Motion 10)
Date: Dec 15, 2021LETTER / CORRESPONDENCE TO JUDGE
Date: Dec 14, 2021NOTICE OF APPEAL
Date: Nov 22, 2021AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Nov 12, 2021NOTICE OF ENTRY
Date: Nov 05, 2021NOTICE OF ENTRY
Date: Nov 05, 2021ORDER TO SHOW CAUSE-SIGNED
Date: Nov 01, 2021NOTICE OF ENTRY
Date: Oct 28, 2021NOTICE OF ENTRY
Date: Oct 26, 2021AFFIDAVIT OR AFFIRMATION IN REPLY (Motion 10)
Date: Oct 25, 2021ORDER ( PROPOSED ) (Motion 4)
Date: Oct 25, 2021ORDER ( PROPOSED ) (Motion 9)
Date: Oct 25, 2021EXHIBIT(S) - A-D (Motion 11)
Date: Oct 25, 2021AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 11)
Date: Oct 25, 2021DECISION ORDER ON MOTION (Motion 2)
Date: Oct 25, 2021EXHIBIT(S) - A (Motion 10)
Date: Oct 07, 2021EXHIBIT(S) - C (Motion 10)
Date: Oct 07, 2021AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion 10)
Date: Oct 07, 2021EXHIBIT(S) - B (Motion 10)
Date: Oct 07, 2021EXHIBIT(S) - D (Motion 10)
Date: Oct 07, 2021LETTER / CORRESPONDENCE TO JUDGE
Date: Oct 04, 2021ORDER TO SHOW CAUSE ( PROPOSED )
Date: Sep 30, 2021AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP
Date: Sep 30, 2021EXHIBIT(S) - AA
Date: Sep 30, 2021OTHER COURT FILED DOCUMENT
Date: Sep 27, 2021STIPULATION - OTHER
Date: Sep 24, 2021ORDER - OTHER
Date: Sep 24, 2021AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION
Date: Sep 23, 2021LETTER / CORRESPONDENCE TO JUDGE
Date: Sep 02, 2021EXHIBIT(S) - A
Date: Sep 01, 2021EXHIBIT(S) - B
Date: Sep 01, 2021ORDER TO SHOW CAUSE ( PROPOSED )
Date: Sep 01, 2021AFFIDAVIT OR AFFIRMATION IN SUPPORT
Date: Sep 01, 2021EXHIBIT(S) - C
Date: Sep 01, 2021EXHIBIT(S) - D
Date: Sep 01, 2021EXHIBIT(S) - 118 (Motion 10)
Date: Jul 14, 2021EXHIBIT(S) - 117 (Motion 10)
Date: Jul 14, 2021AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 10)
Date: Jul 14, 2021EXHIBIT(S) - 138 (Motion 10)
Date: Jul 14, 2021EXHIBIT(S) - 139 (Motion 10)
Date: Jul 14, 2021NOTICE OF MOTION (Motion 10)
Date: Jul 14, 2021EXHIBIT(S) - 137 (Motion 10)
Date: Jul 14, 2021NOTICE OF ENTRY (Motion 7)
Date: Apr 30, 2021NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE
Date: Apr 30, 2021NOTICE OF ENTRY (Motion 1)
Date: Apr 30, 2021LETTER / CORRESPONDENCE TO JUDGE
Date: Apr 20, 2021ORDER - OTHER (Motion 1)
Date: Apr 01, 2021ORDER - OTHER
Date: Mar 30, 2021ORDER - OTHER
Date: Mar 22, 2021ORDER ( PROPOSED )
Date: Mar 18, 2021EXHIBIT(S) - 120 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 123 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 40 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 41 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 93 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 128 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 52 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 127 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 119 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 3 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 130 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 70 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 51 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 136 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 39 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 80 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 54 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 53 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 135 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 131 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 29 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 50 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 122 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 30 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 125 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 78 (Motion 8)
Date: Mar 11, 2021MEMORANDUM OF LAW IN OPPOSITION (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 25 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 19 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 24 (Motion 8)
Date: Mar 11, 2021AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 27 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 116 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 42 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 28 (Motion 8)
Date: Mar 11, 2021EXHIBIT(S) - 26 (Motion 8)
Date: Mar 11, 2021ORDER ( PROPOSED )
Date: Mar 09, 2021STATEMENT OF AUTHORIZATION FOR ELECTRONIC FILING
Date: Mar 09, 2021EXHIBIT(S) - 134 (Motion 5)
Date: Mar 03, 2021EXHIBIT(S) - 133 (Motion 5)
Date: Mar 03, 2021EXHIBIT(S) - 87 (Motion 5)
Date: Mar 03, 2021EXHIBIT(S) - 130 (Motion 5)
Date: Mar 03, 2021EXHIBIT(S) - 123 (Motion 5)
Date: Mar 03, 2021EXHIBIT(S) - 78 (Motion 5)
Date: Mar 03, 2021EXHIBIT(S) - 116 (Motion 5)
Date: Mar 03, 2021AFFIDAVIT OR AFFIRMATION IN REPLY (Motion 5)
Date: Mar 03, 2021AFFIDAVIT OR AFFIRMATION IN REPLY
Date: Mar 03, 2021EXHIBIT(S) - 132 (Motion 4)
Date: Mar 02, 2021EXHIBIT(S) - 93 (Motion 4)
Date: Mar 02, 2021AFFIDAVIT OR AFFIRMATION IN REPLY (Motion 4)
Date: Mar 02, 2021EXHIBIT(S) - 78 (Motion 4)
Date: Mar 02, 2021EXHIBIT(S) - 123 (Motion 4)
Date: Mar 02, 2021EXHIBIT(S) - 88 (Motion 4)
Date: Mar 02, 2021EXHIBIT(S) - 134 (Motion 4)
Date: Mar 02, 2021NOTICE OF MOTION (Motion 9)
Date: Feb 16, 2021EXHIBIT(S) - 124 (Motion 9)
Date: Feb 16, 2021EXHIBIT(S) - 92 (Motion 9)
