EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (2024)

EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (1)

EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (2)

  • EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (3)
  • EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (4)
  • EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (5)
  • EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (6)
  • EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (7)
  • EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (8)
  • EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (9)
  • EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (10)
 

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D: OUN PK BV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 10/20/2023 verisma Date: 3/11/2022 Fax: 516-248-0677 To Theresa Phillips Kaufman Borgeest & Ryan, LLP 1205 Franklin Ave Ste 200 Garden City, NY 11530 Phone: 516-248-6000x7058 Re: Records MERC] From: 155-214 Neurology at Lenox Hill DOB: 130 East 77th Street VSI ID: 6981-245154 Black Hall, 8th Floor Case #: 735.128 New York, NY 10075 Pages in this distribution (including this cover sheet): 17 Please call Customer Service at 866-390-7404 if you experience problems with the receipt of this information.Requestor Satisfaction SurveyThank you for requesting medical records. To better serve you in the future, please take a brief survey of yourexperience at: https://(www.surveymonkey.com/r/verismasurvey1 STATEMENT OF CONFIDENTIALITY The information contained is intended for the exclusive use of the addressee and contains confidential or privileged information. If you are not the intended recipient, you are hereby notified that any retention, dissemination, or use of this communication is strictly prohibited. If this information was sent in error, please notify us by phone at the number listed above. 0001D: OUN PK SIV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 “—>\ RECEIVED NYSCEF: 10/20/2023 verisma’ ® IMPORTANT NOTICE Verisma Systems, Inc., works with the facility from which you have requested medical records in connection with the review and processing of such requests. Please read the important notice below, which refers to specific legal rules that may apply to the attached copies of records. If the information now being disclosed to you came from records whose confidentiality is protected by specific federal or state laws and regulations independent of the Health Insurance Portability and Accountability Act (“HIPAA”), those specific laws and regulations may prohibit you from making any further disclosure of such information unless further disclosure is expressly permitted by the written consent of the person to whom it pertains or is otherwise permitted by applicable laws or regulations. These laws include the federal re-disclosure restrictions contained in Title 42, Part 2 of the Code of Federal Regulations, which relates to federally-assisted alcohol or drug abuse programs. A general authorization for the release of confidential information that is covered by Title 42, Part 2 is not sufficient for this purpose. The federal rules referred to in the preceding sentence restrict any use of the information to criminally investigate or prosecute any alcohol or drug abuse patient who has been in a program covered by the rules. Applicable New York State laws include prohibitions on the disclosure of confidential HIV-related information. New York State law prohibits you from making any further disclosure of such information without the specific written consent of the person to whom it pertains or as otherwise permitted by law. Any unauthorized further disclosure in violation of New York State law may result in a fine or jail sentence or both. A general authorization for the release of confidential information is not, except as specifically authorized by law, sufficient authorization for further disclosure of HIV- related information. Disclosure of confidential HIV-related information that occurs as the result of a general authorization for the release of medical or other information will be in violation of state law and may result in a fine or a jail sentence or both. Verisma Systems, Inc. = 510 West Third Street, Suite 200, Pueblo, Colorado 81003 = 866-390-7404 www.verismasystems.com 0002OUN PK DM INDEX NO. 511527/2021 D:NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 10/20/2023 verisma Did you know you could get records quicker by electronic delivery? Go Green with Verisma! Want records via email? Want to save money on postage? Need one central location for record delivery? We have quick and easy solutions for you! Electronic Delivery Options Email Download Simply add an email address to your request letter and we will do the rest! An initial email from customerservice@verisma.com will Low Volume be sent to confirm your email address. Once confirmed, another Requesters/Patients email will be sent as your records become available for download. Follow the link to securely open/download the records right to your computer. Verisma can send requested records directly to a requestor’s server Verisma eTransfer via the eTransfer option. This option does require a conversation between Verisma IT and the Requestors IT. Please visit Bulk Requesters/Commercial www.verisma.com and click Requestor Support Center. Then select Health Plans the link to complete the Secure File Transfer form. Once the form has been received, one of our qualified representatives will reach out directly to begin set up! *For Payment Only* Verisma Tracking App The Verisma Tracking App can be used to track and pay all in one convenient location! Please visit https://track.verisma.com/ and High Volume provide the requested information. Requesters/Attorneys/Third Party Vendors By going green with Verisma and signing up for one of our electronic delivery options, you would save an average of $5.00 in postage on every request. Contact us today! 