Preview
INDEX NO. 805402/2014
NYSCEF DOC. NO.| 8 RECEIVED NYSCEF: 01/06/20/15
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
| ana n e Index No.: 80542/2014
IELLEN BRENNAN,
Plaintiff/, DEMAND FOR
- against - VERIFIED BILL OF
PARTICULARS
INICHOLAS MORRISSEY, M.D., THE NEW YORK AND.
PRESBYTERIAN HOSPITAL AND NEW YORK-
IPRESBY TERIAN HEALTHCARE SYSTEM, INC.,
Defendant
|e anne tease --X.
SIRS
PLEASE TAKE NOTICE that, pursuant to Rule 3041 et seq., of the Civil Practice
Law and Rules, Plaintiff is hereby required to serve upon HEIDELL, PITTONI, MURPHY &
BACH, LLP, attorneys for the defendant, Nicholas Morrissey, M.D. within twenty (20) days
after service of a copy of this demand, a verified bill of particulars of the complaint, setting forth
in detail the following:
1. The manner and respect in which it is claimed that the defendant was
negligent, careless and unskillful.
2. a. The dates on which defendant rendered services.
b The dates and times of the day each alleged act of negligence
of defendant occurred.
C. The place or places where services were rendered by defendant.
3. The nature, location, extent and duration of each injury which it will be
claimed was caused by the negligence of the defendant. If any injuries are claimed to be
lpermanent, so state.
4. If it will be claimed the aforesaid injuries necessitated any hospitalizations or
treatment at other institutions, set forth the following:
a. The names and addresses of each hospital or institution with
the dates of confinement or outpatient treatment.
1297950.1
5. If it will be claimed that the aforesaid injuries necessitated treatment by any
lphysicians, set forth the names and addresses of each physician and the dates of treatment or
visits.
6. If it will be claimed that the aforesaid injuries necessitated confinement to bed
lor home, set forth the following:
a. The dates of confinement to home.
b The dates of confinement to bed.
7. Set forth the following:
a The name and address of plaintiff's decedent’s employer at the
time of the alleged negligence.
The capacity in which plaintiff's decedent was then employed.
The name and address of plaintiff's decedent present employer, if
any.
d The capacity in which plaintiff is presently employed.
8. If loss of earnings is claimed asa result of the alleged negligence, set forth the
following:
Plaintiff's decedent’s earnings for the last full year prior to the
alleged negligence.
The last date plaintiff's decedent worked prior to the alleged
negligence.
The loss of earnings claimed to date.
d. The total amount of lost earnings which will be claimed.
é. The dates which plaintiff claims to have been absent from work.
9. If plaintiff's decedent was a student at the time of the injury, sct forth:
a. The name and address of the school.
b, The class or year at the time of the injury.
1297950.1
Cc. The dates of absence due to the claimed injuries.
10. If any special damages are claimed as a result of the alleged malpractice, set
forth the following:
The charges for the above named hospitals, listing each
hospital separately.
Physicians' charges.
Charges for medicine, itemizing the medicines charged for.
d. Charges for nursing services.
€. Other.
11. Pursuant to CPLR 4545 identify all providers of any collateral source
payment for medical care and/or for disability such as insurance, social security, worker's
compensation or employee benefit programs. For each collateral source provider identify the
limits of coverage available to the plaintiff. Provide the address and claim number for each
collateral source provider.
12. If it is claimed that any negligence or malpractice occurred prior to treatment
by the defendant, set forth the names of the persons responsible therefore and specify what acts
or omissions constituted negligence.
13. If it is claimed that any negligence or malpractice occurred subsequent to the
treatment by the defendant, set forth the names of the persons responsible therefore and specify
‘what acts or omissions constituted negligence.
14. Set forth the patient's residence address at the time of the commencement of
this action, and for five years prior thereto.
15. Set forth the patient's date of birth and social security number.
1297950,1
16. Set forth any other names by which the patient has been known and the dates
of usage of any such other names.
IDated: White Plains, New York
January 6, 2015
Yours, etc.,
Garrett P. ewis, Esq.
HEIDELL, PITTONI, MURPHY & BACH, LLP
Attorneys for Defendant
Nicholas Morrissey, M.D. and NewYork
Presbyterian Hospital s/h/a The New York And
Presbyterian Hospital And New York-
Presbyterian Healthcare System, Inc.