Date: Feb 16, 2021AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 9)
Date: Feb 16, 2021EXHIBIT(S) - 123 (Motion 9)
Date: Feb 16, 2021EXHIBIT(S) - 129 (Motion 9)
Date: Feb 16, 2021AFFIDAVIT OR AFFIRMATION IN REPLY
Date: Feb 10, 2021EXHIBIT(S) - 123
Date: Feb 08, 2021ORDER ( PROPOSED )
Date: Feb 04, 2021EXHIBIT(S) - A (Motion 7)
Date: Feb 04, 2021EXHIBIT(S) - B (Motion 7)
Date: Feb 04, 2021AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION
Date: Feb 04, 2021MEMORANDUM OF LAW IN SUPPORT
Date: Feb 02, 2021EXHIBIT(S) - A (Motion 8)
Date: Feb 02, 2021EXHIBIT(S) - B (Motion 8)
Date: Feb 02, 2021NOTICE OF MOTION (Motion 8)
Date: Feb 02, 2021EXHIBIT(S) - C (Motion 8)
Date: Feb 02, 2021AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION
Date: Feb 02, 2021EXHIBIT(S) - 121 (Motion 7)
Date: Jan 21, 2021AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 7)
Date: Jan 21, 2021EXHIBIT(S) - 120 (Motion 7)
Date: Jan 21, 2021EXHIBIT(S) - 119 (Motion 7)
Date: Jan 21, 2021NOTICE OF MOTION
Date: Jan 21, 2021EXHIBIT(S) - 101 (Motion 7)
Date: Jan 21, 2021EXHIBIT(S) - 122 (Motion 7)
Date: Jan 21, 2021SUMMONS COMPLAINT
Date: Mar 20, 2020Case Events
Date | Type | Description | |
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June 26, 2023 |
LETTER / CORRESPONDENCE TO JUDGE (Motion #13) Letter withdrawing Motion to Settle Record |
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June 21, 2023 |
EXHIBIT(S) - B (Motion #13) Emails between Plaintiff and Furman |
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June 21, 2023 |
EXHIBIT(S) - G (Motion #13) Proposed Record on Appeal as to Goldfarb Defendants |
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June 21, 2023 |
EXHIBIT(S) - F (Motion #13) Proposed Record on Appeal as to Goldfarb Defendants |
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June 21, 2023 |
EXHIBIT(S) - E (Motion #13) Proposed Record on Appeal as to Goldfarb Defendants |
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June 21, 2023 |
NOTICE OF MOTION (Motion #13) Notice of Motion |
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June 21, 2023 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #13) Affidavit in Support of Motion/Petition to Settle the Record as to Goldfarb Defendants |
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June 21, 2023 |
EXHIBIT(S) - A (Motion #13) Proposed Record on Appeals as to the Law Office(s) of Goldfarb & Gerzog |
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June 21, 2023 |
EXHIBIT(S) - C (Motion #13) NYSCEF Doc. Nos. 153, 213, 219, 220, 246, 359, 380, 383, 386 |
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March 02, 2022 |
NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE Notice of Appeal/Informational Statement/Copy of Order |
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February 09, 2022 | NOTICE OF ENTRY | ||
February 09, 2022 | DECISION + ORDER ON MOTION | ||
January 27, 2022 | AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION | ||
January 03, 2022 |
NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE Notice of Appeal Motion Sequence 10 |
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December 21, 2021 |
LETTER / CORRESPONDENCE TO JUDGE (Motion #9) Letter to Court Regarding Motion Sequences 4 and 9 |
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December 17, 2021 | DECISION + ORDER ON MOTION | ||
December 17, 2021 | NOTICE OF ENTRY | ||
December 15, 2021 |
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #10) Aff. in Reply and Aff. of Service on G&G |
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December 14, 2021 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Court Regarding Motion to Recuse |
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November 22, 2021 |
NOTICE OF APPEAL NOTICES OF APPEAL/INFORMATIONAL STATEMENTS/COPY OF ORDERS/NOTICES OF ENTRIES |
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November 12, 2021 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavits of Service Motion # 12 |
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November 05, 2021 | Notice of Entry March 29, 2021 Order | ||
November 05, 2021 | Notice of Entry December 22, 2020 Order | ||
November 01, 2021 | ORDER TO SHOW CAUSE-SIGNED | ||
October 28, 2021 |
NOTICE OF ENTRY Decision and Order With Notice of Entry |
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October 26, 2021 | NOTICE OF ENTRY | ||
October 25, 2021 |
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #10) Affidavit in Reply as to Rosen, Biggs, and Maynard |
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October 25, 2021 |
ORDER ( PROPOSED ) (Motion #4) Proposed Order MS #4 |
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October 25, 2021 |
ORDER ( PROPOSED ) (Motion #9) Proposed Order MS # 9 |
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October 25, 2021 |
EXHIBIT(S) - A-D (Motion #11) Exhibits A, B, C, D |
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October 25, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #11) Affidavit in Support |
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October 25, 2021 |
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 |
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October 25, 2021 |
DECISION + ORDER ON MOTION (Motion #2) MOTION SEQ. 2, 3 & 8 |
