Preview
FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019
NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024
FILED
COURTOFTHESTATEOF NEWYORK/QUEENSCOUNTY
SUPREME JUN 1 0 2024
SOLOMON
SHANY Plaintiff Index No. 702220/2019 COUNTYCLERK
QUEENSCOUNY
-against- RESPONDTO DEMANDIV
REGOPARKVENTURES,LLC
.A&E REAL ESTATEHOLDING, LLC
.A&E REAL ESTATEMANAGEMENT,
LLC
.LOUIS CUTRI Defendants 7019 0160 0000 2377 0377
Please take notice that plaintiff is responding to demand for medical records.
1. This demand, find plaintiff in time of serious health vision condition, therefore could not
defendants'
respond in 30 days. Plaintiff email to Court and attorney for the
circumstances, with attached medical record as support.
2. Plaintiff repeat it here, in this respond. On 4/14/24 Plaintiff were in Hospital Northwell,
for lost vision on LEFTeye (Plaintiff is blind on right eye, for decade). The diagnosed is
CORNEALABRESION, LEFT. Plaintiff follow primary doctor had homesteaded)
(Plaintiff
had referral to eye dr. Uliss, appointment 5/1/24. By that time the vision came back but
could not read. new glasses. Took long time to approved it by
Dr. Uliss prescribed
insurance and by end of May got new reading glasses. On 5/30/24 I sent the email to
Court and Mr. Halkias, with attach document.
3. Took metime to find the addresses of doctors and others, till today 6/2/24, and I have
20 signed authorizations demanded. I amsending those tomorrow with certify mail
as
also fax to to law firm 212-944-5818. ALL THENEEDOF MEDICALRECORDS ANDOTHER
DEMND,AREIN E-FILED DURINGTHEYEARS,INCLUDE THEEDUCATIONDIPLOMASOF
PLAINTIFF (ATTACHTO TWOEXHIBITS A TO Z, WITH ALL WHAT DEFENDANTNEED, AS
OVER3000 DOCUMENTS BEENE-FILED.
4. Plaintiff sent on 5/30/24 thirteen emails to Mr. Halkias, (copy to Court) with about 6
pictures in each (Limit sending in one shot. So, about 78 pictures sent. Any way, plaintiff
going to e-file all the pictures about 350, that plaintiff paid to copy the pictures with
color, and cost over $600 to be able to e-file it) The original pictures kept for trial.
5. Plaintiff retired at age 65, and his rent is freeze to $759.33 since age 62 and also because
disability. Plaintiff have Medicare by HEALTH FIRST (given authorization of record),
Member I.D. 135831035 and have Medicaid TW31995T (attach copy of insurance both)
with payment out of pocket exceeded income to Medicaid, and out of pocket for
for
medications. The total out of pocket for Medicare in 2023 was about $1400. At present
time the only income is from social security. Was$986/month and increased every year
a little.
6. Plaintiff was working part time, 3 hours a week, as Rabbi in Sephardic synagogue. On
2014 retired. Since the Rabbi of synagogue passed away, the synagogue hired two
Rabbis to avoid closing door. Plaintiff work 6 Hours a month. (2 Sabbath for 3 hours in
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morning) to help with little payment. (attach record authorization demand). On 2023
synagogue find replacement to Rabbi Shany. Therefore Plaintiff no longer helping the
synagogue, and left income of social security monthly.
7. Regards the Court against tenants #2L as demand, attach the index number document
of Court 701050/2020 against both tenants #2L, who were causing over 3S00 times at
night times excessive noises and 311/911 calls E- filed in Court, It is public record so you
can see what is in, still active.
8. On 2022 was issue with tenants #1K as was demand for the arrest. The original tenant
Steve Sultan, gave his young people (about 25 age) to live in. On
apartment for 2
1/21/22 they installed recording camera on top of #1G, pointing recording 24/7 towards
#1L (illegally, and landlord sent warning to remove it in 10 days, but IT WASTILL
SEPTEMBER 2022 ON, REGARDLESS ). Both tenants #1K, were from different country
(Hurop), they were making noises every night, loud music and to harass #1L, they were
banging on the share wall of bedrooms, and kicking it at midnights. 311/911calls and
reporting to landlord, been ignored. On 3/22/22 both tenants #1K kicking several times
in 3 hours at midnight. They bank on our door too. As Plaintiff open door, they threat
with metal to hit plaintiff. Plaintiff called 3 times 911in 3 hours for help since midnight
till 3 am. In one point the tenant was ready with loptop to record, and behind him, stood
other one waiving a knife. Tatiana Shany saw it (we have monitor in), and to defense
cane to spray, had to use to avoid the man
fruf
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NOTE:THEPRINTED INTERUPTED, TO SAVE PAGESBEENPRINTED ANDSTARTNEWONE.
8. Continue: Because the mosquito spray (that was China product and even could not kill a
fly, was like water with smell only, and we used glue stick instead at home), the police arrest
Plaintiff with desk appearance. The case after 6 month, dismissed and sealed. (Lawyer of legal
aid, got the copy of the sealed arrest for housing case she handled). Plaintiff filed against both
police a lawsuit for FALSEARREST case attached with the arrest paper. The tenant #1K kicked
the shared between our apartments, and caused damage that the wall broke all over, on
wall
3/22/22 from midnight to 3 am, the wall kicked constantly and damaged and police refused to
deal with it excuse "report to landlord it is not crime. The fact it was in violation and Plaintiff
paid $700 to repair the wall as landlord refused to. Plaintiff took picture of the wall damage
before and after repaired. Landlord done nothing to force the recording camera 24/7 on for 9
months, and on 3/28/24 by this camera, follow meoutside the building while walking on
64th
you"
Rd, #1K tenant kick Plaintiff cane, while say "I will kill and fell on sidewalk and was in
Hospital, It is active. Landlord discriminate Plaintiff, by let #1K, having recording camera 24/7,
HOLDOVERagainst Plaintiff for MONITOR(not recording),
while he filed that legally installed on
2012 by CONSENTof previous landlord, and the fact is, THATON2024 LANDLORDGAVE
PERMISSIONTHE MONITOR TO STAYONBY AGREEMENT THATPLAINTIFF VAIWE WAS
HARASSMENT CASEAGAINSTLANDLORD.(Because landlord found defense of receipt paid on
2012 with consent of previous landlord, in trial they would lose the case).
