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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

CATHERINE WALSH,

Plamtifl(s),

-against-

CRP/CAPSTONE 14W PROPERTY OWNER, L.L.C.,,

Defendant(s).

-X

-X

AFFIRMATION IN

OPPOSITION TO

MOTION TO DISMISS

Index No. 161190/2014

Hon. Carol R. Edmead

JEFFREY E. LITMAN, an attorney admitted to practice law before the Courts of the State

of New York, hereby afSrms the truth of the following under the penalties of perjury and pursuant

to Civil Practice Law and Rules §2106 and 22 NYCRR § 130:

1. I am a member of the law firm of LITMAN & LITMAN, P.C., attorneys for the

plaintiff(s), and as such am fully familiar with all the facts and circumstances of this case.

2. I submit this affirmation in opposition to the motion of the defendant(s) for an order

dismissing plaintiffs complaint and/or precluding testimony and evidence at the time of trial and/or

compelling discovery pursuant to CPLR Section Article 31.

3. This is an action for personal injuries sustained as a result of a fall which occurred

November 10, 2011.

4. Contrary to the motion of the defendants, on August 28, 2015, the plaintiff

provided the attached discovery in full compliance with all court orders, stipulations, and

demands for discovery.

FILED: NEW YORK COUNTY CLERK 02/15/2016 07:04 AM INDEX NO. 161190/2014

NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 02/15/2016

5. Civil Practice Law and Rules § 3126 entitled Penalties for refusal to comply with order

or to disclose states:

"If any party, or a person who at the time a deposition is taken or anexamination or inspection is made is an officer, director, member,employee or agent of a party or otherwise under a party's control,refuses to obey an order for disclosure or wilfully fails to discloseinformation which the court finds ought to have been disclosedpursuant to this article, the court may make such orders with regardto the failure or refusal as are just, among them:

1. an order that the issues to which the information is

relevant shall be deemed resolved for purposes of theaction in accordance with the claims of the partyobtaining the order; or

2. an order prohibiting the disobedient party fromsupporting or opposing designated claims or defenses,from producing in evidence designated things or itemsof testimony, or from introducing any evidence of thephysical, mental or blood condition sought to bedetermined, or from using certain witnesses; or

3. an order striking out pleadings or parts thereof, orstaying further proceedings until the order is obeyed,or dismissing the action or any part thereof, orrendering a judgment by default against thedisobedient party.

6. As has been repeatedly held, dismissal of a plaintiffs complaint for an alleged failure

to comply with discovery requests or court orders pursuant to CPLR § 3126 should not be granted

unless the lack of comphance was "willful, contumacious, deliberate or in bad faith" (Magrabi v. City

of New York. 211 A.D.2d 422,423,621 N.Y.S.2d 39; see. Van Inwegen v. Lucia. 192 A.D.2d 834,

596 N.Y.S.2d 542; Hocevar v. 260 Honig Indus. Diamond Wheel 172 A.D.2d 588, 568 N.Y.S.2d

145; Bermudez v. Laminates Unlimited. 134 A.D.2d 314, 315, 520 N.Y.S.2d.

7. The plaintiff submits that the drastic penalty of dismissal or preclusion is clearly not

warranted in the instant case. It is well settled that the extremely severe sanction of preclusion for

failing to comply with discovery is warranted only where the moving party has sufficiently

demonstrated that the failure to comply was willful, contumacious, or in bad faith. See Harris v. City

ofNew York, 211 A.D.2d 663 (2d Dep't 1995); Lestinqi v. City of New York, 209 A.D.2d 384 (2d

Dep't 1994); Jeffcoat v. Andrade, 205 A.D.2d 374 (1st Dep't 1994); Read v. Dickson, 150 A.D.2d

543 (2d Dep't 1989) ; Dauria v. Terry, 127 A.D.2d 459 (1st Dep't 1987); Bassett v. Bando Sanqsa

Company, Ltd., 103 A.D.2d 728 (1st Dep't 1984).

8. Contrary to the motion of the defendants, on August 28, 2015, the plaintiff

provided the attached discovery in full compliance with all court orders, stipulations, and

demands for discovery.

WHEREFORE, for the foregoing reasons, it is respectfully requested that this court deny

defendants' motion in its entirety and that this Court issue any other, further and different reliefit may

deem just, proper and equitable.

Dated: Woodbury, New YorkFebruary 9, 2016

JEFFREY E. LITMAN

LITMAN & LITMAN, P.C.ATTORNEYS AT LAW

JeffLltmanEsq^a^yahoo.com

TELEPIIO.NE

(516) 353-1500FACSIMILE

(516)908-4210

EL'GENK Ll iMAN

JEFFREY E. LITMAN •

KENNETHS, LITMAN

■ALiinADxtiT'rr.u iNcnN.NrcTiciir

5 BERING COURT

WOODBURY, NEW YORK 11797

Law Offices of Tobias & Kuhn100 William Sircci, Suite 920New York. NY 10038

Augiisl 28, 2015

Re: Catherine Walsh v. CRP-Crapstone 14W Property Owner, L.L.C.DateofLoss: 11/10/2011Your File No.: Y43L 04134-001

Dear Counselors:

In full compliance with the enclosed Preliminary Conference Order and all prior requests, demands,and notices for discovery and inspection and a bill of particulars, enclosed is a Responsive Bill ofParticulars, HIPAA compliant authorizations and a power ofattorncy pursuant to Public Health LawSection 18.