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October 07, 2021 |
EXHIBIT(S) - A (Motion #10) Deft's Nov. 3rd Motion |
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October 07, 2021 |
EXHIBIT(S) - C (Motion #10) Defendant's Reply |
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October 07, 2021 |
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion #10) Affirmation in Opposition |
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October 07, 2021 |
EXHIBIT(S) - B (Motion #10) Co-Defts Mx to Dismiss |
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October 07, 2021 |
EXHIBIT(S) - D (Motion #10) Order Dismissing Co-Deft |
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October 04, 2021 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Justice Rivera Withdrawing Proposed OSC as to Ira D. Gerzog, Esq. |
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September 30, 2021 |
ORDER TO SHOW CAUSE ( PROPOSED ) Proposed Order to Show Cause |
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September 30, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP Affidavit in Support of Proposed OSC |
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September 30, 2021 |
EXHIBIT(S) - AA Emails to Attorneys Erin O'Leary and Joshua Cohen |
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September 30, 2021 |
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 |
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September 27, 2021 | OTHER COURT FILED DOCUMENT | ||
September 24, 2021 | STIPULATION - OTHER | ||
September 24, 2021 | ORDER - OTHER | ||
September 23, 2021 | AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION | ||
September 02, 2021 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Justice Rivera Re: Withdrawl of Branch of Motion with Respect to MCF Defendants |
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September 01, 2021 |
EXHIBIT(S) - A Order to Show Cause Signed by the Hon. Francois Rivera, J.S.C. |
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September 01, 2021 |
EXHIBIT(S) - B Proposed Order dated December 22, 2020 |
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September 01, 2021 |
ORDER TO SHOW CAUSE ( PROPOSED ) Order to Show Cause (Proposed) |
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September 01, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT Affidavit in Support of Motion Pursuant to CPLR 2219; 5019 and 22 NYCRR 202.48 |
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September 01, 2021 |
EXHIBIT(S) - C Transcript of the Proceedings held before the Hon. Francois Rivera, J.S.C. on December 22, 2020. |
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September 01, 2021 |
EXHIBIT(S) - D Order of the Hon. Francois Rivera, J.S.C. dated March 4, 2021 and entered April 1, 2021 |
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July 14, 2021 |
EXHIBIT(S) - 118 (Motion #10) Plaintiff's Aff. in Opp. to Gerzog's Motion and in Support of Sanctions with Supplemental Exhibits |
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July 14, 2021 |
EXHIBIT(S) - 117 (Motion #10) Stipulation Extending Gerzog's Time to Appear (Individually) |
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July 14, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #10) Affidavit in Support of Motion for Default Judgment |
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July 14, 2021 |
EXHIBIT(S) - 138 (Motion #10) Formal Opinion No. 96-Fl2 |
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July 14, 2021 |
EXHIBIT(S) - 139 (Motion #10) Plaintiff's Aff. in Opposition to Goldfarb Defendants Motion to Dismiss with Supplemental Exhibits |
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July 14, 2021 |
NOTICE OF MOTION (Motion #10) Notice of Motion |
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July 14, 2021 |
EXHIBIT(S) - 137 (Motion #10) Bill Jacket, L 1978 ch 640 |
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July 14, 2021 |
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 |
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April 30, 2021 |
NOTICE OF ENTRY (Motion #7) Service of Notice of Entry 202.5-b(h)(2) |
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April 30, 2021 |
NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE Notices of Appeal |
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April 30, 2021 |
NOTICE OF ENTRY (Motion #1) Service of Notice of Entry 202.5-b(h)(2) |
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April 20, 2021 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Justice Rivera Regarding Interm Order Dated March 29, 2021 and Entered March 30, 2021 |
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April 01, 2021 |
ORDER - OTHER (Motion #1) dated 3/4/21 |
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March 30, 2021 | ORDER - OTHER | ||
March 22, 2021 | ORDER - OTHER | ||
March 18, 2021 | ORDER ( PROPOSED ) | ||
March 17, 2021 | AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO CROSS-MOTION AND IN FURTHER SUPPORT OF MOTION | ||
March 17, 2021 | MEMORANDUM OF LAW IN OPPOSITION TO CROSS-MOTION AND IN FURTHER SUPPORT OF MOTION | ||
March 11, 2021 |
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 |
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March 11, 2021 |