Office & P.O. Address
81 Main Street
White Plains, New York 10601
(914) 559-3100
TO: Abbott, Bushlow & Schechner, LLP
Attorneys for Plaintiff(s)
70-11 Fresh Pond Road
Ridgewood, NY 11385
(718) 366-0464
$297950.1
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
|---. a. penne: =. -X Index No.: 80542/2014
ELLEN BRENNAN,
Plaintiff/, : DEMAND FOR
- against - ‘VERIFIED BILL OF
PARTICULARS
ICHOLAS MORRISSEY, M.D., THE NEW YORK AND
PRESBYTERIAN HOSPITAL AND NEW YORK-
IPRESBY TERIAN HEALTHCARE SYSTEM, INC.,
Defendant. :
|annnn newer enn nanan nen!
SIRS
PLEASE TAKE NOTICE that, pursuant to Rule 3041 et seq., of the Civil Practice
[Law and Rules, Plaintiff is hereby required to serve upon HEIDELL, PITTONI, MURPHY &
IBACH, LLP, attorneys for the defendant, NewYork Presbyterian Hospital s/h/a The New
York And Presbyterian Hospital And New York-Presbyterian Healthcare System, Inc.,
within twenty (20) days after service of a copy of this demand, a verified bill of particulars of the
complaint, setting forth in detail the following:
1. The manner and respect in which it is claimed that the defendant was
negligent, careless and unskillful.
2. a. The dates on which defendant rendered services.
b. The dates and times of the day each alleged act of negligence
of defendant occurred.
Cc. The place or places where services were rendered by defendant.
3. The nature, location, extent and duration of each injury which it will be
claimed was caused by the negligence of the defendant. If any injuries are claimed to be
permanent, so state.
4, If it will be claimed the aforesaid injuries necessitated any hospitalizations or
treatment at other institutions, set forth the following:
1297945.1
a. The names and addresses of each hospital or institution with
the dates of confinement or outpatient treatment.
5. If it will be claimed that the aforesaid injuries necessitated treatment by any
physicians, set forth the names and addresses of each physician and the dates of treatment or
visits.
6. If it will be claimed that the aforesaid injuries necessitated confinement to bed
or home, set forth the following:
a, The dates of confinement to home.
b. The dates of confinement to bed.
7. Set forth the following:
a. The name and address of plaintiff's decedent’s employer at the
time of the alleged negligence.
The capacity in which plaintiff's decedent was then employed.
The name and address of plaintiff's decedent present employer, if
any.
d The capacity in which plaintiff is presently employed.
8. If loss of earnings is claimed asa result of the alleged negligence, set forth the
following:
Plaintiff's decedent’s earnings for the last full year prior to the
alleged negligence.
The last date plaintiff's decedent worked prior to the alleged
negligence.
The loss of earnings claimed to date.
d. The total amount of lost earnings which will be claimed.
€. The dates which plaintiff claims to have been absent from work.
9. If plaintiff's decedent was a student at the time of the injury, set forth:
a, The name and address of the school.
1297945.1
b, The class or year at the time of the injury.
C. The dates of absence due to the claimed injuries.
10. If any special damages are claimed as a result of the alleged malpractice, set
forth the following:
The charges for the above named hospitals, listing each
hospital separately.
Physicians’ charges.
Charges for medicine, itemizing the medicines charged for.
Charges for nursing services.
€. Other.
11. Pursuant to CPLR 4545 identify all providers of any collateral source
payment for medical care and/or for disability such as insurance, social security, worker's
compensation or employee benefit programs. For each collateral source provider identify the
limits of coverage available to the plaintiff. Provide the address and claim number for each
collateral source provider.
12. If it is claimed that any negligence or malpractice occurred prior to treatment
by the defendant, set forth the names of the persons responsible therefore and specify what acts
or omissions constituted negligence.
13. If it is claimed that any negligence or malpractice occurred subsequent to the
treatment by the defendant, set forth the names of the persons responsible therefore and specify
what acts or omissions constituted negligence.
14. Set forth the patient's residence address at the time of the commencement of
this action, and for five years prior thereto.
15. Set forth the patient's date of birth and social security number.
1297945,1
16. Set forth any other names by which the patient has been known and the dates
lof usage of any such other names.
(Dated: White Plains, New York
January 6, 2015
Yours, ete,
Garrett P. wis, Esq.
HEIDELL, PITTONI, MURPHY & BACH, LLP
Attorneys for Defendant
Nicholas Morrissey, M.D. and NewYork
Presbyterian Hospital s/h/a The New York And
Presbyterian Hospital And New York-
Presbyterian Healthcare System, Inc.