The plainlifl' does not possess opposing party sialenicnis or photographs. PlaintilT is not aware ofany non-party witnesses. There are no collateral sources other than Workers' Compensaiion. TheplainiifTlias not retained any experts at this lime. Thank you.

Very truly y i.

JHLimkEnclosures.

JEFFR . LITMAN

*.' »

SUPREME COURT OF THE STATE OF NKW YORK, COUNTY OF N^ YORKINDIVIDUAL ASSIGNMENT PART [(« JUSTICE]

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

CATHERINE WALSH,

Plamti£Q[s),

-against-

CRP/CAPSTONE 14W PROPERTY OWNER, L.L.C.,,

RESPONSIVE

VERIFIED BILL OF

PARTICULARS

Index No. 161190/2014

Defendant(s).

Plaintifi((s), by attorney, JEFFREY E. LITMAN, ESQ., pursuant to CPLR Rule 3043,

responding to the demand for a verified bUI ofparticulars of the defendant(s), states:

1. The residence address of plaintiff at the time of the alleged occurrence and at present.

62 Highland Avenue, Leonardo, NJ 07737.

2. The date ofbirth of each plaintiff

3. The social security number of each plaintiff

The date and time of day of the alleged occurrence.

Thursday, November 10,2011 at approximately 10:30 a.m.

The location of the alleged occurrence in sufficient detail to permit identification.

7"* Floor Kitchen of Sadlier Publishing, 9 Pine Street, New York, NY 10005.

The specific acts and/or omissions constituting the negligence claimed.

On November 10, 2011, the plaintiff, CATHERINE WALSH slipped and fell on a wateryslippery substance while she was walking in the 7th Floor Kitchen of Sadlier Publishing, 9Pine Street, New York, NY 10005 due to the negligent failure ofthe defendants, their agents,servants, employees, and/or licensees to properly maintain the floor in a reasonably safe

Page 1 of 6

condition.

PlaintifTwas walking at the aforementioned location at the aforementioned time at the pointhereinbefore described, in the usual way, using all due care and caution, and ignorant of theunsafe, dangerous, and slippery condition of said floor, at that place she slipped and foil withgreat force upon said M. Said foil was occasioned without any foult or negligence on thepart of plaintiff and solely by reason of the foult and negligence of defendants, its ofBcers,and agents hereinbefore mentioned.

The above mentioned occurrence and the results thereof were caused by the negligence ofthe defendants and/or defendants' servants, agents, employees and/or licensees in theownership, operation, management, maintenance and control of the aforesaid premises; incausing allowing and permitting said premises at the place above mentioned to be created,become and remain for a period of time after notice, either actual or constructive, in adangerous and/or hazardous condition; in causing, allowing and permitting a trap likecondition to exist at said location; in foiling to maintain the aforesaid premises in areasonably safe and proper condition; in causing, allowing and permittmg an obstruction toplaintiffs safe passage at said location; in foiling to provide plaintiff with safe and properingress and egress on the premises; in causing, allowing, creating and permitting theexistence of a defective area on the aforesaid premises to interfere with and prevent plaintiffssafe passage; in causing, allowing, creating and permitting the existence of a condition whichconstituted a trap, nuisance, menace and danger to persons lawfulfy on said premises; infoiling to have taken necessary steps and measures to have prevented the above mentionedlocation from being used while in said dangerous condition; in foiling to give plaintiffadequate and timely signal, notice or warning of said condition; in negliiently andL 9^^esslycausing and permitting the above said premises to be and remain in s3^ conditi^^r anunreasonable length of time, resulting in a hazard to the plaintiff and others; in foiling to takesuitable and proper precautions for the safety of persons on and using said premises; and inbeing otherwise negligent and careless under the circumstances all of^lw^^g^g^dy|Mt andproximate cause of the incident involved herein and injuries sustainoS tlierefromi W

That the defendant(s), their agents, servants and/or employees created the conditioncomplained of and/or acquired actual and/or constructive notice of the dangerous anddefective conditions existing and complained of and despite same foiled to timely andproperly remedy same.

7. Identify each and every ordinance, regulation, and statute that the answering defendants areclaimed to have violated.

Not applicable.

Page 2 of 6

8. Describe the injuries sustained by the plaintiff, indicating the exact location, nature, extentand duration of each injury, their sequalae, and a description of those claimed to bepermanent.

