---------------------------------------------------------------------X Index No.: 156487/2016 SULLIVAN, -against- PLAINTIFF'S SUPPLEMENTAL VERIFIED 54 ST HOLDING, LLC., OMNIA GROUP, LTD., OF PARTICULARS 222-71 REALTY, LLC.,SHUSTER 54 LLC., ------------------------------------------------X SULLIVAN, by his attorneys, Buckvar & Buckyar, as and for his BILL Supplemental Verified Bill of Particulars, respectfully sets forth as follows: This Supplemental Verified Bill of Particulars supplements but does not replace Plaintiff's Verified Bill of Particulars in response to Defendants' 54 ST HOLDING, LLC., 351 ON 54 STREET MANHATTAN, LLC, 222-71 REALTY LLC., SHUSTER 54 LLC., and BAH-ULSB, dated May 1, 2017, or Plaintiff's Verified Bill of Particulars in response to Defendant's OMNIA GROUP, LTD., dated May 1, 2017. This Supplemental Verified Bill of Particulars references only those paragraphs of Plaintiff's Verified Bill of Particulars in response to Defendants' 54 ST HOLDING, LLC., 351 ON 54 54 STREET MANHATl'AN, LLC, 222-71 REALTY LLC., SHUSTER 54 LLC., and BAH- ULSB, dated May 1, 2017 and Plaintiff's Verified Bill of Particulars in response to Defendant's OMNIA GROUP, LTD., dated May 1, 2017, that relate to the special damages and damages sustained by Plaintiff as a result of the accident. SPECIAL DAMAGES As previously advised, Plaintiff's past medical expenses have been paid by Medicare. To date, Medicare is asserting the amount of $3,029.45 as a Conditional Payment. Plaintiff reserves the right to supplement and /or amend this response upon receipt of any updated Conditional Payment letter from Center for Medicare & Medicaid Services. PRIOR OR SUBSE UENT ACCIDENTS 1 of 5
Plaintiff is not making a claim for any pre-existing injuries. Plaintiff's has not been involved in any accident, prior to or subsequent to the accident of December 21, 2015, wherein he sustained injuries to his Right Elbow. Dated: New York, New York December 6, 2017 Yours etc... By Eric Buckyar, Esq. BUCKVAR & BUCKVAR Attorneys at Law Attorneys for Plaintiff 11 Broadway, Suite 1054 To: Jack Gross, Esq. The Chartwell Law Offices, LLP. Attorneys for Defendant OMNIA GROUP, LTD. One Battery Park Plaza, 35* 35 Floor (212) 962-2173 (212) 968-2300 Goldberg Segalla, LLP. Attorneys for Defendants 54 ST HOLDING, LLC. 351 ON 54 54 STREET MANHATTAN, LLC. 222-71 REALTY, LLC. and SHUSTER 54 LLC. 200 Garden City Plaza, Suite 520 Garden City, NY 11530 (516) 281-9800 (516) 281-9801 (fax) File No.: 15376.0049 2 2 of 5
INVIDIDUAL VERIFICATION STATE OF NEW YORK ) ) )ss.: SULLIVAN, being sworn, say: SU P PL EMENTAL I am the Plaintiff in the within action. I have read the foregoing BILL OF PARTICULARS and know the contents thereof, the same is true to my own knowledge, except as to the matters therein alleged to be on information and belief, and as to those matters I believe to be true. Dated: New York, New York c~-'â SULLIVAN Sworn to before me on J day of bétow, 20_ 7 Notary-Public No. 02BU49413 3 of 5
--------------------------------------------------------------X X Index No.: 156487/2016 SULLlVAN, -against- AFFIDAVIT OF SERVICE 54 ST HOLDING, LLC., OMNIA GROUP, LTD., 222-71 REALTY, LLC.,SHUSTER 54 LLC., -----------------------------------------X State of New York ) X County of New York } )ss.: LESLIE CARRION, being duly sworn, deposes and says: That deponent is not a party to the action, is over 18 years of age, resides in the State of New York, County of Kings, and is employed by BUCKVAR & BUCKVAR, 11 Broadway, Suite 1054, New York, New York 10004. That on December 6, 2017, I served the within PLAINTIFF'S SUPPLEMENTAL VERIFIED BILL OF PARTICULARS, upon: Goldberg Segalla, LLP. 200 Garden City Plaza, Suite 520 Garden City, NY 11530 The Chartwell Law Offices, LLP. 35* One Battery Park Plaza, 35 Floor (212) 968-2300 at the addresses designated by said attomeys for that purpose by depositing a true copy of same in a postage-paid, properly addressed envelope, in an official d 'itory under the. clusive control of the United States Postal Service within the State of New k. Sworn to bef e me this pby A 6* day of e ber, 2017 +Oqo sue ARRION 4 of 5
Index #: 156487 Year: 2016 SULLIVAN, -against- 54 ST HOLDING, LLC., OMNIA GROUP, LTD., 222-71 REALTY, LLC., SHUSTER 54 LLC., --. PLAINTIFF'S SUPPLEMENTAL VERIFIED BILL OF PARTICULARS BUCKVAR & BUCKVAR ATTORNEYS FOR PLAINTIFF SULLIVAN 11 BROADWAY, SUITE 1054 NEW YORK, NY 10004 212-962-2173 5 of 5