EXHIBIT(S) - 120 (Motion #8) Affidavit in Opposition to the Law Offices of Goldfarb & Gerzog's Motion by OSC |
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March 11, 2021 |
EXHIBIT(S) - 123 (Motion #8) Executed General Release |
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March 11, 2021 |
EXHIBIT(S) - 40 (Motion #8) Examination Before Trial Transcript of Christopher Turner, M.D. |
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March 11, 2021 |
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 |
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March 11, 2021 |
EXHIBIT(S) - 41 (Motion #8) Examination Before Trial of Henry Talus, M.D. |
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March 11, 2021 |
EXHIBIT(S) - 93 (Motion #8) Summons and Verified Complaint |
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March 11, 2021 |
EXHIBIT(S) - 128 (Motion #8) Affidavit of Donald Frangipani Certified Forensic Expert |
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March 11, 2021 |
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 |
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March 11, 2021 |
EXHIBIT(S) - 52 (Motion #8) Goldfarb's Letter of June 14, 2019 to Plaintiff Via Certified Mail Return Receipt Requested |
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March 11, 2021 |
EXHIBIT(S) - 127 (Motion #8) Email of June 21, 2019 at 3:55 PM |
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March 11, 2021 |
EXHIBIT(S) - 119 (Motion #8) Affirmation in Support of Spencer Richards, Esq. November 23, 2020 |
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March 11, 2021 |
EXHIBIT(S) - 3 (Motion #8) Text Message Exchange of October 11, 2018 Between Goldfarb and Plaintiff |
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March 11, 2021 |
EXHIBIT(S) - 130 (Motion #8) Reply Affirmation of Caryn Lilling, Esq. of December 16, 2020 |
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March 11, 2021 |
EXHIBIT(S) - 70 (Motion #8) Catherine Patsos', Esq. Letter Dated May 22, 2020 (Informing of USB w Proof of Mailing) |
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March 11, 2021 |
EXHIBIT(S) - 51 (Motion #8) Goldfarb's Letter of February 5, 2019 to Plaintiff Via Certified Mail Return Receipt Requested |
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March 11, 2021 |
EXHIBIT(S) - 136 (Motion #8) Affidavit of Service of EBT Transcript of April 6, 2017 on Christopher Turner, M.D. |
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March 11, 2021 |
EXHIBIT(S) - 39 (Motion #8) Examination Before Trial of Carina Biggs, M.D. |
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March 11, 2021 |
EXHIBIT(S) - 80 (Motion #8) Letter of June 18, 2020 from HHS-OCR to Plaintiff and Patsos |
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March 11, 2021 |
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 |
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March 11, 2021 |
EXHIBIT(S) - 54 (Motion #8) Consent to Change Attorney Forms Goldfarb to Plaintiff, Pro Se |
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March 11, 2021 |
EXHIBIT(S) - 53 (Motion #8) Goldfarbs Letter of June 14, 2019 to Plaintiff Via Certified and Regular Mail |
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March 11, 2021 |
EXHIBIT(S) - 135 (Motion #8) Plaintiff's Affidavit in Reply of February 10, 2021 |
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March 11, 2021 |
EXHIBIT(S) - 131 (Motion #8) Furman Kornfeld & Brennan LLP New York State Bar Association White Paper 2019 |
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March 11, 2021 |
EXHIBIT(S) - 29 (Motion #8) Certified Transcript of Colloquy Between Gerzog and Plaintiff on June 24, 2019 |
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March 11, 2021 |
EXHIBIT(S) - 50 (Motion #8) Goldfarb's Letter of December 18, 2018 to Plaintiff Via FedEx |
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March 11, 2021 |
EXHIBIT(S) - 122 (Motion #8) Plaintiff's Proposed Order to Vacate G&G Order of December 22, 2020 |
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March 11, 2021 |
EXHIBIT(S) - 30 (Motion #8) Retainer Agreement |
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March 11, 2021 |
EXHIBIT(S) - 125 (Motion #8) Furman Affirmation in Support of Motion to Dismiss of February 2, 2021 |
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March 11, 2021 |
EXHIBIT(S) - 78 (Motion #8) Stipulation of Discontinuance with Prejudice filed By Attorney Kivowitz |
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March 11, 2021 |
MEMORANDUM OF LAW IN OPPOSITION (Motion #8) Memorandum of Law |
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March 11, 2021 |
EXHIBIT(S) - 25 (Motion #8) Certified Transcript of Colloquy Between Karen Levine and Plaintiff on Oct. 17, 2018 |
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March 11, 2021 |
EXHIBIT(S) - 19 (Motion #8) Patsos Letter of May 21, 2020 Accompanying Medical Records Provided Pursuant to HHS-OCR Directive |
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March 11, 2021 |
EXHIBIT(S) - 24 (Motion #8) Certified Transcript of Colloquy Between Goldfarb and Plaintiff on Oct. 17, 2018 |
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March 11, 2021 |
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion #8) Affidavit in Opposition to Goldfarb Defendants Motion to Dismiss |
