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PRESENT: Hon.
JUSTICE
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
wen een ee eee nee neem X
MAXIMINA TORRES and JAHMAL SAUVE,
Plaintiffs,
-against-
JIAN JENNY TANG, M.D., OBSTETRICS/
GYNECOLOGY FACULTY PRACTICE
ASSOCIATES and MT. SINAI MEDICAL CENTER,
Defendants.
X
At Part of the Supreme
Court of the State of New
York, held in and for the
County of New York at the
Courthouse located —at
60 Centre Street, New York,
New York, onthe__ day of
, 2016
ORDER TO SHOW
CAUSE TO BE
RELIEVED AS
COUNSEL
Index No.: 805071/14
Upon the reading and filing of the annexed Affirmation of Amy L. Insler, Esq., dated
February | {_, 2016 and upon all the pleadings and proceedings had herein, let the plaintiff show
cause at Part of the Supreme Court of the State of New York, County of New York, located at
60 Centre Street, New York, New York on the day of
, 2016 at 9:30 in the
forenoon of that day or as soon thereafter as counsel can be heard why an Order should not be
made and entered as follows:
1 Pursuant to CPLR 321 permitting the firm of Bonina & Bonina, P.C., to withdraw
as attorneys for the plaintiffs, Maximina Torres and Jahmal Sauve; and
{00085516}2. Staying this action for a period of sixty (60) days to permit Maximina Torres and
Jahmal Sauve to engage new counsel,
Let service of a copy of this Order upon the plaintiffs Maximina Torres and Jahmal Sauve
by certified mail, return receipt requested and/or personal service; and upon McAloon& Friedman,
P.C.., Attorneys for defendants by certified mail, return receipt requested and/or regular mail on or
before the day of , 2016 be deemed good, timely, and sufficient service
and notice hereof.
ENTER,
J.8.C.
{00085516} 2SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
een ee ee eee ee ee eee eee nee, xX
MAXIMINA TORRES and JAHMAL SAUVE,
Plaintiffs, ATTORNEY’S
AFFIRMATION
-against-
Index No.: 805071/14
JIAN JENNY TANG, M.D., OBSTETRICS/
GYNECOLOGY FACULTY PRACTICE
ASSOCIATES and MT, SINAI MEDICAL CENTER,
Defendants.
mene nee ee ence nee nnn nen enn nnnennenenneeennnnnnnnnnnennnne! X
STATE OF NEW YORK _)
COUNTY OF KINGS
Amy L. Insler, Esq., an attorney at law duly admitted to practice law before the Courts of
the State of New York, hereby affirms the following to be true upon information and belief under
the penalties of perjury:
1. I am an associate of the law firm of Bonina & Bonina, P.C., attorneys for the
plaintiff in the above named action.
2. This action was commenced by the filing of a Summons and Verified Complaint
with the New York County Clerk’s Office on February 25, 2014. Issue was joined by defendants
on May 21, 2014.
3. Thereafter your Affirmant’s office prepared and served Verified Bills of
Particulars, Exchanges of Medical Information, Response to Combined Demands and numerous
discovery demands.
4. The law firm of Bonina & Bonina, P.C. does not wish to continue as the plaintiffs’
attorneys due to issues that have arisen. We do not wish to expand upon these differences in
{00085518}papers which defense counsel will have access to in the Court file. Should the Court desire, we
would gladly provide further details, in camera, as to the reasons for our request.
5. It is therefore respectfully requested that this Court grant permission for the law
office of Bonina & Bonina, P.C., to be relieved and withdraw as plaintiffs’ counsel in this action
and that plaintiffs be given a period of sixty (60) days to consult with and engage a new attorney on
this matter.
6. Our office has previously discussed the issues which have given rise to this
application with Maximina Torres and Jahmal Sauve.
7. No prior application for this relief has been requested.
WHEREFORE, it is respectfully requested that the plaintiffs’ Order to Show Cause be
granted in its entirety and for such other and further relief as to this Court may seem just and
proper.
Dated: Brooklyn, NY
February |\_, 2016
l have read the foregoing and I certify that, upon information and belief, the source of
which is the review of a file maintained by my office, that the foregoing Attorney’s Affirmation is
not frivolous as defined in subsection (c) of Section 130-1.1 of the rules of the Chief
Administrator.
{00085518} 2Index No.: 805071/14
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
MAXIMINA TORRES and JAHMAL SAUVE,
Plaintiffs,
-against-
JIAN JENNY TANG, M.D., OBSTETRICS/GYNECOLOGY FACULTY PRACTICE
ASSOCIATES and MT. SINAI MEDICAL CENTER,
Defendants.
ORDER TO SHOW CAUSE TO BE RELIEVED AS COUNSEL
BONINA & BONINA, P.C.
Attorneys for Plaintiff(s)
16 Court Street, Suite 1800
Brooklyn, NY 11241
Tele. No,: (718) 522-1786
Fax No.: (718) 243-0414
—
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State,
certifies that, upon information and belief and reasonable inquiry, the contentiof{4 contained in the annexed
documents are not frivolous.
Dated: February 11, 2016 Signature:
Print Signer’s Namie: Amy I Insler, Esq.
Service of a copy of the within is hereby admitted,
Dated:
Attorney(s) for
PLEASE TAKE NOTICE
Ol _ that the within is a (certified) true copy of a
entered in the office of the clerk of the within named Court on
Notice of
Entry
CI that an Order of which the within is a true copy will be presented for settlement to the Hon,
one of the judges of the within named Court,
Notice of gy on 20 , at M.
Settlement
Dated: BONINA & BONINA, P.C.
