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FILED: QUEENS COUNTY CLERK 08/30/2021 10:35 AM INDEX NO. 706444/2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/30/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
MARK A. COTOIA,
Plaintiff(s)
DEMAND FOR DISCOVERY
- against -
Index No.: 706444/2021
MARIA E. ARIAS,
Defendant(s)
PLEASE TAKE NOTICE that pursuant to the applicable Rules, you are hereby required to
serve the following upon the undersigned within twenty (20) days after receipt of this notice:
A. Duly executed, current and acknowledged HIPAA Compliant authorizations with records
enabling FERRO & STENZ to obtain all applicable records from the following:
• Village Chiropractic Queens
• Industrial Physical Therapy, Inc.
• Dr. Aron Rovner, M.D., FAAOS
• Spreemo Radiology
• Nickhil Gupta, D.O. / Interventional Spine and MSK Specialist
• Alexandr Khaimov, D.O. / Quality Orthopedics and Complete Joint Care
• Employer’s Ins. – Zurich American Ins. Co.
• Plaintiff’s Primary Care Physician
• Ambulance Call Report
• Pharmacy records
B. Duly executed, current and acknowledged authorization enabling FERRO & STENZ to
obtain employment records; including, but not limited to attendance records, employment
application, W-2, physical limitations and any medical or nurse’s file from two years prior
to date of loss until present, from Schindler Elevator Corporation.
C. Duly executed, current, and acknowledged HIPAA Compliant authorizations with records
enabling FERRO & STENZ to obtain all applicable records from Plaintiff’s prior loss of
March 19, 2016. Please be advised the authorizations should include, but not be limited to:
• No-fault file
• Medical records including but not limited to all medical providers, diagnostic
exams, MRIs, x- rays, hospitals, no-fault file records, emergency room records,
physical therapy records, acupuncture records, cat scans, doctor’s notes, surgical
records, pharmacy records, and ambulance call report.
• Legal records including all pleadings, transcripts, and Verified Bill of Particulars.
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FILED: QUEENS COUNTY CLERK 08/30/2021 10:35 AM INDEX NO. 706444/2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/30/2021
D. Duly executed, current, and acknowledged HIPAA Compliant authorizations with records
enabling FERRO & STENZ to obtain all applicable records from Plaintiff’s prior loss of
July 1, 1998. Please be advised the authorizations should include, but not be limited to:
• No-fault file
• Medical records including but not limited to all medical providers, diagnostic
exams, MRIs, x- rays, hospitals, no-fault file records, emergency room records,
physical therapy records, acupuncture records, cat scans, doctor’s notes, surgical
records, pharmacy records, and ambulance call report.
• Legal records including all pleadings, transcripts, and Verified Bill of Particulars.
If any of the above cannot be provided plaintiff will provide an affidavit
stating same, including why such cannot be provided.
PLEASE TAKE FURTHER NOTICE that this is a continuing demand and should any of
the above requested information become available to or known in the future, you are then required
to furnish same at such time.
DATED: Westbury, New York
August 25, 2021
Yours, etc.
_______________________________________
Barbie McAleavey, Esq.
FERRO & STENZ
Attorneys for Defendant(s)
Maria Arias
875 Merrick Avenue,
Westbury, N 11590-6603
516-229-4229
516-229-4203
bmcaleavey@geico.com
Our File Number: 21-0060866
Claim Number: 0337348510101030 (J013)
TO:
Scott Baron & Associates, P.C.
Attorneys for Plaintiff(s)
159-49 Crossbay Boulevard
Howard Beach, NY 11414
718-738-9800
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FILED: QUEENS COUNTY CLERK 08/30/2021 10:35 AM INDEX NO. 706444/2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/30/2021
Index No.: 706444/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
MARK A. COTOIA,
Plaintiff(s)
- against - DEMAND FOR DISCOVERY
MARIA E. ARIAS,
Defendant(s)
FERRO & STENZ
Attorneys for the Defendant(s)
Maria Arias
875 Merrick Avenue,
Westbury, NY 11590-6603
516-229-4229
------------------------------------------------------------------------------------------------------------------------
TO:
Scott Baron & Associates, P.C.
Attorneys for Plaintiff(s)
159-49 Crossbay Boulevard
Howard Beach, NY 11414
718-738-9800
------------------------------------------------------------------------------------------------------------------------
Due and timely service of a copy of the within DEMAND FOR DISCOVERY is hereby admitted.