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March 11, 2021 |
EXHIBIT(S) - 27 (Motion #8) Certified Transcript of Colloquy Between Goldfarb and Plaintiff on November 29, 2018 |
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March 11, 2021 |
EXHIBIT(S) - 116 (Motion #8) Denial of Motion by OSC to Remove Goldfarb Due to Case Being Disposed and CPLR 2217 |
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March 11, 2021 |
EXHIBIT(S) - 42 (Motion #8) Examination Before Trial of Muthukumar Muthusamy, M.D. |
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March 11, 2021 |
EXHIBIT(S) - 28 (Motion #8) Certified Transcript of Colloquy Between Karen Levine and Plaintiff on Dec. 12, 2018 |
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March 11, 2021 |
EXHIBIT(S) - 26 (Motion #8) Certified Transcript of Colloquy Between Goldfarb and Plaintiff on Oct. 25, 2018 |
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March 09, 2021 |
ORDER ( PROPOSED ) Proposed Order to Dismiss |
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March 09, 2021 | STATEMENT OF AUTHORIZATION FOR ELECTRONIC FILING | ||
March 03, 2021 |
EXHIBIT(S) - 134 (Motion #5) Web Civil Supreme Case Type COMM-Contract |
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March 03, 2021 |
EXHIBIT(S) - 133 (Motion #5) Plaintiffs Affidavit in Opposition to MCF Defendants Motion to Dismiss of November 17, 2020 |
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March 03, 2021 |
EXHIBIT(S) - 87 (Motion #5) Affirmation in Support of Caryn Lilling, Esq. of October 1, 2020 |
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March 03, 2021 |
EXHIBIT(S) - 130 (Motion #5) Reply Affirmation of Caryn Lilling, Esq. of December 16, 2020 |
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March 03, 2021 |
EXHIBIT(S) - 123 (Motion #5) Executed General Release |
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March 03, 2021 |
EXHIBIT(S) - 78 (Motion #5) Stipulation of Discontinuance |
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March 03, 2021 |
EXHIBIT(S) - 116 (Motion #5) Kings Supreme Court Part 72 / Ex Parte |
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March 03, 2021 |
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #5) Affidavit in Reply |
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March 03, 2021 | AFFIDAVIT OR AFFIRMATION IN REPLY | ||
March 02, 2021 |
EXHIBIT(S) - 132 (Motion #4) Affirmation in Opp. to Plaintiff's Cross-Motion for Sanctions |
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March 02, 2021 |
EXHIBIT(S) - 93 (Motion #4) Summons & Verified Complaint |
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March 02, 2021 |
AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #4) Plaintiff's Affidavit in Reply |
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March 02, 2021 |
EXHIBIT(S) - 78 (Motion #4) Stipulation of Discontinuance |
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March 02, 2021 |
EXHIBIT(S) - 123 (Motion #4) Executed Gnereal Release |
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March 02, 2021 |
EXHIBIT(S) - 88 (Motion #4) Affirmation in Support of Erin O'Leary, Esq of October 15, 2020 |
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March 02, 2021 |
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 |
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March 02, 2021 |
EXHIBIT(S) - 134 (Motion #4) Web Civil Supreme Case Type "COMM-Contract" |
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February 24, 2021 |
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 |
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February 16, 2021 |
NOTICE OF MOTION (Motion #9) Notice of Cross-Motion for Sanctions |
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February 16, 2021 |
EXHIBIT(S) - 124 (Motion #9) Reply Affirmation of Joshua Cohe, Esq. of December 16, 2020 |
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February 16, 2021 |
EXHIBIT(S) - 92 (Motion #9) Affirmation in Support of Joshua Cohen, Esq. of November 3, 2020 |
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February 16, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #9) Plaintiff's Affidavit in Support of Cross-Motion for Sanctions |
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February 16, 2021 |
EXHIBIT(S) - 123 (Motion #9) Executed General Release |
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February 16, 2021 |
EXHIBIT(S) - 129 (Motion #9) Plantiff's Aff. In Opp. to Defs. Rosen's, Biggs', and Maynard's Motion of Nov. 17, 2020 |
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February 10, 2021 | AFFIDAVIT OR AFFIRMATION IN REPLY | ||
February 08, 2021 |
EXHIBIT(S) - 123 Executed General Release |
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February 04, 2021 | ORDER ( PROPOSED ) | ||
February 04, 2021 |
EXHIBIT(S) - A (Motion #7) Gubernatorial Executive Order 202.8 |
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February 04, 2021 |
EXHIBIT(S) - B (Motion #7) Administrative Order 115/20 |
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February 04, 2021 | AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION | ||
February 02, 2021 | MEMORANDUM OF LAW IN SUPPORT | ||
February 02, 2021 |
EXHIBIT(S) - A (Motion #8) Summons & Complaint |