866.390.7404 ustomerservice@verisma.com 0003D: OUN PK BV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 10/20/2023 = « < = North t ell fy Northwell Health System Certification RE: Merceron, Lesly To Whom It May Concern: This letter will certify that |, Tamica Lockwood, the Verisma Release of Information (ROI) Representative for Northwell Heath Physician Partners System. In my capacity as the Verisma Release of Information Representative for Northwell Health Physician Partners Lenox Hill Neurology, | serve as the individual (ROI vendor representative) whom is fulfilling this request. | hereby do attest that the enclosed is a true copy of the complete and original medical record that is kept in the ordinary course of business for PATIENT NAME: Merceron, Lesly co (total of 9 of pages) If you have any questions regarding the completion of this medical records request, please do not hesitate to contact the practice office directly. Sincerely, UO. & Arrced 2.032021 Verisma Representative 0004D: OUN PK DIV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 10/20/2023 TMM 1006981 866 155-214 Neurology at Lenox Hill, 130 East 77th Street ORG 1006981 Clinic 866 Dr Mandat New to practice joined 8/12/2019, records will be stored in Allscripts under “ Outside medical records- Dr Mandel”. Any reqeust received proir to 8/12/2019 can be processed with Dr Mandal’s old address. Any request received after 8/12/2019 must be rejected if it does not list the address of 130 East 77" ST , Black Hall 8" floor, NY NY EMR Systems: Allscripts (primary) Any Legacy EMR, please print and attach the records behind the bar code sheet/request letter, if Verisma does not currently have access to the Legacy EMR. If we can obtain remote access to your legacy EMR, please contact Julie Szakall (jszakall@verisma.com) to arrange access for Verisma NHPP Sender’s Name: Ruche) a# rreno NHPP Sender’s Email: rparren oO @Northwell.edu 0005D: OUN PK DIV INDEX NO. 511527/2021NYSCEF Doc. NO. 47 RECEIVED NYSCEF: 10/20/2023 kor KAUFMAN BORGEEST creer —_—_eeee & RYAN LLP 1205 FRANKLIN AVENUE, GARDEN CITY, NY 11530 TEL: 516.248.6000 FAX: 516.248.0677. WWW.KBRLAW.COM KIMBERLY WILLIAMS, PARALEGAL DIRECT: 516.248.6000 x7042 KWILLIAMS@KBRLAW.COM November 4, 2021 Northwell Health Physician Partners Lenox Hill Neurology 130 East 77" Street, 8" Floor New York, New York 10075 Re: Claimant's Name Lesly Merceron Date of Birth Social Security # KBR Eile No. 735.128 Dear Sir/Madam: We represent the defendant in a lawsuit brought by the above referenced claimant. Our office would like to obtain a complete copy of ALL RECORDS and FILMS in your possession pertaining to Lesly Merceron. This request is including but not limited to patient registration/sign-in sheets, patient history, treatment and/or progress notes, appointment logs, consultation records, prescriptions, correspondence, billing records, all lab and radiology reports, insurance records and outpatient clinic visitation records. Enclosed please find an original, duly executed authorization with accompanying Power of Attorney that permits you to provide us with these items. Please provide records electronically if possible and kindly advise the cost to obtain those records in both the paper and electronic format. Please forward an invoice, before duplication, for approval to my attention via email to tphillilps@kbriaw.com or via fax to 516-248-0677 or regular mail, with the number of pages and your taxpayer identification number and, upon approval from our client, | will arrange for immediate payment. Please address all regular mail to the following address: Kaufman Borgeest & Ryan LLP 1205 Franklin Avenue, Suite 200 Garden City, New York 11530 Attention: Theresa Phillips Additionally, we ask that you kindly complete and return the enclosed Record Certification with all materials pertaining to Lesly Merceron. NEW YORK NEW JERSEY CONNECTICUT CALIFORNIA. 7198857D: OUN PK DIV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 10/20/2023 Page 2 Please note that pursuant to New York State Public Health Law, Section 17 and 18, the fees for reproduction may not exceed $.75 per page. However, should you not possess any of the requested materials, kindly return our letter with accompanying authorization and indicate this in writing on your letterhead. Should you have any questions, please do not hesitate to contact the undersigned. Thank you for your courtesy and your anticipated prompt response to this request. Very truly yours, KAUFMAN BORGEEST & RYAN LLP barca (Phthpe Theresa Phillips Enciosures KAUFMAN BORGEEST & RYAN LLP TPR:OUN PK DM INDEX NO. 511527/2021NYSCE Fr RRGaa NOs rAd 1 DANTS Oca ORRGAAMED, NYSCEF: 10/20/2023 AUTROI HON FOR RELEASE OF HEALTH IN MATION PURSUANT TO HIPAA ‘his form has be a raved by the Now York S: Dx f He: *PLEAS Aa IOTECE THAT ANY DISCUSSION WITH COUN ‘ SEL ES VOL) ARY AND YOU D NOT COMPLY WITH ANY REQUEST FOR AN INTERVIEW TO DISCUSS THIS PATIENT, *THE PURPOSE OF THIS INTERVIEW IS TO ASSIST THE DEFENDANT(S) EN THE DE} SE OF THIS LAWSUIT BROUGHT BY THIS PATIENT. THIS AUTHORIZATION IS NOT AT THE REQUEST GF YOUR PATIEN YOUR WILLINGNESS TO PARTICIPATE IN THIS INTERVIEW IS ENTIRELY VOLUNTARY, YOU ARE FREE TO DECLINE THE REQUEST FOR SAID INTERVIEW. aime: sly Merceron Date of Birth i | Social Security i” \Address 938 East 89th Street, Brooklyn, New York 11236 Lormy authorized r sentativ: re t chat hi eal formation tegarding my care and tamer ben ised a ¢ forth on this form; Ta accords with N w York State Law: ad the Pri Rule ef the Health § ance Postah ined A ountahility Act of 19! {HEPA unde that q Th aut jon may Jnckude psure of information relating to GL ad DRUG ABUSE, MENTAL H TH TRE, ME easept psychotherapy notes, and CONFIDENTIAL HIV+ RELATED INFORMATIO) 1 if | place my als on the apprypriate Lis in Kem 9 in the event the health infor ition described bela in des any of these types of information, and | initial the Hine on the box in Item Sa}, I specifically authorize retea: af such information to the personis din a 8, i an author ing Je release of RIV related, aleahs ordm Ng treatment, ar mental health treatment isformation, the recipient is prohituted trom redisclosiag such information without m a ization unless permitted to d under federal or state taw fF anderstand that T ha aghit foque: a fof people who may receive oF u: ny HIV: New York 11936 ‘a), Specific information to be released: Medical Records trom (insert date) (insert date} x re er 5, CO jelical Record, including patient hist , Difling records, urance records, and records fice notes (except to otherapy Botes}, test results. radiology studies, w by other health caree raviders, films, Other: include: (indicate by Inuiatings Sico*koli Drag Treatment ontal Health information Authorization to Disenss Health Tafarmation HEV-Related information thy Ry init 2 here, § authotiz oF vlividual tealt! 