9. Regard the fall on sidewalk of the landlord property. The pictures of the sidewalk after falling
and the time of repair (was year later repair, regardless of letter sent to landlord (in e-file) , will
file among rest of pictures. Plaintiff live at present address since 1982. Used to go right from
exit building at beginning towards 99 st. Since around 2015, after surgery start walk with cane,
and never walk to from building exit, but to left toward 102 st.
right Also walk on 102 street up
64th Rd.
to Queens Blvd, to bus station Q60. NEVERwalk on towards 99 at. One late time of
evening Plaintiff had to officiate at memorial service for congregant, in restaurant Bukharian,
located on 99th street near 66. Plaintiff had dizziness, but could walk with his walker to officiate.
64th Rd.
Plaintiff was walking on towards 99th street, and suddenly, the walker stock by sidewalk
ground, and plaintiff fell forward twice circle to the floor, and could not move as knee pain. A
said"
nurse by chance heard it, and run to Plaintiff I ama nurse, come to help you, do not try
I
to move, I callwas taking by Ambulance to flushing.
911. I Whenwas home went to see the
2"
sidewalk, why I fell? I saw the sidewalk GAPfrom other. I notice the BlG tree that roots might
raised the sidewalk, and I did not know ahead of time. Was surprised to me, as before 2015 I
2"
was walking through. The building should know the GAP, and did nothing. Even after writing
to landlord, done nothing, and plaintiff forced report to 311 latter on, past year, finally I saw
construction block with yellow tape the sidewalk and I took picture. Pass long time from
evening Plaintiff fell to date of repair. IT IS NEGLIGENCE!
10.THEALL DOCUMENTS AS DEMAND
AREEXICT IN FILE ALREADYINCLUDEALL THE477
AMONG
LETTERS, LETTEROFSIDEWALKWARNING IT. ATTACHEXHIBITSANDALL THE
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DOCUMENTS BEENE-FILED. THEHOUSINGCOURTHPD9 CASESAREPUBLIC RECORDS INCLUDE
THE MOLDVIOLATIONS IN EACHCASE, SOTHE INSPECTORSBE A WITNESSTOTHE MOLDEXIST
IN #1L FOROVER8 YEARS
11. The witnesses as mention in deposition were tenant #2K to MOLDand noises by #2L, as well
tenant #3L with his letter sent to landlord attach to plaintiff letter, exist in file. Tatiana Shany is
witness to EVERYTHING IN THIS CASE, INCLUDE MOLD, LEAKING, HARASSMENT,
NOlSESAT
NIGHTSBY #2L, ANDWHATEVERWITH #1K.
12. if any thing is missing I will try to look on, but now need to transfer the authorization for
record immediately. ONCEalready landlord lawyer got authorization for records before 2017,
and they got it. Now another lawyer took over and asking second time the same medical
records. Most of it, include Hospitals are exist in file, as Brunswick Hospital the all records in e-
file. If the lawyer read the over 3000 documents in file, he get the answer there. Therefore, I
go immediately to records. MANYYEARSPASS, ANDI PUT
stop this respond here, to let it
PHONENUMBER
OF DOCTOR,IF I KNOW,TO LOCATETHE ADDRESS,AS MANYYEARSPASSAND
DR. COLLINS MOVED
3 TIMESALREADY.ORWILL BE HARDTO FIND FROMYEARSPAST.
RECORDS
BUTALL IN FILE ALREADY.
Sworn to before meon...Î....day of June 2024 SOLOMON
SHANY
ISKHAKOV
YAKUBSHOLOM
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FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019
NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024
CONFIDENTIAL PATIENT DISCHARGE
INSTRUCTIONS CONFIDENTIAL
NorthweH su4my,so1omom
Date of Birth: 5/15/1946
Long island Jewish Forest Hills MRN/VisitlD: 95554/1681354245
102-01 66th Road, Forest Hills, NY1137s
Emergency Department: p18) 830-4200-northwelledu
Date of Service: 04/14/2024 Principal Discharge Diagnosis: Corneal abrasion, left
The following providers were involved In your care: Max Lazarus (DO)
Thank you for choosing Northwell Health to provide care
You have choices when it comes to care. As a system, we provide:
"
Primary care and specialty care: If you need to find a provider or if you want to makean appointment, please call our
Patient Access Center at 1-888-321- DOCS.
" Urgent care: Please visit one of our Northwell Health-GoHealth Urgent Care Centers. They are open Mon-Fri: 8am-8pm,
Sat-Sun: 9am-5pm. Visit www.gohealthut.com/northwell.
"
Emergency Care: Visit our website for more information: https://www.northwell.edu/emergency-medicine
"
Emergency Telehealth: Appointments available to speak with an Emergency Medicine provider from your home.
Ill
Please schedule an appointment with the following healthcare provider(s):
" Please call the ED Referrals Coordinator at (516) 582-3076 if you would like our assistance with arranging your follow-up
visit(s).
" Manhattan Eye, Ear, Throat Institute - Eye Clinic; Ophthalmology
210 E. 64th Street; NewYork, NY 10021
Phone: (212) 838-9200
Follow Up Time: Urgent
Instructions from your ED Healthcare Provider
- You have been evaluated in the Emergency Department today for a comeal abrasion.
Please follow up with your primary care physician within two days.
Retum to the Emergency Department if you experience worsening or new concerning symptoms.
Thank you for choosing us for your care. Although you have been discharged from the emergency
department, this does not mean that you have a "clean bill of health".
If your symptoms persist or get worse or if any new symptoms develop, please return to the immediately for
re-evaluation.