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February 02, 2021 |
EXHIBIT(S) - B (Motion #8) Malpractice Retainer |
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February 02, 2021 | NOTICE OF MOTION (Motion #8) | ||
February 02, 2021 |
EXHIBIT(S) - C (Motion #8) Underlying Complaint |
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February 02, 2021 | AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION | ||
January 21, 2021 |
EXHIBIT(S) - 121 (Motion #7) Goldfarb & Gerzog's Proposed Order |
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January 21, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #7) Affidavit In Support of Motion to Vacate Order of December 22, 2020 |
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January 21, 2021 |
EXHIBIT(S) - 120 (Motion #7) Plaintiff's Affidavit in Opposition |
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January 21, 2021 |
EXHIBIT(S) - 119 (Motion #7) Affirmation in Support of Spencer Richards, Esq. of Nov. 23, 2020 |
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January 21, 2021 | NOTICE OF MOTION | ||
January 21, 2021 |
EXHIBIT(S) - 101 (Motion #7) Administrative Orders of Chief Administrative Judge Lawrence Marks 115/20 |
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January 21, 2021 |
EXHIBIT(S) - 122 (Motion #7) Plaintiff's Proposed Order Vacating the Order of December 22, 2020 |
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January 14, 2021 | hearing |
(Motion #002) MOTION TRIAL TERM 52 ADM Judge: FRANCOIS A. RIVERA (PT. 52) |
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January 14, 2021 | hearing |
(Motion #001) MOTION TRIAL TERM 52 ADM Judge: FRANCOIS A. RIVERA (PT. 52) |
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December 17, 2020 | hearing |
(Motion #005) MOTION TRIAL TERM 52 Judge: FRANCOIS A. RIVERA (PT. 52) |
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December 17, 2020 | hearing |
(Motion #003) MOTION TRIAL TERM 52 Judge: FRANCOIS A. RIVERA (PT. 52) |
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December 17, 2020 | hearing |
(Motion #004) MOTION TRIAL TERM 52 Judge: FRANCOIS A. RIVERA (PT. 52) |
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December 03, 2020 | hearing |
ADJOURNED (Motion #003) SUBSEQUENT MOTION PART Judge: FRANCOIS A. RIVERA (PT. 52) |
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December 03, 2020 | hearing |
ADJOURNED (Motion #005) SUBSEQUENT MOTION PART Judge: FRANCOIS A. RIVERA (PT. 52) |
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December 03, 2020 | hearing |
ADJOURNED (Motion #004) SUBSEQUENT MOTION PART Judge: FRANCOIS A. RIVERA (PT. 52) |
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December 03, 2020 | hearing |
ADJOURNED (Motion #002) MOTION TRIAL TERM 52 ADM Judge: FRANCOIS A. RIVERA (PT. 52) |
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December 03, 2020 | hearing |
ADJOURNED (Motion #001) MOTION TRIAL TERM 52 ADM Judge: FRANCOIS A. RIVERA (PT. 52) |
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November 19, 2020 | hearing |
ADJOURNED (Motion #002) SUBSEQUENT MOTION PART Judge: FRANCOIS A. RIVERA (PT. 52) |
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November 19, 2020 | hearing |
ADJOURNED (Motion #001) MOTION PART Judge: FRANCOIS A. RIVERA (PT. 52) |
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November 18, 2020 | Motion |
SANCTIONS (Motion #004) Before Justice: FRANCOIS A\. RIVERA (PT. 52) Answer demanded: Yes Judge: FRANCOIS A. RIVERA (PT. 52) |
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November 18, 2020 | Motion |
SANCTIONS (Motion #005) Before Justice: FRANCOIS A\. RIVERA (PT. 52) Answer demanded: Yes Judge: FRANCOIS A. RIVERA (PT. 52) |
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November 04, 2020 | Motion |
DISMISS (Motion #003) Before Justice: FRANCOIS A\. RIVERA (PT. 52) Answer demanded: Yes Judge: FRANCOIS A. RIVERA (PT. 52) |
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October 16, 2020 | Motion |
DISMISS (Motion #002) Before Justice: FRANCOIS A\. RIVERA (PT. 52) Answer demanded: Yes Judge: FRANCOIS A. RIVERA (PT. 52) |
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October 02, 2020 | Motion |
DISMISS (Motion #001) Before Justice: FRANCOIS A\. RIVERA (PT. 52) Answer demanded: Yes Judge: FRANCOIS A. RIVERA (PT. 52) |
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August 17, 2020 | Docket Event |
LETTER / CORRESPONDENCE TO JUDGE Letter requesting extension of time to respond to complaint |
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August 11, 2020 | Docket Event |
AFFIRMATION/AFFIDAVIT OF SERVICE Carina Biggs, M.D. |
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August 07, 2020 | Docket Event |
AFFIRMATION/AFFIDAVIT OF SERVICE Karen Levine / Proof of Delivery / 8/20/2020 |
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August 07, 2020 | Docket Event |
AFFIRMATION/AFFIDAVIT OF SERVICE Steven M. Goldfarb, Esq., Goldfarb & Gerzog, and the Law Offices of Steven M. Goldfarb / Proof of De |
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July 28, 2020 | Docket Event |
AFFIRMATION/AFFIDAVIT OF SERVICE Ira D. Gerzog, Esq. and Goldfarb & Gerzog |
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July 28, 2020 | Docket Event |
AFFIRMATION/AFFIDAVIT OF SERVICE McAloon & Friedman, P.C. |
