NOTE OF ISSUE Calenda Ñö. (if any) Index No. 805 1041201 5 For use of Clerk SUPREME Court, STAIE OI- NEW YORK County, N.Y. HON. JOAA A. MADDEN, J.S.C. Name of Justice Assigned MiCHELÈ, NÓŸICE ÑOR TRIAL IMPREVEDUTO, Plaintiff/Petitioner Trial b jury demanded Of all issues Of issues specified below Or attached hereto Trial without Jury Filed by PLAINTIFF Date summons served MARCH 17, 2015 -against- Date service completed MARCH 17, 2015 Date Issue joined AUGUST 3, 2015.NAŸURE ÔF ACTNN Ö RÖCÊEÔIÑG 885 PARK AVENUE Tort otor Vehicle Negligence PODIATRY, P.C.: B edical Malpractice SUZANNE M. LEVINE, DPM- DPM; BARBARA LEE, ther Tort DOCTORS DOE 1-5, et al. Contract Defendant/ReSpondent _ Contested Uncontested Tax Certiorari Condemnation Matrimonial Matrimonial Other (not itemized above) specify: his action is brought as a class action An amount pursuant to CPLR 3017(c), together with interest, Amount Demanded $ costs and disbursements. Othe.r Relief Special Preference claimed under Insurance carrier(s), if known: Landniark Americari Ins. Co. Beagley Ins. Co. the ground that Attorney for Plaintiff/Plaintiff Pro Se: RONALD P. BOTELHO, ESQ Address: CHASAN LAMPARELLO MALLON & CAPPUZZO, PC 232 Madison Avenue, Ste. 1200 New Yötk, NY 10016 Phone Number (212) 531-1883 ór (201) 34826000 Attorney for Defendant/Defendant Pro Se: SEE RIDER ATTACHED Address: Phone Numtier 1 of 6
CERTIFICATE OF READINESS FOR TRIAL (Items 1-7 must be checked) Com leted W ed Not Required 1. All pleadings served... _ 2. Bill of particulars served... _ 3. Physical examinations completed... _ 4. Medical reports exchanged... _ 5. Appraisal reports exchanged... _ X 6. Compliance with rules in matrirnonial actions... _ X 7. Discovery now know to be necessary completed... _ 8. There are no outstanding requests for discovery. 9. There has been a reasonable opportunity to camp êto the foregoing prõgeed ñgs. 10. There has been compliance with any order issued to Precalendar Rules (22 NYCRR 202.12) 11. If a medical malpractice action, there has been compliance with any order ursuant to 22 NYCRR 202.56 12. The case is ready for trial. Dated: 01/3 I /$ 013 Signature P [gdgrge RONALD P. BOTELHO, ESQ Attorney fo arty Pro Se PLAINTIFF r s 0 Lighting Way, Suite 200 Secaucus, New Jersey 07094 Phone Number (201) 348-6000 State of New State of New York County of ss: Jersey, County of Hudson ss: CHRISTINE LIPINSKI, being duly sworn deposesitnd. says: that deponent is not a party to this action, is-evef being duly sworn deposes and says: that deponent is not a 18 years of age and resides in the County of Hudson, party to the action, is over 18 years of age and resides at State of New Jersey, that on that on the 31STday of JANUARY, 2019, deponent the _ day of, 20 served the within Note of Issue, Certificate of deponent served the within Note of Issue and Certificate of Readiness, and Affirmation of Compliance on Readiness on TRAUB LIEBERMAN STRAUS & SHREWSBERRY, attorney(s) LLP, for Defendants 885 PARK AVENUE PODIATRY and SUZANNE M. herein at their office LEVINE, DPM herein, at 7Skyline Drive, Hawthorne, NY 10532, and CATALANO located at GALLARDO & PETROPOULOS, LLP, for Dêfêñdant during their absence from said office Barbara J. Lee, DPM herein, at 100 Jericho Quadrangle, Suite 326, Jericho, NY 11753, (a) by then and there leaving a true copy of the same with the addresses designated by said attorneys for that purpose by depositing a true copy ofsame enclosed in the clerk; partner; person having charge of said office. a postpaid properly addressed wrapper, in a post office-official depository under the exclusive care and (b) and said office being closed by deposit ñg a true copy of custody of the United States Postal Service within the same enclosed in a sealed wrapper directed to said State o Jersey attorney(s), in the office letter drop or box,.. Sworn before me on the day of, 20_ Sworn before me on the31stday of January, 20.l_9. Notary Public Notary blic, I MARIA IACOPELLI Commission # 2449981 ra; y Public, State of New Jersey My Commission Expires September 1 7, 2019 Admission of Service Due service of a note of issue and certificate of readiness of which the within is a copy is admitted this 31stday of January, 20 19 Ronald P. Botelho, Esq. Chasan Lamparello Mallon & Caopuzzo, PC Attorney(s) for Plaintiff 2 of 6