02 provider To discuss my health information with my attomey, ora govemmental agency, tis ed here: stort tem Name or Gove i Agen Namie) 1G. Reason release of infor ation: HH. Da wevent on whic bis authonzation will pi At request of ind! ual pon the conclusion of lit ion \ Other: Lawsuit a2 not the sbove named. naine of person signin; 1 Author to mon beh: ab named ort Viler @, Bs Amited £ aver af AL Ail items on this fona have be complotea ape questic about this forr: wen answered, dilifion. Th: p provided a copy of thts form, we Dae, £ wf of DED agur ot above od or repfesonti thorized by ne, Robert Viensky, Bq Human fumunsdeticiosey Virbs that causes AID ow K State Fublic Health Law protets information, which reasonubly could ideagi@pgenenmeas iraving HIV symapionis or infection and inlormationreg: ding ap a's contacdsD OUN PK DIV INDEX NO. 511527/2021NYSCEF Doc. NO. 47 RECEIVED NYSCEF: 10/20/2023 RECORD CERTIFICATION RECORDS PERTAINING TO: Lesly Merceron ID # or MR#: {} | certify that, to the best of my knowledge, the enclosed is an accurate reproduction of the above mentioned individual’s record in keeping with policies and proced ures. This record was made in the regular course of business, and it is the regular course to maintai n such records. The information contained in the record was recorded at the time of the occurre nce or event or within a reasonable time thereafter. As requested, outside corres pondence is being provided but cannot be certified as it did not originate at: Attached Materials (Please check all that apply) — RECORDS PATHOLOGY MATERIALS — RADIOLOGY FILMS RADIOLOGY REPORTS BILLING OTHER: (Please specify) CERTIFICATION OF NO RECORDS [} | certify that after a thorough search no information, records or documents have been located pertaining to the above referenced individual. (PLEASE CHECK ALL THAT APPLY) — RECORDS PATHOLOGY MATERIALS — RADIOLOGY FILMS RADIOLOGY REPORTS — BILLING OTHER: (Please specify) — MATERIALS HAVE BEEN DESTROYED This certification is made to the best of my knowledge, information and belief. Date Authorized Signature for: Northwell Health Physician Partners-Lenox Hill Radiology THIS FORM MUST BE SIGNED, DATED & RETURNED TO KAUFMAN BORGEEST & RYAN LLP KBR FILE No.: 7723703 0010D: OUN PK DIV INDEX NO. 511527/2021NYSCEF Doc. NO. 47 RECEIVED NYSCEF: 10/20/2023 LIMITED POWER OF ATTORNEY TO ALL PERSONS, be itknown that, ELLY 18 0(E Coal do hereby make and grant a limited power of attorney » the undersigned Principal, to Ronemus & Vilensky, LLP and do thereupon constitute and appoint said individuals as my attorneys- in-fact. This power is limited to the extent of permitting my attorneys to sign HIPAA com pliant authorizations in my place and stead pursuant to New York State Pub! lic Health Law Section 18. My attorneys-in-fact hereby accepts this appointment subj. ect to its terms and agrees to act and perform in said fiduciary capacity consistent with my best interests as he/s ‘S! he in his/her best discretion deems advisable, affirm and ratify all acts so undertaken, and 1 TO INDUCE ANY THIRD PARTY TO ACT HE REUNDER, I HEREBY AGREE THAT ANY THIRD PARTY RECEIVING A DULY EXECUTED CO} PY OR FACS] IMILE OF THIS INSTRUMENT MAY ACT HEREUNDER, AND THAT REVOCATION OR TER MINAT I! ON HEREOF SHALL BE INEFFECTIVE AS TO SUCH THIRD PARTY UNLESS AND UNTIL ACTU AL NOT! ICE OR KNOWLEDGE OF SUCH REVOCATION OR TERMINATION SHALL HAVE BEEN REC. EIVED BY SUCH THIRD PARTY, AND [ FOR MYSELF AND FOR MY HEIRS, EXECUTORS, E , LEGAL REPRESEENTATIVES AND ASSIGNS HEREBY AGREE TO INDEMNII FY AND HOLD HARM LESS ANY SUCH THIRD PARTY FROM AND AGAINST ANY AND ALL CLAIMS THAT MAY ARISE AG, ‘AINST SUCH THIRD PARTY BY REASON OF SUCH THIRD PARTY HAVING RELIED ON THE PRO VISIONS OF THIS INSTRUMENT. Thereby grant Ronemus & Vilensky, LLP the power of attome y to si ‘gt my name to any settlement checks. Signed under seal this / 4“ day of Ma 4 » 2029 STATE OF NEW YORK lese Y AME RCE Rap) ) COUNTY OF 44 é¢0 ge 7 )ss.: On Ly Oey of, i 1 Ze 2026 before me, personally appeared ¢ € § fi ‘7 ef Eitcé ‘adsforsonally known to me (or proved to me on n the basis of satisfactory evidence) to be the pe son whose name is subscribed to the within instrument and acknowledged to me that he/she execute d the same in his/her authorized capacity, and that by his/her signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument. WITNESS my hand and official seal, we ’a “ é LON ALE Notary Public cette to MOWARD CAH Fubhe Staotre Naw “ert OICAgU2a5A2 Sdunkiod in Grone eproiri Sao Aon 20S a one 0011D: OUN PK BV INDEX NO. 511527/2021NYSCEF DOCASNO Médical PC RECEIVED NYSCEF 10/20/2023 P.O. Box 28372 Account Number: 19655812/3/ New York, NY 10087-8372 Statement Date: 12/03/21 Due Date: 12/18/21 Amount Due: $0.00 LESLY MERCERON oe Make Checks Payable to: oe 958 EAST 89 STREET NSLIJ MEDICAL PC P.O. BOX 28372 BROOKLYN,NY 11236 NEW YORK, NY 10087-8372 Patient Name: MERCERON,LESLY Pay Your Bills Online! at www.northwell.edu/billpay enn nnnnnee nee CHARGES PAYMENTS - Provider: SABA MD,SAMI INVOICE #: 83201428 PRIMARY INSURANCE: MAGNACARE STANDARD SECONDARY INSURANCE: 07/20/20 99244 OFFICE CONSULT 943.00 07/20/20 95912 NERVE CONDUCTION 11-12 STUDIES 1355.00 07/20/20 95886 EMG; EACH EXTREMITY COMPLETE W/NCS_ 456.00 07/20/20 95885 EMG; EACH EXTREMITY LIMITED W/ NCS 297.00 08/10/20 MAGNACARE PMT 1109.54 08/10/20 ADJUSTMENT 1831.17 Total: 3051.00 PATIENT PAYMENTS: 110.29 INVOICE BALANCE: 0.00 een nnnnnnnnnnnnnnnnnnne an -- This is a bill for physician services. If you have any questions or updates please contact customer service Monday through Thursday from 9:00am to 4:45pm and Friday 8:00am to 3:45pm by phone at 516-876-5555 or email at PhysicianUpdates@northwell.edu. For financial assistance please contact us at 800-995-5727 or on the web at www.northwell.edu/financial-assistance enn nnnnnee nee 0012D: OUN PK BV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 10/20/2023 <2.% Northweil eee Health: Se Name: LESLY MERCERON Date of Visit: Jul 20 2020 —_— Address: 958 EAST 89 STREET MR BROOKLYN, NY 11236 DO! Reason For Visit LESLY MERCERON is a 61 year old male being seen for a consultation visit. History of Present Illness CC: left foot weakness HPI: 61 year old man referred by Dr. Mont for left foot weakness Location: left foot Quality: weakness Severity: severe Duration: 6 months Timing: constant Context: after hip surgery Modifying Factors: seems worse when walking Associated signs and symptoms: no numbnessftingling in right leg and no significant back pain Data reviewed: Labs: CRP, ESR 8/2019 normal Imaging (independently reviewed): MRI L spine - marked central stenosis at L4/5 Prior records: reviewed notes by Dr. Mont ROS: 13 pt review of systems performed and reviewed with patient (General, Eyes, Ears, Cardiovascular, Respiratory, Gastrointestinal, Genitourinary, Musculoskeletal, Skin, Endocrine, Hematologic, Psychiatric, Neurologic) Past medical history, surgical history, social history, and family history reviewed with patient See scanned document for details Active Problems Aftercare following