It is also very important that you see a primary care doctor within the next few days to follow-up.
4/14/2024 3:12:54 PM Page: 1 of 9
Requested By: Thomas, Cheryl (Clerk) Job ID: 157902156 Printed From:LFH ED
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NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024
CONFIDENTIAL PATIENT DISCHARGEINSTRUCTIONS CONFIDENTIAL
M Northwell
4 ', su^my.sotouom
Health° Date of Birth: 5/15/1946
Long Island Jewish Forest Hills MRN/VisitlD: 95554/1681386155
102-0166th Road, Forest Hills, NY11375
Emergency Department: (718) 830-4200- northwell.edu
Date of Service: 05/03/2024 Principal Discharge Diagnosis: Chest wall pain
The following providers were involved in your care: Alexander Lucks (DO)
Thank you for choosing Northwell Health to provide care
You have choices when it comes to care. As a system, we provide:
"
Primary care and specialty care: If you need to find a provider or if you want to makean appointment, please call our
Patient Access Center at 1-888-321- DOCS.
" Urgent care: Please visit one of our Northwell Health-GoHealth Urgent Care Centers. They are open Mon-Fri: 8am-8pm,
Sat-Sun: 9am-5pm. Visit www.gohealthuc.com/northwell.
"
Emergency Care: Visit our website for more information: https://www.northwell.edu/emergency-medicine
"
Emergency Telehealth: Appointments available to speak with an Emergency Medicine provider from your home.
E
Instructions from your ED Healthcare Provider
" Take over the counter acetaminophen (Tylenol) 650-1000 mg every 4-6 hours as needed for pain. Do not take
more than 3000 mg in a 24 hour period. Be aware many over the counter and prescription medications also
contain acetaminophen (Tylenol).
Follow up with your primary care physician in 1-3 days.
Return with any new or worsening symptoms or concerns (see below).
Chest Wall Pain
Chest wall pain is pain in or around the bones and muscles of your chest. Sometimes, an injury causes this
pain. Excessive coughing or overuse of arm and chest muscles may also cause chest wall pain. Sometimes, the
cause may not be known. This pain may take several weeks or longer to get better.
Follow these instructions at home:
Managing pain, stiffness, and swelling
If directed, put ice on the painful area:
Put ice in a plastic bag.
Place a towel between your skin and the bag.
5/3/2024 10:26:56 PM Page: 1 of 11
Requested By: Lucks, Alexander (DO) Job ID: 159272615 Printed From:LFH ED
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FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019
NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024
FORESTHILLS RETINAL DIAGNOSTICCENTER
ALANE. ULISS, M.D., F.A.C.S.
110-11 72NDAVENUE
FORESTHILLS, NEWYORK 11375
(718) 575"8434
918)5758434 Fax Gl8) 575-3079
ALAN E. ULISS, M.D., F.A.C.S.
DIPLOMATE
AMERICANBOARD OFOPHTFIALMOLOGY
SPECIALlZINGIN
MEDICAL
DISEASES 110-11 72NDAVENT
OFTHERETBIA HEIS, NEW
FOREST YORK11375
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. ,
COPY
MAR I 6 2023
THEUNITEDSTATESDISTRICT COURT
IN PROSE OFFICE
FORTHEEASTERNDISTRICT OFNEWYORK
Complaint for Violation of Civil
Rights
(Write the full nameof each plaintif who is fling
this compioint. (f the names of all the plaintifs Case No.
cannot ft fn the space above, please write "see
attached" (to befiled in by the Clerk's Of ice)
in the space and attach an additional
page with the full list of names.) . Jury Trial: a Yes O No e
(check one)
-against-
hid:2-
Mf f c! A/¬ L / TY &ü
)/f f
H2. a AvSTi §t , f
pl L S Il3 75
(Write the f ull
Af
nameof each defendant who is
being sued. If the names of all the defendants
cannot)11 in the space above, please write "see
attached"
in the space and attach an additionai
M fN
page with the full of names. Do not include
"
list
****"**
I
FALl:51 1
NOTICE
Federal Rules of Civil Procedure S.2 addresses the privacy and security concerns resulting
from public access to electronic court files. Under this rule, papers filed with the court should
not contain: an individual's full social security number or full birth date; the full nameof a
person known to be a minor; or a complete financial account nurnber. filing mayincludeA
only: the last four digits of a social security pumber; the year of an individual's birth; a
minor's initials; and the last four digits of a financial account number.
Plaintiff need not send exhibits, affidavits, grievance or wiur.ss statements, or any other
materials to the Clerk's Office with this complaint.
In order for your complaint to be filed, it must be accompanied by the filing fee or an
application to proceed in forma pauperts.
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NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024
UNITED STATESDISTRICT COURT
.EASTERNDISTRICT OF NEWYORK
" X
SHANY
.SOLOMON
Plaintiff, ff f
-against- COMPLAINTANDJURY
. TRIAL DEMAND
.P.O. NICHOLAS DICANDIA, shield No.23582, [MD$)( kbi
2 fÛ
.P.O. RAULSARIOL, Shield No.9930
.THE CITY OF NEWYORKand
"JOHN DOE" and/or "JANE DOE",
Defendants.
. x
Plaintiff, SOLOMON SHANY,as Pro-Se (If a lawyer take this
case, plaintiff seek expenses & payment ) complaining of the
Defendants herein, respectfully alleges as follows:
JURISDICTION
.
_____________
1. This is a civil action, seeking compensatory damages, punitive
damages.
2. This action is brought pursuant to 42 U.S.Cgy1983 and 1988 and
the fourth amendmentto the Constitution of the United States.
3. Jurisdiction is founded upon 28 U.S.C. py1331, 1343 and 1367
4. Plaintiff, invoking the supplemental jurisdiction of this Court, also
seeks compensatory and punitive damages for battery and false
arrest. Misconducts & Harassments.