RIDeR Jonathan R. Harwood, Esq. Traub Lieberman Straus & Shrewsberry LLP 7 Skyline Drive Hawthorne, NY 10532 (914) 586-7006 Direct (914) 347-2600 Main (914)347-8898 Fax jharwood@tisslaw.corn For defendant 88p Park Avenue Podiatry and Suzanne M. Levine, DPM Jeffrey E. Bondoc, Esq. Catalano Gallardo & Petropoulos, LLP 100 Jericho Quadrangle Suite 326 Jericho, NY 11753 516 931-1800 Main 516 931-1033 Fax ibondoc@capllp.com For defendant Barbara J. Lee, DPM 3 of 6
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YQRK -------- -------------- ---------- X MICHELE IMPREVEDUTO, Index No. 805104/2015 Plaintiff, -against- 885 PARK AVE-NUE PODIATRY, P.C.; AFFIRMATION OF SUZANNE M. LEVINE, DPM; BARBARA LEE, COMPLIANCE DPM, DOCTORS DOE 1-5, (a class of fictitiously named doctors), (fictitious designations representing the class of as yet unknown entities affiliated or connected in any manner with the individual defendants or with plaintiff's care and vicariously, administratively or directly providers' responsible for the other medical actions and plaintiff's injuries), Defendants. --------------------- X RONALD I. BOTELHO, an attorney duly admitted to practice law before the Courts of the State of New York, affirms the truth of the fellowing, under penalties of perjury, pursuant to New York Civil Practice Law and Rules 2106: 1. I am a attorney with the law firm of Chasan Lamparello Mallon & Cappuzzo, PC, attorneys for Plaintiff, Michele Impreveduto in the above-captioned matter. I am fully familiar with the facts and. circumstances set forth herein, with my knowledge having been obtained through investigation and review of the records and files maintained by my office throughout the handling of Ms. Impreveduto's claims. 2. This Affirmation is submitted in connection with the filing of a Note of Issue. 4 of 6
3. The parties have exchanged answers to discovery requests, exchanged medical records and HIPAA compliant authorizations, completed all party depositions, and completed medical examinations of the plaintiff. 4. The parties are to complete the subpoenaed deposition of non-party witi1ess, Dr. Raza, on or before March 24, 2019. See the attached photograph, which is a true copy of the January 24, 2019 Compliance Conference Order, agreed to by all counsel, but not yet posted to NYSCEF as of the filing of this Affirmation of Compliance. 5. There shall be no additional discovery, unless by consent. See attached photograph of January 24, 2019 Compliance Conference Order. WHEREFORE, Plaintiff respectfully requests that the instant matter be promptly placed on the trial calendar. Dated: Secaucus, New Jersey January 31, 2019 By: RONALD P.BOTELHO, Esq. CHASAN LAMPARELLO MALLON & CAPPUZZO, PC Attorneys for Plaintiff Office Address 232 Madison Avenue, Suite 1200 New York, NY 10016 (646)531-1883 Mailing Address 300 Lighting Way, Suite 200 Secaucus, NJ 07094 (201) 348-6000 5 of 6
SUPREME COURT OF THE STATE OF NEW YORK, COUNTY OF NEW YORK INDEX NO. - against - IAS PART 58s, 6 cd wenaanus> COMPLlANCE ORDER CONFERENCE On 20 \3 a conference was held in th s case The partles aopeared as follows by Defendant(s) by b b The Court has considered the status of th s case [ and determined that the Court's case management order of 20 has not been compf ed w th n that) Accord ng y t is ORDE tha W 5 u Dated: 6 of 6