left hip joint replacement surgery (V54.81,V43.64) (Z47.1,Z96.642) Chronic hip pain after total replacement of left hip joint (719.45,338.29,V43.64) (M25.552,G89.29,Z96.642) Left foot drop (736.79) (M21.372) Current Meds Celecoxib 200 MG Oral Capsule; TAKE 1 CAPSULE TWICE DAILY AS NEEDED. MDD:2 tabs Cyclobenzaprine HCl - 5 MG Oral Tablet; TAKE 1 TABLET AT BEDTIME AS NEEDED Meloxicam 15 MG Oral Tablet; TAKE 1 TABLET DAILY WITH FOOD oxyCODONE-Acetaminophen 5-325 MG Oral Tablet, TAKE 1 TABLET Every 6 hours PRN for pain MDD:004 traMADol HCl - 50 MG Oral Tablet; TAKE 1 TABLET At Bedtime MDD:001 traMADol HCl - 50 MG Oral Tablet; TAKE 1 TABLET Every twelve hours MDD:100mg Vitals Vital Signs 600 Community Drive ,, Manhasset, NY, 11001, Tel (516) 495-5993 Fax (516) 495-5993 0013D: OUN PK BV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 10/20/2023 Date of Visit: 07/20/2020 Page 2 of 3 Name:LESLY MERCERON DOB} Recorded: 20Jul2020 01:41PM ‘Systolic 169, LUE, Sitting Diastolic 93, LUE, Sitting Height 6 ft Weight 242 |b BMI Calculated 32.82 kg/m2 BSA 2.31 Calculated ‘Temperature 98.7 F, Oral Heart Rate 67 Respiration 16 O2 Saturation 94, Room Air Physical Exam Gen: appears well, well-nourished, no acute distress MS: awake, alert, oriented, speech fluent, comprehension intact, good fund of knowledge, recent and remote memory intact, attention intact CN: PERRL, EOMI, visual fields full, facial strength and sensation intact and symmetric, hearing grossly intact, palate elevation symmetric, tongue midline, no tongue atrophy or fasciculations, shoulder shrug intact and symmetric Motor: UE 5/5 symmetric; hip flexion, knee extension 5/5; left knee flexion 4/5, right 5; ankle dorsiflexion 1/5 L, eversion 1/5, inversion 4/5, EHL/EDB 1, toe flexion 3/5 L; right EHL/EDB 4/5, otherwise 5/5 RLE Sensory: LT/PP diminished in left dorsum and plantar foot, anterolateral and posterior leg compared to right; vibration absent at both big toes and ankles Reflexes: 2+ symmetric UE and patellar, absent achilles b/l Coordination: no dysmetria on finger to nose Gait: drags left leg with impairment of plantar and dorsiflexion Skin: no rash on extremities CV: 2+ pulses b/l, no edema Ophtho: fundi not visualized. Assessment Neuropathy of left sciatic nerve (355.0) (G57.02) Polyneuropathy (356.9) (G62.9) History, exam, and NCS/EMG consistent with a severe left sciatic neuropathy, affecting the fibular (peroneal) division somewhat more than the tibial division. Although the patient states the weakness started after surgery, he did not seem to complain of it until last month. Given the uncertainty, it may be prudent to image the hip to look for any impingement of the sciatic nerve due to scarring or other structural process There was also an axonal polyneuropathy in the feet that appears to be incidental at this time as he denies any symptoms that would correspond to it 600 Community Drive , Manhasset, NY, 11001Tel (516) 495-5993 Fax (516) 495-5993 0014D: OUN PK BV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 10/20/2023 Date of Visit: 07/20/2020 Page 3 of 3 7a Name:LESLY MERCERON Given the distance between nerve injury and the most distally affected muscles, improvement may be seen up to 3 years after the injury. However the severity of axon loss suggests that recovery will likely be incomplete | recommended he see an orthotist for an AFO to aid with his gait He has f/u with Dr. Mont in 2 days Return in 3 months for clinical re-evaluation See separate procedure note for full results of study. Plan Left foot drop Orthotics Lower Limb Ankle-Foot; Status:Complete; Done: 20Jul2020 Electronically signed by : SAMI SABA, MD; Jul 22 2020 10:14AM EST (Author) 600 Community Drive , Manhasset, NY, 11001Tel (516) 495-5993 Fax (516) 495-5993 0015D: OUN PK BV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 10/20/2023 <2.% Northweil eee Health: Se Name: LESLY MERCERON Date of Visit: Jul 20 2020 oC aT Address: 958 EAST 89 STREET MRN: 14485672 BROOKLYN, NY 11236 Dear Dr. Mont, | had the pleasure of evaluating your patient, LESLY MERCERON. Please see my note below. Thank you very much for allowing me to participate in the care of this patient. If you have any questions, please do not hesitate to contact me. Sincerely, Sami Saba M.D. Neurology, Electromyography and Neuromuscular Medicine Lenox Hill Hospital Assistant Professor of Neurology Hofstra / Northwell School of Medicine History of Present Illness CC: left foot weakness HPI: 61 year old man referred by Dr. Mont for left foot weakness Location: left foot Quality: weakness Severity: severe Duration: 6 months Timing: constant Context: after hip surgery Modifying Factors: seems worse when walking Associated signs and symptoms: no numbness/tingling in right leg and no significant back pain Data reviewed: Labs: CRP, ESR 8/2019 normal Imaging (independently reviewed): MRI L spine - marked central stenosis at L4/5 Prior records: reviewed notes by Dr. Mont ROS: 13 pt review of systems performed and reviewed with patient (General, Eyes, Ears, Cardiovascular, Respiratory, Gastrointestinal, Genitourinary, Musculoskeletal, Skin, Endocrine, Hematologic, Psychiatric, Neurologic) Past medical history, surgical history, social history, and family history reviewed with patient See scanned document for details Active Problems Aftercare following left hip joint replacement surgery (V54.81,V43.64) (Z47.1,Z96.642) Chronic hip pain after total replacement of left hip joint (719.45,338.29,V43.64) (M25.552,G89.29,296.642) 600 Community Drive ,, Manhasset, NY, 11001, Tel (516) 495-5993 Fax (516) 495-5993 0016D: OUN PK BV INDEX NO. 511527/2021NYSCEF DOC. NO. 47 RECEIVED NYSCEF 10/20/2023 Date of Visit: 07/20/2020 Page 2 of 3 Name:LESLY MERCERON >a Left foot drop (736.79) (M21.372) Current Meds Celecoxib 200 MG Oral Capsule; TAKE 1 CAPSULE TWICE DAILY AS NEEDED. MDD:2 tabs Cyclobenzaprine HCl - 5 MG Oral Tablet; TAKE 1 TABLET AT BEDTIME AS NEEDED Meloxicam 15 MG Oral Tablet; TAKE 1 TABLET DAILY WITH FOOD oxyCODONE-Acetaminophen 5-325 MG Oral Tablet; TAKE 1 TABLET Every 6 hours PRN for pain MDD:004 traMADol HCl - 50 MG Oral Tablet; TAKE 1 TABLET At Bedtime MDD:001 traMADol HCl - 50 MG Oral Tablet; TAKE 1 TABLET Every twelve hours MDD:100mg Vitals Vital Signs Recorded: 20Jul2020 01:41PM ‘Systolic 169, LUE, Sitting Diastolic 93, LUE, Sitting Height 6 ft Weight 242 Ib BMI Calculated 32.82 kg/m2 BSA 2.31 Calculated ‘Temperature 98.7 F, Oral Heart Rate 67 Respiration 16 O2 Saturation 94, Room Air Physical Exam Gen: appears well, well-nourished, no acute distress MS: awake, alert, oriented, speech fluent, comprehension intact, good fund of knowledge, recent and rem