Dated August 25, 2021
Attorney(s) for Defendant Maria Arias
------------------------------------------------------------------------------------------------------------------------
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Preview
FILED: QUEENS COUNTY CLERK 08/30/2021 10:35 AM INDEX NO. 706444/2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/30/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS MARK A. COTOIA, Plaintiff(s) DEMAND FOR DISCOVERY - against - Index No.: 706444/2021 MARIA E. ARIAS, Defendant(s) PLEASE TAKE NOTICE that pursuant to the applicable Rules, you are hereby required to serve the following upon the undersigned within twenty (20) days after receipt of this notice: A. Duly executed, current and acknowledged HIPAA Compliant authorizations with records enabling FERRO & STENZ to obtain all applicable records from the following: • Village Chiropractic Queens • Industrial Physical Therapy, Inc. • Dr. Aron Rovner, M.D., FAAOS • Spreemo Radiology • Nickhil Gupta, D.O. / Interventional Spine and MSK Specialist • Alexandr Khaimov, D.O. / Quality Orthopedics and Complete Joint Care • Employer’s Ins. – Zurich American Ins. Co. • Plaintiff’s Primary Care Physician • Ambulance Call Report • Pharmacy records B. Duly executed, current and acknowledged authorization enabling FERRO & STENZ to obtain employment records; including, but not limited to attendance records, employment application, W-2, physical limitations and any medical or nurse’s file from two years prior to date of loss until present, from Schindler Elevator Corporation. C. Duly executed, current, and acknowledged HIPAA Compliant authorizations with records enabling FERRO & STENZ to obtain all applicable records from Plaintiff’s prior loss of March 19, 2016. Please be advised the authorizations should include, but not be limited to: • No-fault file • Medical records including but not limited to all medical providers, diagnostic exams, MRIs, x- rays, hospitals, no-fault file records, emergency room records, physical therapy records, acupuncture records, cat scans, doctor’s notes, surgical records, pharmacy records, and ambulance call report. • Legal records including all pleadings, transcripts, and Verified Bill of Particulars. 1 of 3 FILED: QUEENS COUNTY CLERK 08/30/2021 10:35 AM INDEX NO. 706444/2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/30/2021 D. Duly executed, current, and acknowledged HIPAA Compliant authorizations with records enabling FERRO & STENZ to obtain all applicable records from Plaintiff’s prior loss of July 1, 1998. Please be advised the authorizations should include, but not be limited to: • No-fault file • Medical records including but not limited to all medical providers, diagnostic exams, MRIs, x- rays, hospitals, no-fault file records, emergency room records, physical therapy records, acupuncture records, cat scans, doctor’s notes, surgical records, pharmacy records, and ambulance call report. • Legal records including all pleadings, transcripts, and Verified Bill of Particulars. If any of the above cannot be provided plaintiff will provide an affidavit stating same, including why such cannot be provided. PLEASE TAKE FURTHER NOTICE that this is a continuing demand and should any of the above requested information become available to or known in the future, you are then required to furnish same at such time. DATED: Westbury, New York August 25, 2021 Yours, etc. _______________________________________ Barbie McAleavey, Esq. FERRO & STENZ Attorneys for Defendant(s) Maria Arias 875 Merrick Avenue, Westbury, N 11590-6603 516-229-4229 516-229-4203 bmcaleavey@geico.com Our File Number: 21-0060866 Claim Number: 0337348510101030 (J013) TO: Scott Baron & Associates, P.C. Attorneys for Plaintiff(s) 159-49 Crossbay Boulevard Howard Beach, NY 11414 718-738-9800 2 of 3 FILED: QUEENS COUNTY CLERK 08/30/2021 10:35 AM INDEX NO. 706444/2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/30/2021 Index No.: 706444/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS MARK A. COTOIA, Plaintiff(s) - against - DEMAND FOR DISCOVERY MARIA E. ARIAS, Defendant(s) FERRO & STENZ Attorneys for the Defendant(s) Maria Arias 875 Merrick Avenue, Westbury, NY 11590-6603 516-229-4229 ------------------------------------------------------------------------------------------------------------------------ TO: Scott Baron & Associates, P.C. Attorneys for Plaintiff(s) 159-49 Crossbay Boulevard Howard Beach, NY 11414 718-738-9800 ------------------------------------------------------------------------------------------------------------------------ Due and timely service of a copy of the within DEMAND FOR DISCOVERY is hereby admitted. Dated August 25, 2021 Attorney(s) for Defendant Maria Arias ------------------------------------------------------------------------------------------------------------------------ 3 of 3