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NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024
Keypad
911 911
h
CCRB CCRB
STAVE
(2) STAVE
*67311
Recents
SULTAN SULTAN
MEDWINTER MEDWINTER
Contacts
o
P 92
one
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DOC. NO. QUEENSCOUNTY CLERK 08/08/2019 09: 58 AM INDEX NO. 702220/2015
NYSCEFFILED: 61 RECEIVED NYSCEF: 06/10/2024
NYSCEFDOC. NO. 19 . RECEIVEDNYSCEF: 08/08/2015
EXHIBITS TO BILL OF PARTICULAR
.A) LEASESOF #1L .
B) 46 HPDVlOLATIONS AT #1L, 2014 TO 2019
C) 300 LETTERSSENTTO DEFENDANTS(2014-20.16 mailed UPS)
D) Dr. COLLINSLETTERSANDTREATMENT
FORALLERGYTO MOLD.
E) SINUSITIS ANDOTHER.
SURGERY
F) HYDROPONICSYSTEMAT #2L ANDDAMAGES
G) DIPLOMASOF SOLOMON
SHANY-EDUCTIONS
H) HYDROPONICSYSTEM
I) TRIAL CASEONMAY2015 ANDABETMENT
$2350 FROMRENT
J) HOLDOVER
201S +2019. HOSPITAL 22 DAYS
K) DOGSISSUES
L) #2L FROM12/17/18 TO 6419. TATIANA AFFIDAVIT
M) "DHCR"- 258/19- 6/22/17 LETTER-
N) REPAlR ON6/21/16- PANIC ATTACK2/15/19-HOSPITAL 5/21/15-
. Dr. PINKCSOVA-TREMORRIGHT HAND, NERVEISSUE.
0) - SLEEPINGIN SUBWAY-ATTACK- HOSPlTAL
P) MR. GAMBARELLA,GRIEVANCEC. FAILORTO MEDIATE
Q) SUPREME
CASE5857/17 AGAINSTLOUIS CUTRI + SKIADAS
R) NOISE LISE BY #2L ON2019 and CALLSTO MANAGEMENT
S) REPORTOF #2L ATTACK PLAINTIF F 12/23/18 and HOSPITAL
T) LETTER SENT TOTENANT#3L, ON2018, TOCOVERTHE FLOOR
20 of 430
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. QUEENSCOUNTY
NYSCEF DOC. NO. 61
CLERK 04/22/2021 09:31 AM
10:48 AM| INDEX NO. 701050/2020
RECEIVED NYSCEF: 06/10/2024
NYSCEFDOC, NO. 40 RECEIVEDNYSCEF: 04 /22/202 1
3/2/21 TO: ADMINISTERJUDGEAT SUPREME
COURT:88-11 SUTPHINEBLVD.
JAMAICA, NY 11435
REQUEST TO REMOVEJUDGEROBERTJ. MCDONALDFROMMYCASE
701050/2020, ANDAPPOINTJUDGEWITH NOTICETO PLAINTlFF.
SUPREMECOURTOFTHE STATEOF NEWYORK/QUEENS
COUNTY
index: 701050/2020
SOLOMON
SHANY Plaintiff
-against
A&E REALESATEMANAGEMENT,
LLC, LOUISCUTRI
and ODELLGORDON
ALEX INOA, CRAIG P. GAMBARDELLA COUNTYCLERK
QUEENSCOUNTY
Defendants
1. I am Rabbi SOLOMON SHANYthe PLAINTlFF in this case. I am 74 years old, disable
64* Rd. # 1l, rego park, NY 11374. Cell 718-4967809
mentally & physically, live at 99-65
2. On 2/21/20 i open above case as poor man, NOFEE action. Because pandemic was
service delay to defendants. On 7/1/20 the defendant ODELLGORDON been served the
complaint & summons.
And he never answer till this moment. The defendant Craig P.
Gambardella been served on 7/15/20. He hired a lawyer, that start MOTIONon 9/25/20
to dismiss the ammendad against Defendant GAMBARDELLA. I file cross motion, and
judge granted the motion of defendant and even gave orders that plaintiff is enjoining
from commencing litigation against him, and cross motion dismissed, filed on 11/19/20
3. APPEALof that decision made and on 2/3/21appellate court gave case 2021-00782.
4. The defendant put return date for 10/16/20. But judge did conference with Mrs.
(lawyer of defendant) already on 10/14/20,
Christina WITHOUTPLAINTlFF PRESENTAND
WITHOUTKNOWLEDGE OF PLAINTIFF. On 10/16/20, plaintiff was in Court, to be
present, and Mrs. Christina, never present. I call the chamber of Judge, and been told,
that can not talk to judge without The case postponed to 11/19/20.
other side present.
Plaintiff appear in Court, and call Judge chamber, and gave e-mail sol4325@gmall to
notify plaintiff of outcome and date to come back.
5. The CROSSmotion done on time, and requested more time to complete, because
first
Plaintiff was in Mental Hospital for suicidal from 9/1120 /till 9/25/20, with depression,
and was 8 days Jewish Holiday Sukkot. On 11/19/20, plaintiff file the second part of
CROOSS MOTION,together with BILL OF PARTICULAR,THEMRS. CHRISTINA
REQUESTED.I call judge Chamber, and I been told the case postpone to 2/11/21, to
wait for decision till 2/11/21. Also the chamber lawyer, asked me if I filed cross motion
1. of 4
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NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024
COURTOFTHE CITY OF NEWYORK/QUEENSCOUNTY,
SUPREME
SOLOMON
SHANY plaintiff index No. 702220/2019
-against-
BILL OFPARTICULAR/UPDATE
. NOVEMBER2020
REGOPARKVENTURESrLLC at all Defendants & MEDICALRECORDS'
WITNESSES
+SUPPLUMENTAL
TO BILL OF PARTICULAR
I am the plaintiff SOLOMON
SHANY, giving the list of witnesses , addresses & medical records
addresses, as by Preliminary Conference order b.efore 5/15/2020.