Office & P.O. Address
81 Main Street
White Plains, New York 10601
(914) 559-3100
TO Abbott, Bushlow & Schechner, LLP
Attorneys for Plaintiff(s)
70-11 Fresh Pond Road
Ridgewood, NY 11385
(718) 366-0464
1297945.1
Preview
INDEX NO. 805402/2014 NYSCEF DOC. NO.| 8 RECEIVED NYSCEF: 01/06/20/15 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK | ana n e Index No.: 80542/2014 IELLEN BRENNAN, Plaintiff/, DEMAND FOR - against - VERIFIED BILL OF PARTICULARS INICHOLAS MORRISSEY, M.D., THE NEW YORK AND. PRESBYTERIAN HOSPITAL AND NEW YORK- IPRESBY TERIAN HEALTHCARE SYSTEM, INC., Defendant |e anne tease --X. SIRS PLEASE TAKE NOTICE that, pursuant to Rule 3041 et seq., of the Civil Practice Law and Rules, Plaintiff is hereby required to serve upon HEIDELL, PITTONI, MURPHY & BACH, LLP, attorneys for the defendant, Nicholas Morrissey, M.D. within twenty (20) days after service of a copy of this demand, a verified bill of particulars of the complaint, setting forth in detail the following: 1. The manner and respect in which it is claimed that the defendant was negligent, careless and unskillful. 2. a. The dates on which defendant rendered services. b The dates and times of the day each alleged act of negligence of defendant occurred. C. The place or places where services were rendered by defendant. 3. The nature, location, extent and duration of each injury which it will be claimed was caused by the negligence of the defendant. If any injuries are claimed to be lpermanent, so state. 4. If it will be claimed the aforesaid injuries necessitated any hospitalizations or treatment at other institutions, set forth the following: a. The names and addresses of each hospital or institution with the dates of confinement or outpatient treatment. 1297950.1 5. If it will be claimed that the aforesaid injuries necessitated treatment by any lphysicians, set forth the names and addresses of each physician and the dates of treatment or visits. 6. If it will be claimed that the aforesaid injuries necessitated confinement to bed lor home, set forth the following: a. The dates of confinement to home. b The dates of confinement to bed. 7. Set forth the following: a The name and address of plaintiff's decedent’s employer at the time of the alleged negligence. The capacity in which plaintiff's decedent was then employed. The name and address of plaintiff's decedent present employer, if any. d The capacity in which plaintiff is presently employed. 8. If loss of earnings is claimed asa result of the alleged negligence, set forth the following: Plaintiff's decedent’s earnings for the last full year prior to the alleged negligence. The last date plaintiff's decedent worked prior to the alleged negligence. The loss of earnings claimed to date. d. The total amount of lost earnings which will be claimed. é. The dates which plaintiff claims to have been absent from work. 9. If plaintiff's decedent was a student at the time of the injury, sct forth: a. The name and address of the school. b, The class or year at the time of the injury. 1297950.1 Cc. The dates of absence due to the claimed injuries. 10. If any special damages are claimed as a result of the alleged malpractice, set forth the following: The charges for the above named hospitals, listing each hospital separately. Physicians' charges. Charges for medicine, itemizing the medicines charged for. d. Charges for nursing services. €. Other. 11. Pursuant to CPLR 4545 identify all providers of any collateral source payment for medical care and/or for disability such as insurance, social security, worker's compensation or employee benefit programs. For each collateral source provider identify the limits of coverage available to the plaintiff. Provide the address and claim number for each collateral source provider. 12. If it is claimed that any negligence or malpractice occurred prior to treatment by the defendant, set forth the names of the persons responsible therefore and specify what acts or omissions constituted negligence. 13. If it is claimed that any negligence or malpractice occurred subsequent to the treatment by the defendant, set forth the names of the persons responsible therefore and specify ‘what acts or omissions constituted negligence. 14. Set forth the patient's residence address at the time of the commencement of this action, and for five years prior thereto. 15. Set forth the patient's date of birth and social security number. 