2019 11:12 AM

EXHIBIT C

FILED: KINGS COUNTY CLERK 03/22/2019 11:12 AM INDEX NO. 522196/2016

NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 03/22/2019

JOSEPH M. PALMlOTTO

Attorney at Law

50 Jeanette Avenue

Staten Island, New York 10312

Phone: 917-6474903

e-mail: [email protected]

November 14, 2018

Attn. Alexandra D. Slater, Esq.

McAloon & Friedman, P.C.

123 William Street

New York, New York 10038

Re: Kin K. Lam v. Jerome D. Taylor, M.D.,, et al.

Dear Ms. Slater:

Enclosed please find duly signed authorizations for the following:

1. Authorization to interview Dr. Serur.

2. Hañdwritten authorization to obtain employment records from Aegis Capital.

Please advise convcniêñt dates for Dr. Taylor's examination before trial.

Very truly yours,

Joseph M. Palmiotto



June 4, 2018

Daniel B. Henderson, Esq.


123 William Street


Re: Kin K. Lam v. Jerome D. Taylor, M.D., , et al.

Dear Mr. Henderson:

In response to your letter of May 10, 2018 please be advised that we previously provided your

office with all of the authorizations and responses to discovery demands which you now indicate are

"outstanding'. In fact, many of the authorizations you requested have been furnished on multiple

occasions because your firm keeps requesting the same authorizations over and over again.

Enclosed please find copies of authorizations with cover letters as well as copies of the Plaintiff's

responses to discovery demands.

As we previously indicated to your office we will not provide authorizations for left knee surgerybecause it is so remote in time and iiivülves a body part not relevant to this action.

Very truly yours,

Joseph M. Palmiotto



Phone: 212-208-1446 Fax: 212-858-7750

THE PALMIOTTO LAW FIRM

140 Broadway, 46th Floor


e-maib FORENSICALNY@AOLCOM

May 14, 2018

Alexander P. Lev, Esq.


123 William Street



Dear Mr.Lev:

Enclosed please find duly signed authorizations for the fc::cwiiig:

1. Bellvue 911 Event Clinic

2. D. Bhatt, MD3. Paul Park, MD4. Mengko Tseng, MD5. Jonathan Kuo, MD

truly yours,

Joseph M. Palmiotto



‰ne: 212-208-1446 Fax: 212-858-7750




e-maib [email protected]

March 26, 2018

Lawrence W. Burnett, Esq..McAloon & Friedman, P.C.123 William StreetNew York, New York 10038


Dear Mr.Burnett:

Enclosed please find an additiene!, original authorization for Maimonides Madical Center.

Very truly yours,

Joseph M. Palmioû



Phone: 212-208-1446 Fax:212-858-7750





May 14, 2018



123 William Street


Re: Kin K. Lam v. Jerome D. Taylor, M.D.,, et al.

Dear Mr.Lev:


1. Bellvue 911 Event Clinic

2. D. Bhatt, MD3. Paul Park, MD4. Mengko Tseng, MD

5. Jonathan Kuo, MD

.Yeg truly yours,

Joseph M. Palmiotto



Phone:212-208-1446 - Fax: 212-858-7750





March 26, 2018

Lawrence W. Burnett, Esq..McAloon & Friedman, P.C.123 William StreetNew York, New York 10038


Dear Mr.Burnett:

Enclosed please find an additional, original authorization for Maimonides Medical Center.

Very truly yours,

Joseph M. Imiofto



March 22, 2018

Lawrence W. Burnett, Esq..


123 William Street



Dear Mr.Burnett:

This is in response to the compliance conference Order of 2/14/18.

Plaintiff previously respünded to Defendant Taylor's combined demands and these responses

were filed with the Court.

Lien Information: Medicaid lien information was previously provided (copy enclosed). Plaintiff is

not in possession of any lien information other than the Medicaid lien letter of June 19, 2017.

Empicyment authorization records: Previously provided on 10/18/17.

Collateral Source Authorizations: Previously provided.

Deféñdant's 9/12/17 Demands: Authorizations provided on 10/23/17. Additionally, Plaintiff

furnished Arons authorizations on 10/23/17.

Defendants demands for authorizations dated 12/6/17: Previously provided.

Defendants demands dated 9/18/17. Previously provided.

With respect to your firm's letter of December 18, 2017 please note the fcl|üwing.

1. Authorizations for the plaintiff's most recent psychiatrists at WTCEHC are enclosed. Drs , Park,

Bengsten and Atkins.

2. The authorization for the primary care physician, Dr. Kimbel was provided to your office in May,

2017.



Page -2-

3. The authorizations for the neurologist seen in 2017, Jeff Davis, M.D. and Jai Y. Chong, MD were

provided on 8/18/17 and again on 9/8/17.

4. The authorization for the CT scan in 2017, NYU Langone and was provided on 12/5/17.

5. The 911 clinic at Bellvue is the World Trade Center Health Center and we have provided you

with the authorization for those Drs. as well as set forth below.