MEDICALRECORDS: 701% 16 4 O OOOL J 17 OGf
1. Dr. Claudia L. Smuglin-'psychiatric since 2006-2017 at: 99-24 64* Ave, Rego park, NY 11374.
. also witness. Business card.
2. Dr. Bruce Schweiger-psychiatric since 2017 to present. At: Queens Consultation Center, LLC.
Preview
FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 FILED COURTOFTHESTATEOF NEWYORK/QUEENSCOUNTY SUPREME JUN 1 0 2024 SOLOMON SHANY Plaintiff Index No. 702220/2019 COUNTYCLERK QUEENSCOUNY -against- RESPONDTO DEMANDIV REGOPARKVENTURES,LLC .A&E REAL ESTATEHOLDING, LLC .A&E REAL ESTATEMANAGEMENT, LLC .LOUIS CUTRI Defendants 7019 0160 0000 2377 0377 Please take notice that plaintiff is responding to demand for medical records. 1. This demand, find plaintiff in time of serious health vision condition, therefore could not defendants' respond in 30 days. Plaintiff email to Court and attorney for the circumstances, with attached medical record as support. 2. Plaintiff repeat it here, in this respond. On 4/14/24 Plaintiff were in Hospital Northwell, for lost vision on LEFTeye (Plaintiff is blind on right eye, for decade). The diagnosed is CORNEALABRESION, LEFT. Plaintiff follow primary doctor had homesteaded) (Plaintiff had referral to eye dr. Uliss, appointment 5/1/24. By that time the vision came back but could not read. new glasses. Took long time to approved it by Dr. Uliss prescribed insurance and by end of May got new reading glasses. On 5/30/24 I sent the email to Court and Mr. Halkias, with attach document. 3. Took metime to find the addresses of doctors and others, till today 6/2/24, and I have 20 signed authorizations demanded. I amsending those tomorrow with certify mail as also fax to to law firm 212-944-5818. ALL THENEEDOF MEDICALRECORDS ANDOTHER DEMND,AREIN E-FILED DURINGTHEYEARS,INCLUDE THEEDUCATIONDIPLOMASOF PLAINTIFF (ATTACHTO TWOEXHIBITS A TO Z, WITH ALL WHAT DEFENDANTNEED, AS OVER3000 DOCUMENTS BEENE-FILED. 4. Plaintiff sent on 5/30/24 thirteen emails to Mr. Halkias, (copy to Court) with about 6 pictures in each (Limit sending in one shot. So, about 78 pictures sent. Any way, plaintiff going to e-file all the pictures about 350, that plaintiff paid to copy the pictures with color, and cost over $600 to be able to e-file it) The original pictures kept for trial. 5. Plaintiff retired at age 65, and his rent is freeze to $759.33 since age 62 and also because disability. Plaintiff have Medicare by HEALTH FIRST (given authorization of record), Member I.D. 135831035 and have Medicaid TW31995T (attach copy of insurance both) with payment out of pocket exceeded income to Medicaid, and out of pocket for for medications. The total out of pocket for Medicare in 2023 was about $1400. At present time the only income is from social security. Was$986/month and increased every year a little. 6. Plaintiff was working part time, 3 hours a week, as Rabbi in Sephardic synagogue. On 2014 retired. Since the Rabbi of synagogue passed away, the synagogue hired two Rabbis to avoid closing door. Plaintiff work 6 Hours a month. (2 Sabbath for 3 hours in 1 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 morning) to help with little payment. (attach record authorization demand). On 2023 synagogue find replacement to Rabbi Shany. Therefore Plaintiff no longer helping the synagogue, and left income of social security monthly. 7. Regards the Court against tenants #2L as demand, attach the index number document of Court 701050/2020 against both tenants #2L, who were causing over 3S00 times at night times excessive noises and 311/911 calls E- filed in Court, It is public record so you can see what is in, still active. 8. On 2022 was issue with tenants #1K as was demand for the arrest. The original tenant Steve Sultan, gave his young people (about 25 age) to live in. On apartment for 2 1/21/22 they installed recording camera on top of #1G, pointing recording 24/7 towards #1L (illegally, and landlord sent warning to remove it in 10 days, but IT WASTILL SEPTEMBER 2022 ON, REGARDLESS ). Both tenants #1K, were from different country (Hurop), they were making noises every night, loud music and to harass #1L, they were banging on the share wall of bedrooms, and kicking it at midnights. 311/911calls and reporting to landlord, been ignored. On 3/22/22 both tenants #1K kicking several times in 3 hours at midnight. They bank on our door too. As Plaintiff open door, they threat with metal to hit plaintiff. Plaintiff called 3 times 911in 3 hours for help since midnight till 3 am. In one point the tenant was ready with loptop to record, and behind him, stood other one waiving a knife. Tatiana Shany saw it (we have monitor in), and to defense cane to spray, had to use to avoid the man fruf 2 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 NOTE:THEPRINTED INTERUPTED, TO SAVE PAGESBEENPRINTED ANDSTARTNEWONE. 