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GIBSON,ELAINE M v. BEDFORD-STUYVESANT

May 04, 2012 |Partnow, Hon. Mark I. |Tort-Other Negligence |Tort-Other Negligence |2965/2012

Case

SERVAIS,CAMERON L. v. GIBSON,GEORGE E. M.

Nov 13, 2013 |Vaughan, Hon. David B. |Tort-Motor Vehicle |Tort-Motor Vehicle |12378/2013

Ruling

TENG JIAO ZHOU, ET AL. VS NORTH EL MONTE AUTOMOTIVE, ET AL.

Aug 27, 2024 |24PSCV01179

Case Number: 24PSCV01179 Hearing Date: August 27, 2024 Dept: O Tentative Ruling (1) Plaintiffs Demurrer to the Cross-Complaint is SUSTAINED with leave to amend. (2) PLAINTIFFS NOTICE OF MOTION AND MOTION TO STRIKE PORTIONS OF CROSS-COMPLAINANTS COMPLAINT is MOOT in part (i.e., punitive damages) and DENIED in part (untimeliness). Background This is a negligence case. Plaintiffs TENG JIAO ZHOU (Zhou) and Yung Wu (Wu) allege the following against Defendants NORTH EL MONTE AUTOMOTIVE, business form unknown, and HANK JANN, an individual and JENNIFER JANN, as an individual and as TRUSTEE OF THE ELDAN JANN AND JENNIFER JANN REVOCABLE LIVING TRUST, and ELDAN JANN, as an individual and as TRUSTEE OF THE ELDAN JANN AND JENNIFER JANN REVOCABLE LIVING TRUST: Defendants hired Zhou to do repairs on the roof of a premises owned by Defendants; Zhou was not licensed nor is he a licensed contractor. On the second day of the job, Zhou fell off the latter. Zhou alleges that because he was unlicensed, he is deemed an employee of the Defendants for civil tort purposes. On April 12, 2024, Plaintiffs filed suit for: 1. Negligence 2. Premises Liability 3. Loss of Consortium (Wu is Zhous wife)

Ruling

KEVIN LLEWELLYN vs. CALIFORNIA HOTEL GROUP LLC

Aug 28, 2024 |23CV13260

No appearances necessary. After review of the parties’ CMC statements, the matter is continued for trial setting to October 2, 2024 at 1:30 p.m. in Department 3. Parties and counsel are ordered to meet and confer in advance regarding mutually available dates for trial.

Ruling

RICKY MILLAN, ET AL. VS JOAN PLOTFIN, ET AL.

