FILED: BRONX COUNTY CLERK 08/13/ :53 PM INDEX NO /2015E NYSCEF DOC. NO. 116 RECEIVED NYSCEF: 08/13/2018
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1 ALANS.FREDMAN ATTORNEY AT LAW 875 AVENUE OF THE AMERCAS SUTE 1802 NEW YORK. NEW YORK ADMTTED N NY. DC & MD TELEPHONE (212) FAX (212) August 13, 2018 BRODY & BRANCH 205 Lexington Avenue, 4 th F1OOr New York, New York Re: Reid v. Yeshivah Of Flatbush, LLC and CS Builders, nc. ndex Number: 22904/15 Dear Counsel: Per CPLR 5 R 3122-a, please be advised that plaintiff intends to offer the business records/medical records of Complete Care which have been certified, into evidence during the trial of the above referenced matter. Said business records/medical records are available for your review at the office of the undersigned located at 875 Avenue of the Americas, Suite 1802, New York, New Y.ork Please advise when you would like to come review said records. Moreover, a courtesy copy of said records, and the certification, are enclosed herein ur reference, although not required by the CPLR. ( uly ours, / A. EDMAN, ESQ. ~ AF/dd Enc.reords 1 of 5
2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX KARL RED, x Plaintiff, ndex #: 22904/15E -against- SUBPOENA DUCES TECUM YESHVAH OF FLATBUSH, LLC AND CS BULDERS, NC., Defendants. The People of the State ofnew York x TO: Complete Care 2488 Grand Concourse Bronx, New York Attn: Medical Records GREETNG: WE COMMAND YOU, That all business and excuses being laid aside, you and each of you appear and attend before JUSTCE LUC1NDO SUAREZ, At SUPREME Court BRONX County 17th YORK on the day date to give 851 GRAND CONCOURSE BRONX, NEW o' of August, 2018 at 9:30 clock, in the FORE noon, and at testimony in this action on the part of the PLANTFF any recessed or n lieu of appearing forward a certified copy of the Medical Records of Karl Reid from 1/16/15 to the present;. to Supreme Court, Bronx County, 851 Grand Concourse, Room 217, Subpoena Records, Bronx, New York Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of your failure to comply. WTNESS, JUSTCE LUCNDO SUAREZ one of the CES of said Court, at 851 GRAND CONCOURSE, BRONX, NEW YORK the 9th d y of Augus, S. DMAÑ, ESQ. Attorney for Plainfiff 875 Avenue oft'he Americas Suite 1802 New York, New York *Please include copy of subpoena with records. 2 of 5
3 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX KARL RED, NDEX NO.:22904/15 Plaintiff, CPLR R 3122-a AFFRMATON -against- YESHVAH OF FLATBUSH, LLC AND CS BULDERS, NC., Defendants. Victoria Garcia, being duly sworn affirms and says under the penalties of perjury: 1. am a custodian of medical records for patients of Complete Care which is located at 2488 Grand Concourse, Bronx, New York. 2. Thus, have the authority to certify said medical records. 3.. The records of Karl Reid are an accurate version of the documents described in the subpoena duces tecum which received that are in my possession, custody and/or control. 4. To the best of my knowledge, after reasonable inquiry, the records produced represent the documents described in the subpoena duces tecum. 5. The records produced were made by me, Complete Care/Aric Hausknecht, M.D., acting in the regular course Complete Care's business, at the time of the act, transaction, occurrence or event 3 of 5
4 recorded therein, or within a reasonable time thereafter, and that it was the regular course of Complete Care's business to make such records. Victoria Garcia Sworn to before me this 10" 10 day of August, 2018 N ry blic JORDAN SCH FF Notmy Public, State of Newibrk No. 02S Qualified in New Wrk County Commission Expires March 3, of 5
5 RECORDS HAVE BEEN REDACTED FOR EFLNG PURPOSES BUT PERSONALLY SERVED ON DEFENDANTS COUNSEL 5 of 5
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