Attorneys for Plaintifi(s)
16 COURT STREET
BROOKLYN, N.Y. 11241
To:
Attorney(s) for
(00088108)
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PRESENT: Hon. JUSTICE SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK wen een ee eee nee neem X MAXIMINA TORRES and JAHMAL SAUVE, Plaintiffs, -against- JIAN JENNY TANG, M.D., OBSTETRICS/ GYNECOLOGY FACULTY PRACTICE ASSOCIATES and MT. SINAI MEDICAL CENTER, Defendants. X At Part of the Supreme Court of the State of New York, held in and for the County of New York at the Courthouse located —at 60 Centre Street, New York, New York, onthe__ day of , 2016 ORDER TO SHOW CAUSE TO BE RELIEVED AS COUNSEL Index No.: 805071/14 Upon the reading and filing of the annexed Affirmation of Amy L. Insler, Esq., dated February | {_, 2016 and upon all the pleadings and proceedings had herein, let the plaintiff show cause at Part of the Supreme Court of the State of New York, County of New York, located at 60 Centre Street, New York, New York on the day of , 2016 at 9:30 in the forenoon of that day or as soon thereafter as counsel can be heard why an Order should not be made and entered as follows: 1 Pursuant to CPLR 321 permitting the firm of Bonina & Bonina, P.C., to withdraw as attorneys for the plaintiffs, Maximina Torres and Jahmal Sauve; and {00085516}2. Staying this action for a period of sixty (60) days to permit Maximina Torres and Jahmal Sauve to engage new counsel, Let service of a copy of this Order upon the plaintiffs Maximina Torres and Jahmal Sauve by certified mail, return receipt requested and/or personal service; and upon McAloon& Friedman, P.C.., Attorneys for defendants by certified mail, return receipt requested and/or regular mail on or before the day of , 2016 be deemed good, timely, and sufficient service and notice hereof. ENTER, J.8.C. {00085516} 2SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK een ee ee eee ee ee eee eee nee, xX MAXIMINA TORRES and JAHMAL SAUVE, Plaintiffs, ATTORNEY’S AFFIRMATION -against- Index No.: 805071/14 JIAN JENNY TANG, M.D., OBSTETRICS/ GYNECOLOGY FACULTY PRACTICE ASSOCIATES and MT, SINAI MEDICAL CENTER, Defendants. mene nee ee ence nee nnn nen enn nnnennenenneeennnnnnnnnnnennnne! X STATE OF NEW YORK _) COUNTY OF KINGS Amy L. Insler, Esq., an attorney at law duly admitted to practice law before the Courts of the State of New York, hereby affirms the following to be true upon information and belief under the penalties of perjury: 1. I am an associate of the law firm of Bonina & Bonina, P.C., attorneys for the plaintiff in the above named action. 2. This action was commenced by the filing of a Summons and Verified Complaint with the New York County Clerk’s Office on February 25, 2014. Issue was joined by defendants on May 21, 2014. 3. Thereafter your Affirmant’s office prepared and served Verified Bills of Particulars, Exchanges of Medical Information, Response to Combined Demands and numerous discovery demands. 4. The law firm of Bonina & Bonina, P.C. does not wish to continue as the plaintiffs’ attorneys due to issues that have arisen. We do not wish to expand upon these differences in {00085518}papers which defense counsel will have access to in the Court file. Should the Court desire, we would gladly provide further details, in camera, as to the reasons for our request. 5. It is therefore respectfully requested that this Court grant permission for the law office of Bonina & Bonina, P.C., to be relieved and withdraw as plaintiffs’ counsel in this action and that plaintiffs be given a period of sixty (60) days to consult with and engage a new attorney on this matter. 6. Our office has previously discussed the issues which have given rise to this application with Maximina Torres and Jahmal Sauve. 7. No prior application for this relief has been requested. WHEREFORE, it is respectfully requested that the plaintiffs’ Order to Show Cause be granted in its entirety and for such other and further relief as to this Court may seem just and proper. Dated: Brooklyn, NY February |\_, 2016 l have read the foregoing and I certify that, upon information and belief, the source of which is the review of a file maintained by my office, that the foregoing Attorney’s Affirmation is not frivolous as defined in subsection (c) of Section 130-1.1 of the rules of the Chief Administrator. {00085518} 2Index No.: 805071/14 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK MAXIMINA TORRES and JAHMAL SAUVE, Plaintiffs, -against- JIAN JENNY TANG, M.D., OBSTETRICS/GYNECOLOGY FACULTY PRACTICE ASSOCIATES and MT. SINAI MEDICAL CENTER, Defendants. ORDER TO SHOW CAUSE TO BE RELIEVED AS COUNSEL BONINA & BONINA, P.C. Attorneys for Plaintiff(s) 16 Court Street, Suite 1800 Brooklyn, NY 11241 Tele. No,: (718) 522-1786 Fax No.: (718) 243-0414 — Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentiof{4 contained in the annexed documents are not frivolous. Dated: February 11, 2016 Signature: Print Signer’s Namie: Amy I Insler, Esq. Service of a copy of the within is hereby admitted, Dated: Attorney(s) for PLEASE TAKE NOTICE Ol _ that the within is a (certified) true copy of a entered in the office of the clerk of the within named Court on Notice of Entry CI that an Order of which the within is a true copy will be presented for settlement to the Hon, one of the judges of the within named Court, Notice of gy on 20 , at M. Settlement Dated: BONINA & BONINA, P.C. Attorneys for Plaintifi(s) 16 COURT STREET BROOKLYN, N.Y. 11241 To: Attorney(s) for (00088108)