Aug 29, 2024 |22STCV26847

Case Number: 22STCV26847 Hearing Date: August 29, 2024 Dept: 48 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT RICKY MILLAN, et al., Plaintiffs, vs. JOAN PLOTFIN, et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) CASE NO.: 22STCV26847 [REVISED TENTATIVE] ORDER DENYING AS MOOT DEFENDANTS MOTION TO COMPEL FURTHER RESPONSES; SUSTAINING DEMURRER Dept. 48 8:30 a.m. August 29, 2024 MOTION TO COMPEL FURTHER RESPONSES On January 10, 2024, Defendant Joan Plotkin, individually and as trustee of Plotkin Trust Agreement Dated August 28, 1991 filed a motion to compel further responses to Form Interrogatories (Set One) from Plaintiffs Ricky Millan, Silvia Millan, Michael Millan, Samantha Millan, and Tommy Millan. A. Defendant is Ordered to Pay Four Additional Filing Fees. Defendants single motion seeks to compel production pursuant to five discovery requests (one for each Plaintiff). Each set of discovery should have been filed as a separate motion, with separate filing fees and hearing reservations. Despite being scheduled as only one motion and one hearing, the total substance is that of five motions. This unfairly allows Defendant to take only one hearing reservation (instead of five) and results in an inaccurate projection and accounting of the Courts workload, inconveniencing both the Court and other litigants. All parties are ordered not to do this and are warned that continued action of this type may result in monetary sanctions under Code of Civil Procedure section 177.5. For any future discovery motions, the parties must file a separate motion for each discovery request, or the Court may strike or deny the motions for being improperly filed. Defendant is ORDERED to pay four additional filing fees within 10 days. A Non-Appearance Case Review Re: Defendants Payment of Four Additional Filing Fees is scheduled for September 13, 2024 at 9:00 a.m. B. Defendant Did Not Comply With This Departments Procedures. Plaintiffs argue that Defendant did not comply with the Courts requirement to hold an informal discovery conference. (Opposition at p. 3.) However, according to Page 1 of Department 48s Courtroom Information, available on the Courts website (www.lacourt.org), Informal Discovery Conferences (IDCs) are not conducted in Department 48. You may file your motions to compel further discovery. However, the Court now requires the parties to also file a joint statement for discovery disputes (as outlined in Exhibit A) together with your motions. For a motion to compel further, the moving party must meet and confer with the opposing party and file a Separate Statement or follow the Courts alternative method of outlining the disputes. (Code Civ. Proc., § 2031.310, subd. (b); California Rules of Court, rule 3.1345(b).) This Department requires the parties to follow the procedures outlined in Exhibit A of Department 48s Courtroom Information (available on the Courts website, www.lacourt.org) and file a joint statement. Defendant did not comply with these requirements. If any party continues to electronically file noncompliant documents, the Court may strike the filings or impose monetary sanctions. C. Plaintiffs Supplemental Production Makes This Motion Moot. On August 12, 2024, Plaintiffs served supplemental responses, including responsive documents. (Yadegari Decl. ¶ 3.) Accordingly, the motion is moot. Defendant argues that the motion is not moot because the supplemental responses remain deficient. (See Reply.) Those further arguments may be raised in a timely motion to compel further responses that complies with all procedural requirements. However, the original motion filed on January 10, 2024 is now moot. D. Conclusion The motion to compel further responses to Form Interrogatories (Set One) is DENIED AS MOOT. DEMURRER On March 27, 2023, Plaintiffs Ricky Millan, Silvia Millan, Michael Millan, Samantha Millan, and Tommy Millan filed a first amended complaint (FAC). The FAC alleges (1) negligence premises liability; (2) negligence per se; (3) negligent hiring; (4) negligent infliction of emotional distress; (5) unjust enrichment; (6) nuisance; (7) breach of contract; (8) breach of the covenant of quiet enjoyment; (9) unfair business practices; and (10) fraudulent concealment. On March 26, 2024, Plaintiffs identified Doe 3 as Defendant Milner Roofing Inc. On July 8, 2024, Defendant filed a demurrer. A demurrer for sufficiency tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.) When considering demurrers, courts read the allegations liberally and in context, accepting the alleged facts as true. (Nolte v. Cedars-Sinai Medical Center (2015) 236 Cal.App.4th 1401, 1406.) Because a demurrer challenges defects on the face of the complaint, it can only refer to matters outside the pleading that are subject to judicial notice. (Arce ex rel. Arce v. Kaiser Found. Health Plan, Inc. (2010) 181 Cal.App.4th 471, 556.) A. Defendants Request for Judicial Notice is Granted. Plaintiffs argue that the demurrer is based solely on impermissible use of extrinsic evidence, an unsigned, unauthenticated paper (see Defendants Demurrer) which must not be considered. (Opposition at p. 4.) The unsigned, unauthenticated paper is a copy of the Trust Transfer Deed recorded on May 23, 2018 as document number 20180509199. The Court may take judicial notice of the existence and recordation of real property records, including deeds of trust, when the authenticity of the documents is not challenged, as well as a variety of matters that can be deduced from the documents. (Fontenot v. Wells Fargo Bank, N.A. (2011) 198 Cal.App.4th 256, 264-265.) [A] court may take judicial notice of the fact of a documents recordation, the date the document was recorded and executed, the parties to the transaction reflected in a recorded document, and the documents legally operative language, assuming there is no genuine dispute regarding the documents authenticity. From this, the court may deduce and rely upon the legal effect of the recorded document, when that effect is clear from its face. (Id. at p. 265.) The request for judicial notice is granted to the extent explained above. B. The Deed Does Not Show that Defendant Lacks Any Interest in the Property. Defendant argues that it did not own, possess, or control the property. (See Demurrer at p. 7.) The Trust Transfer Deed reflects a conveyance of real property from JOAN H. PLOTKIN, Trustee of the PLOTKIN TRUST AGREEMENT dated August 28, 1991 to JOAN H. PLOTKIN, Trustee of the SURVIVORS TRUST under the PLOTKIN TRUST AGREEMENT dated August 28, 1991 on May 16, 2018. The legal effect of the Deed is a transfer of the property on May 16, 2018. It does not show that Defendant had no interest in the property at any time thereafter until the September 5, 2020 fire. The demurrer is overruled on this ground. C. Plaintiffs Negligence Causes of Action Are Duplicative. Defendant argues that the causes of action for negligence per se (second cause of action), negligent hiring (third cause of action), and negligent infliction of emotional distress (fourth cause of action) are duplicative of the first cause of action for negligence. (Demurrer at pp. 7-89) Plaintiffs first four cases of action all allege different theories of negligence and should be combined into a single cause of action for negligence. The demurrer is sustained on this ground. D. There Are No Facts About Defendants Conduct. Defendant argues that there are no allegations about its involvement in any wrongdoing or any relationship with Plaintiffs. (See Demurrer at pp. 7-14.) Plaintiffs sued Joan Plotkin and Doe Defendants, and they later identified Defendant as Doe 3. The allegations that all Does are responsible for Plaintiffs harm and that they are the agents, servants, employees, and/or joint venturers of their co-defendants are conclusory and lack facts. (FAC ¶¶ 7-8.) Each cause of action is brought against All Defendants. However, Plaintiffs specifically seek equitable relief, monetary and punitive damages against Defendant JOAN PLOTKIN, a California landlord. (FAC ¶ 1.) The landlords failed to properly fix the roof, the absence of a swamp cooler caused an electrical fire, and the negligence and lack of care by the landlord caused this situation which led to the fire. (See, e.g., FAC ¶¶ 19, 24, 27; 31, 35, 40.) The lack of maintenance, the poor conditions, and the fire gave rise to all of Plaintiffs damages. (See, e.g., FAC ¶ 50, 62, 69, 77, 85, 97.) There are no specific facts about Defendants involvement. The demurrer to all causes of action is sustained on this ground. E. Conclusion Defendant Milner Roofing Inc.s demurrer is SUSTAINED with 30 days leave to amend. On January 11, 2024, the Court sustained Joan Plotkins demurrer to the third, fourth, fifth, seventh, and tenth causes of action with 30 days leave to amend. Plaintiffs did not timely file an amended complaint. Joan Plotkin then filed an answer to the remainder of the FAC on March 7, 2024. Accordingly, this orders grant of leave to amend is limited to the allegations about demurring Defendant Milner Roofing Inc. Moving party to give notice. Parties who intend to submit on this tentative must send an email to the Court at SMCDEPT48@lacourt.org indicating intention to submit. If all parties in the case submit on the tentative ruling, no appearances before the Court are required unless a companion hearing (for example, a Case Management Conference) is also on calendar. Dated this 29th day of August 2024 Hon. Thomas D. Long Judge of the Superior Court