6. Facility at which plaintiff received treatment after 2/22/17 fall was also NYU Langone which was

previously provided.

7. Plaintiff does not know of any pain Dr. seen after Dr. Kuo. If you provide us with a name we will

respond.

With respect to your firm's letter of 8/21/17 please note the following:

1. We previously objected to providing authorizations for left knee surgery and hospital where

it was performed because we will not provide authorizations for unrelated body parts,

particularly when the treatment is ten to fifteen years prior to the malpractice at issue in

this case.

2. The authorization for the Dr. who performed the colonoscopy in 2015 , Jeremy Schwartz,

M.D. was provided on 10/18/17. We also provided authorizations for Weil Cornell Medicine

and Beth Israel.

3. The authorization for Mt. Sinai Beth Israel was provided again in May 2017.

4. Dr. Jercme- This is your client, Jerome Taylor, M.D. who treated plaintiff for hemorrhoids.

5. Authorization for Lyubov Izyayeva is enclosed although my client does not know who this is

so we have no address. If you find an address you can fill it in.

6. Authorization for Dr. Lisa Anthony was provided on 5/21/17 and again on 9/5/17.

7. Authorization for Maimonides was provided on 9/5/17 for the second time.

Please note we also provided your office with authorizations for plaintiff's other treatingpsychiatrists at the World Trade Center clinic including Dr. Bhatt and Dr. Priyanka Upadhyaya.

Enclosed please find new authorizations for World Trade Center Clinic at Bellvue as well

as authorizations for Paul Park, M.D. Eric Bengsten, M.D. and Philip Atkins, M.D.

Very truly yours,

Joseph M. Palmiotto



October 23, 2017



123 William Street



Dear Mr.Lev:


1. Anthony Azar, M.D.

2. Robert Lin, M.D.

3. Deborah Sonenblick, M.D.

4. Ashral Samaan, MD5. Vidya Malhotra, M.D.

We also enclose herewith, Arons authorizations for Anna Serur, M.D. and Rebecca Rhee, M.D.

Please note that we do not have an address for Ashral Samaan, M.D. A computer check reveals

that the correct name is Ashraf Samaan, M.D. so we included an additional authorization with what I

believe is the correct spelling. It appears that Dr.Samaan is an ariesthesiologist.

Please note that Mr. Lam never visited any Caris or Quest Diagnostics office and therefore we do

not have an appropriate address for these providers.

I appreciate your limiting your requests to providers you bêlieve provided medical care relevant

to this action and I have enclosed my letter to Heidell, Pittoni regarding their requests.

Very truly yours,

Joseph M. Palmiotto



October 18, 2017



123 William Street



Dear Mr.Lev:


1. RI Michaels Holding, Inc.

2. Obsidian Financial Group, inc.

3. Aegis Capital Corp.

4. Quest Diagnostics.

5. NY Presbyterian.

6. Jeremy Schwartz, M.D.

Please note that Mr. Lam never visited any Quest Diagnostics office and therefore we do not have

an appropriate address for Quest. His blood samples were taken by the physician and apparentlysent to Quest for analysis.

Very truly yours,

Joseph M. Palmiotto



Phone: 212-208-1446 Fax: 212-858-7750




e-mail: FORENSICALNY@AOLCOM

August 18, 2017



123 William Street



Dear Mr.Lev:

Enclosed please find duly signed authorizations for the folicwing:

1. Page Baker, PT., Metro Sports Medicine.

2. Grace Sun, M.D., Weil Cornell Medicine.

3. Priyanka Upadhyaya, M.D. WTC Envirõñrñêntal Health Center.

4. Ji Y. Chong, M.D., Weil Cornell Medicine.

Very truly yours,

Joseph MM'imtl2Ltto---



December 5, 2017



123 William Street


Re: Kin K. Lam v. Jercrñe D. Taylor, M.D., , et al.

Dear Mr.Lev:

Enclosed please find duly signed authorizations for the hospita! and neurciagist who treated

mr. Lam for a concussion.

1, NYU Langañe Medical Center.

2. Yevgency Azrieli, M.D.

Very truly yours,

Joseph M. Palmiotto



SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF KINGS

------- X

KIN K. LAM,Index No.522196/2016

Plaintiff,-against-

JEROME D. TAYLOR, M.D., and MOUNT SINAl

HEALTH SYSTEMS, INC.,MOUNT SINAI BETH ISRAEL

f/k/a BETH ISRAEL MEDICAL CENTER and

PHILLlPS AMBULATORY CARE CENTER,

Defendants.

PLAINTIFF'S OPPOSilTON TO DEFENDANT TAYLOR'S CROSS-MOTION

JOSEPH M. PALMIOTTO

Attorney for Plaintiff

50 Jeanette Avenue

Staten Island, NY 10312

917-647-4903



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2019 11:12 AM