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July 26, 2020 | Docket Event |
EXHIBIT(S) - 80 Letter of June 18, 2020 from HHS-OCR to Plaintiff and Patsos Advising of the Closing of Investigatio |
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July 26, 2020 | Docket Event |
EXHIBIT(S) - 20D Medical Records Reproduced by NYCHHC/KCHC Pursuant to OCR Directive (Scanned Hard Copies) |
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July 24, 2020 | Docket Event |
EXHIBIT(S) - 79 NYCHHC No Fee Authorization Letter to County Clerk filed by Attorney Kivowitz |
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July 24, 2020 | Docket Event |
EXHIBIT(S) - 78 Stipulation of Discontinuance with Prejudice filed By Attorney Kivowitz |
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June 23, 2020 | Docket Event |
EXHIBIT(S) - 20C Medical Records Reproduced on 05/19/2020 by NYCHHC/KCHC Pursuant to OCR Directive (Encrypted USB) |
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June 23, 2020 | Docket Event |
EXHIBIT(S) - 20B Medical Records Reproduced on 05/19/2020 by NYCHHC/KCHC Pursuant to OCR Directive (Encrypted USB) |
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June 22, 2020 | Docket Event |
EXHIBIT(S) - 20A Medical Records Reproduced on 05/19/2020 by NYCHHC/KCHC Pursuant to OCR Directive (Encrypted USB) |
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June 20, 2020 | Docket Event |
EXHIBIT(S) - 75 Plaintiff's Response to Combined Demands |
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June 20, 2020 | Docket Event |
EXHIBIT(S) - 74 NYCHHC/KCHC/M&F "Accounting of Disclosures" Styled as an "Accounting of Records" |
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June 20, 2020 | Docket Event |
EXHIBIT(S) - 73 Plaintiff's June 5, 2020 letter to Catherine Patsos, Esq. w Proof of Mailing |
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June 20, 2020 | Docket Event |
EXHIBIT(S) - 72 Plaintiff's June 3, 2020 Letter to Catherine Patsos, Esq. w Proof of Mailing |
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June 20, 2020 | Docket Event |
EXHIBIT(S) - 76 KCHC Consent Forms Provided Pursuant to OCR Directive |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 71 Catherine Patsos', Esq. Letter Dated May 22, 2020 (Informing of Password w Proof of Mailing) |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 70 Catherine Patsos', Esq. Letter Dated May 22, 2020 (Informing of USB w Proof of Mailing) |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 69 Email of January 22, 2019 From Plaintiff to LOSMG Headed "Happy New Year to all!" |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 68 Email Series of Dec. 12, 2018-Dec. 14, 2018 Headed "Documents" |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 67 Email of November 30, 2018 From Plaintiff to LOSMG Headed "Followup of Conversation of November 29, |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 66 Email of Nov. 26, 2018 From Plaintiff to Goldfarb and Gerzog Headed "Preliminary Statement of Profes |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 65 Email of Nov. 19, 2018 From Plaintiff to the LOSMG Headed "Outstanding requested documents" |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 64 Email of Nov. 8, 2018-Nov. 9, 2018 From Plaintiff to LOSMG Headed "Documents request reminder" |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 63 Note of Issue, Index No.: 500113/2015 |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 62 Notice of Medical Malpractice |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 61 Verified Answer of NYCHHC |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 60 Verified Answer of Muthukumar Muthusamy, M.D. |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 59 Verified Answer of Henry Talus, M.D. |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 58 Verified Answer of Christopher Turner, M.D. |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 57 Verified Answer of Carina Biggs, M.D. |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 56 Underlying Summons and Verified Complaint, Index No.: 500113/2015 |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 55 Plaintiff's Email of Dec. 11, 2018 to Goldfarb Headed "I need to speak with you!" |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 54 Consent to Change of Attorneys from LOSMG to Plaintiff Attorney Pro Se |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 53 Goldfarb's Letter of June 14, 2019 to Plaintiff Via Regular Mail |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 52 Goldfarb's Letter of June 14, 2019 to Plaintiff Via Certified Mail Return Receipt Requested |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 51 Goldfarb's Letter of February 5, 2018 to Plaintiff Via Certified Mail Return Receipt Requested |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 50 Goldfarb's Letter of December 18, 2018 to Plaintiff Via FedEx |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 49 Consent to Change of Attorneys G&G to the LOSMG |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 48 Goldfarb's Letter of July 23, 2018 to Plaintiff |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 47 Email of June 22, 2018 From Plaintiff to Goldfarb Headed "Continuation of Representation" |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 