8. Continue: Because the mosquito spray (that was China product and even could not kill a fly, was like water with smell only, and we used glue stick instead at home), the police arrest Plaintiff with desk appearance. The case after 6 month, dismissed and sealed. (Lawyer of legal aid, got the copy of the sealed arrest for housing case she handled). Plaintiff filed against both police a lawsuit for FALSEARREST case attached with the arrest paper. The tenant #1K kicked the shared between our apartments, and caused damage that the wall broke all over, on wall 3/22/22 from midnight to 3 am, the wall kicked constantly and damaged and police refused to deal with it excuse "report to landlord it is not crime. The fact it was in violation and Plaintiff paid $700 to repair the wall as landlord refused to. Plaintiff took picture of the wall damage before and after repaired. Landlord done nothing to force the recording camera 24/7 on for 9 months, and on 3/28/24 by this camera, follow meoutside the building while walking on 64th you" Rd, #1K tenant kick Plaintiff cane, while say "I will kill and fell on sidewalk and was in Hospital, It is active. Landlord discriminate Plaintiff, by let #1K, having recording camera 24/7, HOLDOVERagainst Plaintiff for MONITOR(not recording), while he filed that legally installed on 2012 by CONSENTof previous landlord, and the fact is, THATON2024 LANDLORDGAVE PERMISSIONTHE MONITOR TO STAYONBY AGREEMENT THATPLAINTIFF VAIWE WAS HARASSMENT CASEAGAINSTLANDLORD.(Because landlord found defense of receipt paid on 2012 with consent of previous landlord, in trial they would lose the case). 9. Regard the fall on sidewalk of the landlord property. The pictures of the sidewalk after falling and the time of repair (was year later repair, regardless of letter sent to landlord (in e-file) , will file among rest of pictures. Plaintiff live at present address since 1982. Used to go right from exit building at beginning towards 99 st. Since around 2015, after surgery start walk with cane, and never walk to from building exit, but to left toward 102 st. right Also walk on 102 street up 64th Rd. to Queens Blvd, to bus station Q60. NEVERwalk on towards 99 at. One late time of evening Plaintiff had to officiate at memorial service for congregant, in restaurant Bukharian, located on 99th street near 66. Plaintiff had dizziness, but could walk with his walker to officiate. 64th Rd. Plaintiff was walking on towards 99th street, and suddenly, the walker stock by sidewalk ground, and plaintiff fell forward twice circle to the floor, and could not move as knee pain. A said" nurse by chance heard it, and run to Plaintiff I ama nurse, come to help you, do not try I to move, I callwas taking by Ambulance to flushing. 911. I Whenwas home went to see the 2" sidewalk, why I fell? I saw the sidewalk GAPfrom other. I notice the BlG tree that roots might raised the sidewalk, and I did not know ahead of time. Was surprised to me, as before 2015 I 2" was walking through. The building should know the GAP, and did nothing. Even after writing to landlord, done nothing, and plaintiff forced report to 311 latter on, past year, finally I saw construction block with yellow tape the sidewalk and I took picture. Pass long time from evening Plaintiff fell to date of repair. IT IS NEGLIGENCE! 10.THEALL DOCUMENTS AS DEMAND AREEXICT IN FILE ALREADYINCLUDEALL THE477 AMONG LETTERS, LETTEROFSIDEWALKWARNING IT. ATTACHEXHIBITSANDALL THE 3 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 DOCUMENTS BEENE-FILED. THEHOUSINGCOURTHPD9 CASESAREPUBLIC RECORDS INCLUDE THE MOLDVIOLATIONS IN EACHCASE, SOTHE INSPECTORSBE A WITNESSTOTHE MOLDEXIST IN #1L FOROVER8 YEARS 11. The witnesses as mention in deposition were tenant #2K to MOLDand noises by #2L, as well tenant #3L with his letter sent to landlord attach to plaintiff letter, exist in file. Tatiana Shany is witness to EVERYTHING IN THIS CASE, INCLUDE MOLD, LEAKING, HARASSMENT, NOlSESAT NIGHTSBY #2L, ANDWHATEVERWITH #1K. 12. if any thing is missing I will try to look on, but now need to transfer the authorization for record immediately. ONCEalready landlord lawyer got authorization for records before 2017, and they got it. Now another lawyer took over and asking second time the same medical records. Most of it, include Hospitals are exist in file, as Brunswick Hospital the all records in e- file. If the lawyer read the over 3000 documents in file, he get the answer there. Therefore, I go immediately to records. MANYYEARSPASS, ANDI PUT stop this respond here, to let it PHONENUMBER OF DOCTOR,IF I KNOW,TO LOCATETHE ADDRESS,AS MANYYEARSPASSAND DR. COLLINS MOVED 3 TIMESALREADY.ORWILL BE HARDTO FIND FROMYEARSPAST. RECORDS BUTALL IN FILE ALREADY. Sworn to before meon...Î....day of June 2024 SOLOMON SHANY ISKHAKOV YAKUBSHOLOM 4 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 CONFIDENTIAL PATIENT DISCHARGE INSTRUCTIONS CONFIDENTIAL NorthweH su4my,so1omom Date of Birth: 5/15/1946 Long island Jewish Forest Hills MRN/VisitlD: 95554/1681354245 102-01 66th Road, Forest Hills, NY1137s Emergency Department: p18) 830-4200-northwelledu Date of Service: 04/14/2024 Principal Discharge Diagnosis: Corneal abrasion, left The following providers were involved In your care: Max Lazarus (DO) Thank you for choosing Northwell Health to provide care You have choices when it comes to care. As a system, we provide: " Primary care and specialty care: If you need to find a provider or if you want to makean appointment, please call our Patient Access Center at 1-888-321- DOCS. " Urgent care: Please visit one of our Northwell Health-GoHealth Urgent Care Centers. They are open Mon-Fri: 8am-8pm, Sat-Sun: 9am-5pm. Visit www.gohealthut.com/northwell. " Emergency Care: Visit our website for more information: https://www.northwell.edu/emergency-medicine " Emergency Telehealth: Appointments available to speak with an Emergency Medicine provider from your home. Ill Please schedule an appointment with the following healthcare provider(s): " Please call the ED Referrals