Ruling

Maria Aguilar Barajas, et al. vs Eduardo Flores, et al.

Aug 30, 2024 |23CV-04351

23CV-04351 Maria Aguilar Barajas, et al. v. Eduardo Flores, et al.Order to Show Caue re: DismissalAppearance required. Parties who wish to appear remotely must contact the clerk of thecourt at (209) 725-4111 to seek permission and arrange for a remote appearance. Appearto address Plaintiff’s failure to appear at the June 25, 2024, Case ManagementConference and at the July 31, 2024, Order to Show Cause re: Sanctions. Absent anappearance by Plaintiff and a showing of good cause, this matter will be DISMISSEDWITHOUT PREJUDICE.

Ruling

BYRD vs YANEZ

Aug 26, 2024 |CVPS2403104

Motion to be Relieved as Counsel forCVPS2403104 BYRD vs YANEZZACHARY BYRDTentative Ruling: Grant. No opposition was filed. The Court will sign the proposed order lodged at thetime the motion was filed. Counsel are reminded that they are not relieved until proof of service of thesigned order upon their client has been filed with the Court.

Ruling

JUAN PEREZ ROJAS, ET AL. VS CALIFORNIA DEPARTMENT OF TRANSPORTATION, ET AL.

Aug 28, 2024 |Renee C. Reyna |21STCV40615

Case Number: 21STCV40615 Hearing Date: August 28, 2024 Dept: 29 This matter has been transferred to a different department. The hearing must be renoticed in the new department.Moving party to give notice.

Ruling

JOHN ROE VS MADELINE ISABEL CORDOBA, ET AL.

Aug 29, 2024 |22STCV32918

Case Number: 22STCV32918 Hearing Date: August 29, 2024 Dept: 14 #13 Case Background Plaintiff alleges that Defendants falsely accused him of giving one of the Defendants herpes. Defendants allege that Plaintiff did in fact give this woman herpes. The relevant procedural history is as follows: On October 14, 2022, Plaintiff filed his First Amended Complaint (FAC) for (1) Defamation, (2) Libel, (3) Slander, (4) Intentional Infliction of Emotional Distress (IIED), (5) Fraudulent Concealment, (6) Civil Extortion, and (7) Libel against Defendants Madeline Isabel Cordoba (Cordoba), Justin Daily (Daily), Reed Aljian (Aljian), and Daily Aljian LLP (Firm).1 The first five causes of action are asserted against Defendant Cordoba only. The last two causes of action are asserted against the Attorney Defendants only. On August 22, 2023, Plaintiff filed his Second Amended Complaint (SAC) for (1) Defamation, (2) Libel, (3) Slander, (4) Intentional Infliction of Emotional Distress (IIED), (5) Civil Code § 1708.85, and (6) Negligence against Defendant Cordoba. On April 18, 2023, Defendant Cordoba filed her First Amended Cross-Complaint (Cross-Complaint) for (1) Sexual Battery, (2) Intentional Misrepresentation, (3) Concealment, (4) Negligent Misrepresentation, (5) Negligence, and (6) IIED against Plaintiff and ROES 1-35. On February 27, 2024, the Court granted Plaintiffs motion for a protective order. On June 5, 2024, Plaintiff filed this motion to seal. Instant Pleading Plaintiff moves to seal documents he filed in support of his motion for summary judgment or summary adjudication. Decision Plaintiffs motion to seal the documents submitted in support of his motion for summary judgment or summary adjudication is GRANTED. The Court orders Exhibits H, I, J, K, L, and M to the Declaration of Michael Killingsworth submitted in support of Plaintiffs motion for summary judgment or summary adjudication sealed. Discussion Pursuant to California Rules of Court Rule 2.550 the court may seal a record only if it expressly finds facts that establish: (1) There exists an overriding interest that overcomes the right of public access to the record; (2) The overriding interest supports sealing the record; (3) A substantial probability exists that the overriding interest will be prejudiced if the record is not sealed; (4) The proposed sealing is narrowly tailored; and (5) No less restrictive means exist to achieve the overriding interest. (Cal. Rules of Court, rule 2.550(d).) In Hinshaw v. Superior Court (1996) 51 Cal.App.4th 233, 242, the court stated that private, non-governmental parties have a privacy interest in maintaining confidentiality of settlement agreements that contain personal financial information. The sealing of court documents is not permitted solely based on the agreement of the parties "without a specific showing of serious injury." (Huffy Corp. v. Superior Court (2003) 112 Cal.App.4th 97, 106.) Regarding the serious injury, "[b]road allegations of harm, bereft of specific examples or articulated reasoning, are insufficient." (Huffy, supra, 112 Cal.App.4th at p. 106) (quoting In re Cendant Corp. (3d Cir. 2001) 260 F.3d 183, 194.) Here, Plaintiff moves to seal exhibits H, I, J, K, L, and M to the Declaration of Michael Killingsworth which he submitted in support of his motion for summary judgment or summary adjudication. These documents include: Exhibit 1: Copies of the subpoenas at issue. Exhibit H: Defendants testing results from May 13, 2022. Exhibit I: Defendants Communications to Plaintiff threatening to contact Plaintiffs workplace. Exhibit J: Medical testing results of one of Defendants other sexual partners. Exhibit K: Communications between Defendant and her doctor. Exhibit L: Communications between Defendant and Plaintiff. Exhibit M: Defendants medical records from May 25, 2022. Plaintiff argues that the documents include information marked for protection under the protective order in this action. Plaintiff seeks to seal these documents to protect Defendants rights under the protective order and to protect Plaintiffs true name and identifying characteristics. The records include medical records, sensitive communications and images, and Plaintiffs true name. It is reasonable to infer that these documents are confidential or highly confidential as defined in the protective order because the content of the documents could harm the parties reputations if they are made public. The Court finds that an overriding interest exists which overcomes the publics right to access these materials and supports sealing the records. Both parties in this action will be prejudiced if the records are not sealed. Finally, the sealing is narrowly tailored and there are no less restrictive means of achieving the overriding interest. Therefore, the motions to seal are granted. Conclusion Plaintiffs motion to seal the documents submitted in support of his motion for summary judgment or summary adjudication is GRANTED. The Court orders Exhibits H, I, J, K, L, and M to the Declaration of Michael Killingsworth submitted in support of Plaintiffs motion for summary judgment or summary adjudication sealed.