46 Series of Emails of June 3, 2018 Between Plaintiff and Gerzog Headed "Hello" |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 45 Firm Overview of M&F |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 44 Firm Overview of the LOSMG |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 43 Firm Overview of G&G |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 42 Examination Before Trial of Muthukumar Muthusamy, M.D. |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 41 Examination Before Trial of Henry Talus, M.D. |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 40 Examination Before Trial of Christopher Turner, M.D. |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 39 Examination Before Trial of Carina Biggs, M.D. |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 38 Transcript of Proceedings of July 10, 2018 - Gerzog v Goldfarb, Index No. 653432/2018 (Sup. Ct. NY C |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 37 Goldfarb Aff. of August 7, 2018 |
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June 19, 2020 | Docket Event |
EXHIBIT(S) - 36 Gerzog Aff. of August 27, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 35 Gerzog Aff. of July 9, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 34 Levine Aff. of August 2, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 33 Dinhofer Aff. of August 1, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 32 General Release |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 31 LOSMG'S Disbursements Sheet |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 30 Malpractice Retainer Agreement (G&G) |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 29 Certified Transcript of Colloquy Between Gerzog and Plaintiff on June 24, 2019 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 28 Certified Transcript of Colloquy Between Karen Levine and Plaintiff on December 12, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 27 Certified Transcript of Colloquy Between Goldfarb and Plaintiff on November 29, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 26 Certified Transcript of Colloquy Between Goldfarb and Plaintiff on October 25, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 25 Certified Transcript of Colloquy Between Karen Levine and Plaintiff on or About October 17, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 23 Certified Transcript of Colloquy Between Goldfarb and Plaintiff on October 17, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 23 Kings County Hospital Center Nursing Discharge Summary of August 29, 2013 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 22 Certified Ambulance Call Report of 07/09/2013 Reproduced by FDNY on 7/14/2014 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 21 Ambulance Call Report of 07/09/2013 Provided by NYCHHC/KCHC Pursuant to OCR Directive |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 19 Patsos Letter of April 21, 2020 Accompanying Medical Records Provided Pursuant to HHS-OCR Directive |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 18 Medical Records Reproduced by NYCHHC/KCHC on March 1, 2019 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 17 Medical Records Reproduced by NYCHHC/KCHC on February 12, 2019 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 16 Medical Records Reproduced by NYCHHC/KCHC on January 22, 2019 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 15 Certified Operative Report of 07/09/2013 Reproduced on November 1, 2016 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 14 Certified Pathology Report Reproduced on July 28, 2014 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 13 LOSMG'S Email of November 20, 2018 to Plaintiff |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 12 Pathology Report Reproduced by NYCHHC/KCHC on June 13, 2014 Produced by Goldfarb on October 17, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 11 Medical Records reproduced by NYCHHC/KCHC on June 13, 2014 Produced by Goldfarb on October 17, 2018 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 10 Email Series of October 17, 2018 from LOSMG to Plaintiff Headed "Kings County Records" |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 9 Actual Discharge Summary of August 29, 2013 |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 8 Email of October 17, 2018 from LOSMG to Plaintiff Headed "Transcripts" |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 7 Medical Records Reproduced by NYCHHC/KCHC on 12/3/2013 (sent to NYSOTDA/SSA) |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 6 Goldfarb's Memorandum of Termination With Cause |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 5 Email Series of October 12, 2018 From Plaintiff to LOSMG |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 4 Email of October 11, 2018 From Plaintiff to the LOSMG |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 3 Text Message Exchange of October 11, 2018 Between Goldfarb and Plaintiff |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 2 Email Series of May 22, 2017 Headed "Hi" |
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June 18, 2020 | Docket Event |
EXHIBIT(S) - 1 Email of March 27, 2017 from Plaintiff to Goldfarb & Gerzog |
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March 20, 2020 | Docket Event | SUMMONS + COMPLAINT |