Coordinator at (516) 582-3076 if you would like our assistance with arranging your follow-up visit(s). " Manhattan Eye, Ear, Throat Institute - Eye Clinic; Ophthalmology 210 E. 64th Street; NewYork, NY 10021 Phone: (212) 838-9200 Follow Up Time: Urgent Instructions from your ED Healthcare Provider - You have been evaluated in the Emergency Department today for a comeal abrasion. Please follow up with your primary care physician within two days. Retum to the Emergency Department if you experience worsening or new concerning symptoms. Thank you for choosing us for your care. Although you have been discharged from the emergency department, this does not mean that you have a "clean bill of health". If your symptoms persist or get worse or if any new symptoms develop, please return to the immediately for re-evaluation. It is also very important that you see a primary care doctor within the next few days to follow-up. 4/14/2024 3:12:54 PM Page: 1 of 9 Requested By: Thomas, Cheryl (Clerk) Job ID: 157902156 Printed From:LFH ED 5 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 CONFIDENTIAL PATIENT DISCHARGEINSTRUCTIONS CONFIDENTIAL M Northwell 4 ', su^my.sotouom Health° Date of Birth: 5/15/1946 Long Island Jewish Forest Hills MRN/VisitlD: 95554/1681386155 102-0166th Road, Forest Hills, NY11375 Emergency Department: (718) 830-4200- northwell.edu Date of Service: 05/03/2024 Principal Discharge Diagnosis: Chest wall pain The following providers were involved in your care: Alexander Lucks (DO) Thank you for choosing Northwell Health to provide care You have choices when it comes to care. As a system, we provide: " Primary care and specialty care: If you need to find a provider or if you want to makean appointment, please call our Patient Access Center at 1-888-321- DOCS. " Urgent care: Please visit one of our Northwell Health-GoHealth Urgent Care Centers. They are open Mon-Fri: 8am-8pm, Sat-Sun: 9am-5pm. Visit www.gohealthuc.com/northwell. " Emergency Care: Visit our website for more information: https://www.northwell.edu/emergency-medicine " Emergency Telehealth: Appointments available to speak with an Emergency Medicine provider from your home. E Instructions from your ED Healthcare Provider " Take over the counter acetaminophen (Tylenol) 650-1000 mg every 4-6 hours as needed for pain. Do not take more than 3000 mg in a 24 hour period. Be aware many over the counter and prescription medications also contain acetaminophen (Tylenol). Follow up with your primary care physician in 1-3 days. Return with any new or worsening symptoms or concerns (see below). Chest Wall Pain Chest wall pain is pain in or around the bones and muscles of your chest. Sometimes, an injury causes this pain. Excessive coughing or overuse of arm and chest muscles may also cause chest wall pain. Sometimes, the cause may not be known. This pain may take several weeks or longer to get better. Follow these instructions at home: Managing pain, stiffness, and swelling If directed, put ice on the painful area: Put ice in a plastic bag. Place a towel between your skin and the bag. 5/3/2024 10:26:56 PM Page: 1 of 11 Requested By: Lucks, Alexander (DO) Job ID: 159272615 Printed From:LFH ED 6 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 FORESTHILLS RETINAL DIAGNOSTICCENTER ALANE. ULISS, M.D., F.A.C.S. 110-11 72NDAVENUE FORESTHILLS, NEWYORK 11375 (718) 575"8434 918)5758434 Fax Gl8) 575-3079 ALAN E. ULISS, M.D., F.A.C.S. DIPLOMATE AMERICANBOARD OFOPHTFIALMOLOGY SPECIALlZINGIN MEDICAL DISEASES 110-11 72NDAVENT OFTHERETBIA HEIS, NEW FOREST YORK11375 7 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 . , COPY MAR I 6 2023 THEUNITEDSTATESDISTRICT COURT IN PROSE OFFICE FORTHEEASTERNDISTRICT OFNEWYORK Complaint for Violation of Civil Rights (Write the full nameof each plaintif who is fling this compioint. (f the names of all the plaintifs Case No. cannot ft fn the space above, please write "see attached" (to befiled in by the Clerk's Of ice) in the space and attach an additional page with the full list of names.) . Jury Trial: a Yes O No e (check one) -against- hid:2- Mf f c! A/¬ L / TY &ü )/f f H2. a AvSTi §t , f pl L S Il3 75 (Write the f ull Af nameof each defendant who is being sued. If the names of all the defendants cannot)11 in the space above, please write "see attached" in the space and attach an additionai M fN page with the full of names. Do not include " list ****"** I FALl:51 1 NOTICE Federal Rules of Civil Procedure S.2 addresses the privacy and security concerns resulting from public access to electronic court files. Under this rule, papers filed with the court should not contain: an individual's full social security number or full birth date; the full nameof a person known to be a minor; or a complete financial account nurnber. filing mayincludeA only: the last four digits of a social security pumber; the year of an individual's birth; a minor's initials; and the last four digits of a financial account number. Plaintiff need not send exhibits, affidavits, grievance or wiur.ss statements, or any other materials to the Clerk's Office with this complaint. In order for your complaint to be filed, it must be accompanied by the filing fee or an application to proceed in forma pauperts. 