Ruling

KRYSTAL RENEE CASTRO, ET AL. VS THOMAZ PHILLIP COUSSEAU, ET AL.

Aug 27, 2024 |Renee C. Reyna |21STCV31342

Case Number: 21STCV31342 Hearing Date: August 27, 2024 Dept: 29 Castro v. Cousseau 21STCV31342 Motion to be Relieved as Counsel, filed by Plaintiffs Counsel Albert Abkarian & Associates. Background On August 24, 2021, Krystal Renee Castro, Victor Andres Avila, Brisstelle Avila, and Viktor Amias Avila filed a complaint against Thomaz Phillip Cousseau, Nissan North America Inc., and Rebecca Diane Mullin (collectively Defendants) for negligence cause of action arising out of an automobile collision on July 18, 2020. On October 26, 2021, Defendants filed an answer. In June 2023, the Court granted the petition for approval of minors compromises in this case. An OSC re proof of deposit was set and continued several times; in the interim, it appears that counsel has been unable to communicate with the client (guardian ad litem). On June 20, 2024, Albert Abkarian & Associates (Counsel) filed a motion to be relieved as counsel for Plaintiff Krystal Renee Castro (Plaintiff). No opposition has been filed. Legal Standard The court may order that an attorney be changed or substituted at any time before or after judgment or final determination upon request by either client or attorney and after notice from one to the other. (Code of Civ. Proc., § 284(b).) An attorney is permitted to withdraw where conflicts between the attorney and client make it unreasonable to continue the representation. (See Cal. Rules of Prof. Conduct 3-700(C)(1).) The determination whether to grant or deny a motion to withdraw as counsel lies within the sound discretion of the trial court. (Manfredi & Levine v. Superior Court (1998) 66 Cal.App.4th 1128, 1133.) An application to be relieved as counsel must be made on Judicial Counsel Form MC-051 (Notice of Motion and Motion) (Cal. Rules of Court, rule 3.1362(a)), MC-052 (Declaration) (Cal. Rules of Court, rule 3.136(c)), and MC-053 (Proposed Order) (Cal. Rules of Court, rule 3.1362(e)). Further, the requisite forms must be served on the client and all other parties who have appeared in the case. (Cal. Rules of Court, rule 3.1362(d).) The court may delay effective date of the order relieving counsel until proof of service of a copy of the signed order on the client has been filed with the court. (Cal. Rules of Court, rule 3.1362(e).) Discussion Counsel has filed the Notice, Declaration, and Order to be Relieved as Counsel. However, Counsel fails to include all future hearings, including the OSC re Proof of Deposit set for September 25, 2024, on both the Declaration and Order. Moreover, the Court has the following additional concerns: (1) a guardian ad litem cannot represent a minor without counsel, and granting the motion could leave the case in an uncertain state; and (2) it is unclear to the Court whether the settlement funds have been paid and, if so, whether they have been deposited into a blocked account as ordered. Accordingly, the motion is DENIED without prejudice. Conclusion The motion to be relieved as counsel is DENIED without prejudice. Moving counsel to give notice.

Document

Fatmata M. Turay, Deion R. Hylton v. Md Raihan, Uber Technologies, Inc., Uber Usa, Llc, Kevin A. Miller, Tiernan Kiefer

Mar 23, 2022 |Lisa S. Ottley |Torts - Motor Vehicle |Torts - Motor Vehicle |508414/2022

Document

Pedro Flores v. The New York City Housing Authority, Nycha I Housing Development Fund Corporation

Aug 03, 2017 |Landicino |Torts - Other Negligence (Labor Law) |Torts - Other Negligence (Labor Law) |515064/2017

Document

Mar 29, 2016 |Devin P. Cohen |Torts - Other (Fall) |Torts - Other (Fall) |504664/2016

Document

Bernardo Marin, Janet Marin v. 41 Harrison Av Llc

Apr 14, 2016 |Devin P |Torts - Other (Fall) |Torts - Other (Fall) |505903/2016

Document

Alesia Kelly As Administrator of the Estate of JULIANA S. ROSS v. Visiting Nurse Service Of New York

Nov 18, 2022 |Ellen M. Spodek |Torts - Medical, Dental, or Podiatrist Malpractice |Torts - Medical, Dental, or Podiatrist Malpractice |533854/2022

Document

Michele Johnson v. 705-711 Franklin Realty Llc

Oct 01, 2018 |Larry D |Torts - Other Negligence (Slip and Fall) |Torts - Other Negligence (Slip and Fall) |519675/2018

Document

Mar 29, 2016 |Devin P. Cohen |Torts - Other (Fall) |Torts - Other (Fall) |504664/2016

Document

David Lopez, Iris Guzman v. Kamco Services, Llc, D'Onofrio General Contractors Corp.

Jul 16, 2018 |Carolyn E. Wade |Torts - Other Negligence (Labor Law) |Torts - Other Negligence (Labor Law) |514485/2018

EXHIBIT(S) - J (Motion #3) EXH J - Records of Dr. Saba - Northwell Health Phy - EXH J - Records of Dr. Saba - Northwell Health Phy Redacted October 20, 2023 (2024)

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