1297950,1 16. Set forth any other names by which the patient has been known and the dates of usage of any such other names. IDated: White Plains, New York January 6, 2015 Yours, etc., Garrett P. ewis, Esq. HEIDELL, PITTONI, MURPHY & BACH, LLP Attorneys for Defendant Nicholas Morrissey, M.D. and NewYork Presbyterian Hospital s/h/a The New York And Presbyterian Hospital And New York- Presbyterian Healthcare System, Inc. Office & P.O. Address 81 Main Street White Plains, New York 10601 (914) 559-3100 TO: Abbott, Bushlow & Schechner, LLP Attorneys for Plaintiff(s) 70-11 Fresh Pond Road Ridgewood, NY 11385 (718) 366-0464 $297950.1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK |---. a. penne: =. -X Index No.: 80542/2014 ELLEN BRENNAN, Plaintiff/, : DEMAND FOR - against - ‘VERIFIED BILL OF PARTICULARS ICHOLAS MORRISSEY, M.D., THE NEW YORK AND PRESBYTERIAN HOSPITAL AND NEW YORK- IPRESBY TERIAN HEALTHCARE SYSTEM, INC., Defendant. : |annnn newer enn nanan nen! SIRS PLEASE TAKE NOTICE that, pursuant to Rule 3041 et seq., of the Civil Practice [Law and Rules, Plaintiff is hereby required to serve upon HEIDELL, PITTONI, MURPHY & IBACH, LLP, attorneys for the defendant, NewYork Presbyterian Hospital s/h/a The New York And Presbyterian Hospital And New York-Presbyterian Healthcare System, Inc., within twenty (20) days after service of a copy of this demand, a verified bill of particulars of the complaint, setting forth in detail the following: 1. The manner and respect in which it is claimed that the defendant was negligent, careless and unskillful. 2. a. The dates on which defendant rendered services. b. The dates and times of the day each alleged act of negligence of defendant occurred. Cc. The place or places where services were rendered by defendant. 3. The nature, location, extent and duration of each injury which it will be claimed was caused by the negligence of the defendant. If any injuries are claimed to be permanent, so state. 4, If it will be claimed the aforesaid injuries necessitated any hospitalizations or treatment at other institutions, set forth the following: 1297945.1 a. The names and addresses of each hospital or institution with the dates of confinement or outpatient treatment. 5. If it will be claimed that the aforesaid injuries necessitated treatment by any physicians, set forth the names and addresses of each physician and the dates of treatment or visits. 6. If it will be claimed that the aforesaid injuries necessitated confinement to bed or home, set forth the following: a, The dates of confinement to home. b. The dates of confinement to bed. 7. Set forth the following: a. The name and address of plaintiff's decedent’s employer at the time of the alleged negligence. The capacity in which plaintiff's decedent was then employed. The name and address of plaintiff's decedent present employer, if any. d The capacity in which plaintiff is presently employed. 8. If loss of earnings is claimed asa result of the alleged negligence, set forth the following: Plaintiff's decedent’s earnings for the last full year prior to the alleged negligence. The last date plaintiff's decedent worked prior to the alleged negligence. The loss of earnings claimed to date. d. The total amount of lost earnings which will be claimed. €. The dates which plaintiff claims to have been absent from work. 9. If plaintiff's decedent was a student at the time of the injury, set forth: a, The name and address of the school. 1297945.1 b, The class or year at the time of the injury. C. The dates of absence due to the claimed injuries. 10. If any special damages are claimed as a result of the alleged malpractice, set forth the following: The charges for the above named hospitals, listing each hospital separately. Physicians’ charges. Charges for medicine, itemizing the medicines charged for. Charges for nursing services. €. Other. 11. Pursuant to CPLR 4545 identify all providers of any collateral source payment for medical care and/or for disability such as insurance, social security, worker's compensation or employee benefit programs. For each collateral source provider identify the limits of coverage available to the plaintiff. Provide the address and claim number for each collateral source provider. 12. If it is claimed that any negligence or malpractice occurred prior to treatment by the defendant, set forth the names of the persons responsible therefore and specify what acts or omissions constituted negligence. 13. If it is claimed that any negligence or malpractice occurred subsequent to the treatment by the defendant, set forth the names of the persons responsible therefore and specify what acts or omissions constituted negligence. 14. Set forth the patient's residence address at the time of the commencement of this action, and for five years prior thereto. 15. Set forth the patient's date of birth and social security number. 1297945,1 16. Set forth any other names by which the patient has been known and the dates lof usage of any such other names. (Dated: White Plains, New York January 6, 2015 Yours, ete, Garrett P. wis, Esq. HEIDELL, PITTONI, MURPHY & BACH, LLP Attorneys for Defendant Nicholas Morrissey, M.D. and NewYork Presbyterian Hospital s/h/a The New York And Presbyterian Hospital And New York- Presbyterian Healthcare System, Inc. Office & P.O. Address 81 Main Street White Plains, New York 10601 (914) 559-3100 TO Abbott, Bushlow & Schechner, LLP Attorneys for Plaintiff(s) 70-11 Fresh Pond Road Ridgewood, NY 11385 (718) 366-0464 1297945.1