8 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 UNITED STATESDISTRICT COURT .EASTERNDISTRICT OF NEWYORK " X SHANY .SOLOMON Plaintiff, ff f -against- COMPLAINTANDJURY . TRIAL DEMAND .P.O. NICHOLAS DICANDIA, shield No.23582, [MD$)( kbi 2 fÛ .P.O. RAULSARIOL, Shield No.9930 .THE CITY OF NEWYORKand "JOHN DOE" and/or "JANE DOE", Defendants. . x Plaintiff, SOLOMON SHANY,as Pro-Se (If a lawyer take this case, plaintiff seek expenses & payment ) complaining of the Defendants herein, respectfully alleges as follows: JURISDICTION . _____________ 1. This is a civil action, seeking compensatory damages, punitive damages. 2. This action is brought pursuant to 42 U.S.Cgy1983 and 1988 and the fourth amendmentto the Constitution of the United States. 3. Jurisdiction is founded upon 28 U.S.C. py1331, 1343 and 1367 4. Plaintiff, invoking the supplemental jurisdiction of this Court, also seeks compensatory and punitive damages for battery and false arrest. Misconducts & Harassments. 9 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 Keypad 911 911 h CCRB CCRB STAVE (2) STAVE *67311 Recents SULTAN SULTAN MEDWINTER MEDWINTER Contacts o P 92 one 10 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 DOC. NO. QUEENSCOUNTY CLERK 08/08/2019 09: 58 AM INDEX NO. 702220/2015 NYSCEFFILED: 61 RECEIVED NYSCEF: 06/10/2024 NYSCEFDOC. NO. 19 . RECEIVEDNYSCEF: 08/08/2015 EXHIBITS TO BILL OF PARTICULAR .A) LEASESOF #1L . B) 46 HPDVlOLATIONS AT #1L, 2014 TO 2019 C) 300 LETTERSSENTTO DEFENDANTS(2014-20.16 mailed UPS) D) Dr. COLLINSLETTERSANDTREATMENT FORALLERGYTO MOLD. E) SINUSITIS ANDOTHER. SURGERY F) HYDROPONICSYSTEMAT #2L ANDDAMAGES G) DIPLOMASOF SOLOMON SHANY-EDUCTIONS H) HYDROPONICSYSTEM I) TRIAL CASEONMAY2015 ANDABETMENT $2350 FROMRENT J) HOLDOVER 201S +2019. HOSPITAL 22 DAYS K) DOGSISSUES L) #2L FROM12/17/18 TO 6419. TATIANA AFFIDAVIT M) "DHCR"- 258/19- 6/22/17 LETTER- N) REPAlR ON6/21/16- PANIC ATTACK2/15/19-HOSPITAL 5/21/15- . Dr. PINKCSOVA-TREMORRIGHT HAND, NERVEISSUE. 0) - SLEEPINGIN SUBWAY-ATTACK- HOSPlTAL P) MR. GAMBARELLA,GRIEVANCEC. FAILORTO MEDIATE Q) SUPREME CASE5857/17 AGAINSTLOUIS CUTRI + SKIADAS R) NOISE LISE BY #2L ON2019 and CALLSTO MANAGEMENT S) REPORTOF #2L ATTACK PLAINTIF F 12/23/18 and HOSPITAL T) LETTER SENT TOTENANT#3L, ON2018, TOCOVERTHE FLOOR 20 of 430 11 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 INDEX NO. 702220/2019 . QUEENSCOUNTY NYSCEF DOC. NO. 61 CLERK 04/22/2021 09:31 AM 10:48 AM| INDEX NO. 701050/2020 RECEIVED NYSCEF: 06/10/2024 NYSCEFDOC, NO. 40 RECEIVEDNYSCEF: 04 /22/202 1 3/2/21 TO: ADMINISTERJUDGEAT SUPREME COURT:88-11 SUTPHINEBLVD. JAMAICA, NY 11435 REQUEST TO REMOVEJUDGEROBERTJ. MCDONALDFROMMYCASE 701050/2020, ANDAPPOINTJUDGEWITH NOTICETO PLAINTlFF. SUPREMECOURTOFTHE STATEOF NEWYORK/QUEENS COUNTY index: 701050/2020 SOLOMON SHANY Plaintiff -against A&E REALESATEMANAGEMENT, LLC, LOUISCUTRI and ODELLGORDON ALEX INOA, CRAIG P. GAMBARDELLA COUNTYCLERK QUEENSCOUNTY Defendants 1. I am Rabbi SOLOMON SHANYthe PLAINTlFF in this case. I am 74 years old, disable 64* Rd. # 1l, rego park, NY 11374. Cell 718-4967809 mentally & physically, live at 99-65 2. On 2/21/20 i open above case as poor man, NOFEE action. Because pandemic was service delay to defendants. On 7/1/20 the defendant ODELLGORDON been served the complaint & summons. And he never answer till this moment. The defendant Craig P. Gambardella been served on 7/15/20. He hired a lawyer, that start MOTIONon 9/25/20 to dismiss the ammendad against Defendant GAMBARDELLA. I file cross motion, and judge granted the motion of defendant and even gave orders that plaintiff is enjoining from commencing litigation against him, and cross motion dismissed, filed on 11/19/20 3. APPEALof that decision made and on 2/3/21appellate court gave case 2021-00782. 4. The defendant put return date for 10/16/20. But judge did conference with Mrs. (lawyer of defendant) already on 10/14/20, Christina WITHOUTPLAINTlFF PRESENTAND WITHOUTKNOWLEDGE OF PLAINTIFF. On 10/16/20, plaintiff was in Court, to be present, and Mrs. Christina, never present. I call the chamber of Judge, and been told, that can not talk to judge without The case postponed to 11/19/20. other side present. Plaintiff appear in Court, and call Judge chamber, and gave e-mail sol4325@gmall to notify plaintiff of outcome and date to come back. 5. The CROSSmotion done on time, and requested more time to complete, because first Plaintiff was in Mental Hospital for suicidal from 9/1120 /till 9/25/20, with depression, and was 8 days Jewish Holiday Sukkot. On 11/19/20, plaintiff file the second part of CROOSS MOTION,together with BILL OF PARTICULAR,THEMRS. CHRISTINA REQUESTED.I call judge Chamber, and I been told the case postpone to 2/11/21, to wait for decision till 2/11/21. Also the chamber lawyer, asked me if I filed cross motion 1. of 4 12 of 68 FILED: QUEENS COUNTY CLERK 06/10/2024 09:31 AM INDEX NO. 702220/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/10/2024 COURTOFTHE CITY OF NEWYORK/QUEENSCOUNTY, SUPREME SOLOMON SHANY plaintiff index No. 702220/2019 -against- BILL OFPARTICULAR/UPDATE . NOVEMBER2020 REGOPARKVENTURESrLLC at all Defendants & MEDICALRECORDS' WITNESSES +SUPPLUMENTAL TO BILL OF PARTICULAR I am the plaintiff SOLOMON SHANY, giving the list of witnesses , addresses & medical records addresses, as by Preliminary Conference order b.efore 5/15/2020. MEDICALRECORDS: 701% 16 4 O OOOL J 17 OGf 1. Dr. Claudia L. Smuglin-'psychiatric since 2006-2017 at: 99-24 64* Ave, Rego park, NY 11374. . also witness. Business card. 2. Dr. Bruce Schweiger-psychiatric since 2017 to present. At: Queens Consultation Center, LLC.