SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
---x Index No. 155999/2017
JAIME CARSON,
NOTICE TO PRODUCE
Plaintiff,
- against -
JAD REALTY, LLC and CASA PIZZA, INC.,
Defendants, ---______---____________--___________---X
PLEASE TAKE NOTICE, that the Defendant, CASA PIZZA, INC., by its
attorneys, LAW OFFICES OF MICHAEL E. PRESSMAN, pursuant to the CPLR
and Uniform Court Rules, hereby demands that the Plaintiff provide a
Response to this Notice to Produce within thirty (30) days of receipt of this
Notice at 125 Maiden Lane, 17th
Floor, New York, New York 10038, the
following:
1. HIPAA complaint authorizations for plaintiff's medical records and
radiology films held by her primary care physician from the date of accident
to the present pursuant to her testimony at her deposition that she was
examined by her primary care physician in relation to the subject accident;
2. HIPAA complaint authorizations for plaintiff's medical records and
radiology films held by Dr. Cloey Godwin-Gorga from the date of accident to
the present pursuant to her testimony at her deposition that she was
examined by the aforementioned medical provider in relation to the subject
accident;
3. HIPAA complaint authorizations for plaintiff's medical records and
radiology films held by Mohawk Valley Medical from the date of accident to
the present pursuant to her testimony at her deposition that she received
treatment at this facility in the aftermath of the subject accident and in relation
thereto;
4. HIPAA complaint authorizations for plaintiff's acupuncture records
and radiology films held by her acupuncture provider from the date of accident
to the present pursuant to her testimony at her deposition that received
treatment in the aftermath of the subject accident and in relation thereto;
5. HIPAA complaint authorizations for plaintiff's ambulance/EMS
records from the date of accident to the present pursuant to her testimony at
her deposition that she was taken to the emergency room via ambulance;
6. HIPAA complaint authorizations for plaintiff's Pre-Hospital Care
Report Summary from the date of accident to the present pursuant to her
testimony at her deposition that she was taken to the emergency room via
ambulance;
7. Records of all appointments held by Carson Skin Rejuvenation
from 2015 through 2019;
8. Records of any correspondence the plaintiff forwarded to her
customers during the post-accident period indicating she was limited from
accepting or unable to accept appointments;
9. Any and all IRS records documenting the income of Carson Skin
Rejuvenation for the years 2015 through 2019;
10. Any and all financial records documenting the income of Carson
Skin Rejuvenation for the years 2015 through 2019;
11. Any and all financial records documenting the income of the
plaintiff Jamie Carson for the years 2015 through 2019;
12. Any and all photographs, posts and messages on the plaintiff's
social media accounts from the date of the accident to the present;
13. Any and all photographs, posts and messages on the plaintiff's
social media business accounts from the date of the accident to the present;
14. Any and all photographs, posts and messages on Carson Skin
Rejuvenation's social media accounts from the date of the accident to the
present;
15. Any and all documentation and/or records held by Carson Skin
Rejuvenation regarding or describing appointments held from the date of the
accident to the present;
16. Documentation regarding the amount of any liens to which
plaintiff's potential recovery in this action is subject;
17. HIPAA compliant authorizations for any and all medical providers
with whom the plaintiff has treated in the aftermath of the subject accident;
18. HIPAA compliant authorizations for any and all medical providers
with whom the plaintiff has treated for left ankle pain in the aftermath of the
subject accident;
19. HIPAA compliant authorizations for any and all medical providers
with whom the plaintiff has treated for pain in the bottom of her left foot in
the aftermath of the subject accident;
20. A copy of plaintiff's gym membership from Crunch Fitness,
including the date of initiation and the date when membership was
terminated;
21. A copy of plaintiff's gym membership from Equinox Gym, including
the date of initiation and the date when membership was terminated;
22. A copy of plaintiff's gym membership from any gym where the
plaintiff was a member from January 1, 2015 until the present, including the
date of initiation and the date when membership was terminated;
23, HIPAA compliant authorizations for plaintiff's records held by
OSCAR from the date of plaintiff's alleged accident to the present;
24. HIPAA compliant authorizations for plaintiff's medical records and
films held by the physical therapy clinic at Mount Sinai Hospital from the date
of the accident to the present;
25. Any and all documentation in plaintiff's possession which she
intends to submit in support of her claim for special damages at the time of
trial;
26. Any and all documentation in plaintiff's possession which she
intends to submit in support of her claim for lost wages at the time of trial;
27. Any and all documentation in plaintiff's possession which she
intends to submit in support of her claim for out of pocket expenses at the
time of trial;
28. HIPAA compliant authorizations for plaintiff's records held by any
pharmacy which filled prescriptions for treatment related to the subject
accident.
PLEASE TAKE FURTHER NOTICE, that in the event of your failure to
respond to this Demand, you may be precluded from offering any testimony
with regard to the contents thereof.
Dated: New York, New York
August 22, 2019
By:
P RIbK R OLP
W OF I ES OF
MICHAE E. P ESSMAN
Attorneys for Defendant
CASA PIZZA, INC.
125 Maiden Lane, 17th Floor
New York, New York 10038
(212) 480-3030
File No: AM 15672 PRB/st/902526
TO:
Law Offices of Alan S. Friedman, Esq.
875 6th Ave - Suite 1802
New York, New York 10001
Attn: Alan S. Friedman, Esq.
Wilson Elser Moskowitz Edelman & Dicker LLP
150 East 42nd Street
New York, New York 10017
Attn: Gregory P. Regensburg, Esq.
RIDER
Law Offices of Alan S. Friedman, Esq.
875 6th Ave - Suite 1802
New York, New York 10001
Wilson Elser Moskowitz Edelman & Dicker LLP
150 East 42nd Street
New York, New York 10017