1. Interveitebral disc disease requiring fusion surgery.

The above injuries, resulting disabilities and involvements are acconq}anied by severe andpermanent pain, suffering, loss of enjoyment of life, discomfort, disability, restriction ofmotion, and have directly affected the skin, fescia, muscles, tendons, cartilage, ligaments,tissues, blood vessels, nerves, capsule, blood supply and soft tissues in and about theinvolved areas and sympathetic and radiating pains, from all of which the plaintiff suff^s,still suffers and may permanently suffer. As a direct result of the accident and the injuriesherein sustained, the plaintiffe suffered severe shock to their nervous systenos. The plaintiffverily believes that all of the injuries herein above described, with the exception of bruisesand contusions, are permanent and progressive in nature. The plaintiffe' injuries aggravatedpre-existing degenerative changes in the body. The plaintiffe had latent conditions whichmade the plaintiffe more susceptible to injury. The plaintiffs may require surgery,radiographic diagnostic testing, physiother^y and medication and may require the same inthe future. The plaintiff may permanently su^r from the aforesaid injuries and their effectsupon his nervous system and nmy limit him in his activities and in his life. The plaintiff maybe restricted in his normal life and activities and may permanently require medical andneurological care and attention in the fiiture to treat the resulting pain, deformity, disability,infections, stifGiess, tenderness, weakness and restriction and limitation of motion andpossible loss of use of the above mentioned parts, atrophy, anxiety and mental anguish andhave further substantially prevented this plaintiff from enjoying the normal fruits of hisactivities, including but not limited to social, educational and economic. The plaintiffereserve the right to amend and suppfement this Verified Bill of Particulars prior to the timeof trial, to set forth such other and fiirther injuries and permanent effects of the injuries asthey become more apparent pursuant to the Civil Practice Law and Rules.

9. State whether plaintiffe claim any limitation of motion, loss of use, or loss of function as aresult of the injuries alleged, and if so state the nature, extent and degree of permanencythereof.

Yes. Intervertebral disc disease requiring fiision surgery.

10. Set forth the names and addresses o£ a. AU hospitals where each plaintiff was treated and/orconfined as a result of the alleged occurrence, and state the length of time plaintiff wastreated or confined in said hospital or hospitals including the dates of admission anddischarge, b. All physicians or other medical providers who treated each plaintiff as a resultof the alleged occurrence.

Inq)roper demand. Authorizations for all healthcare providers will be provided underseparate cover.

Page 3 of 6

11. State the length of time each plaintiff was confined to a. bed; b. home; following the allegedoccurrence, and state the dates of the confinement.

To date.

12. State the length of time each plaintiff claims to have been: a. Totally disabled; b. Partiallydisabled: c. Unable to pursue his/her usual occupation.

To date.

13. Set forth the amounts claimed to have been sustained as special damages for: a. Physicians'services; b. Medical supplies; c. Hospital eiqpenses; d. Nurses* services; e. X-ray expenses;f. Property damage.

$1,500,000.00 estimated.

14. State each plaintiffs occupation, and the name and address of plaintiffs eiiq>loyen a. at thetime of the accident; b. and at the present time; c. If plaintiff was seffenqiloyed or engagedin some other pursuit, so state and give the address.

The plaintiff was an enq)loyee of Sadlier Publishing, 9 Pine Street, New York, NY 10005.

15. For each plaintiff state a. the length of time, giving specific dates, plaintiff was incapacitatedfi m employment or firom attending to his or her usual duties and vocation as a result of thealleged occurrence; b. the amount of earnings or wages claimed to have been lost and; c. therate of wages or basis of remuneration received by the plaintiff.

To date and lost income/salary in the amount of $600,000.00 estimated.

16. For each plaintiff, if plaintiffwas a student at the time of the alleged occurrence, set forth thename and address of plaintiffs school, the plaintiffs grade level at said school, and the lengthof time plaintiff was unable to attend school.

Not applicable.

17. If loss services, society and consortium is claimed, set forth: a. the length of time claimed forsaid loss; b. the relationship of the plaintiff to the injured part}^ c. the particular servicesclaimed to have been lost or otherwise impaired.

Not applicable.

18. State the part or portion of the premises where the accident allegedly occurred, giving thefloor number and the location thereon if applicable.

1^ Floor Kitchen of Sadlier Publishing, 9 Pine Street, New York, NY 10005.

Page 4 of 6

19. For an alleged occurrence upon a sidewalk* state: a. the distance from the situs to the nearestcon^r of the nearest intersection, id^ifying same; b. the distance and conq>ass directionfrom the situs to the nearest curb; c. the distance and conopass direction from the situs to thebuilding line; d. the address of the building closest to the situs; e. the condition and/orsubstance claimed to have caused the alleged occurrence.

Not applicable.

20. For an alleged occurrence not upon a stairway or sidewalk, set for the condition and/orsubstance claimed to have caused the alleged condition.

Watery slippery substance.

21. Where notice of a condition is claimed, state whether the notice claimed is actual orconstructive, and: a. if actual notice is claimed, state the date, time, place manner, by whomanH to whom such notice was given; b. If constructive notice is claimed, state how long atime the condition existed prior to the alleged occurrence.

The plaintiff contends that the defendants acquired actual or constructive notice and/orcreated the condition complained o£ If actual notice is claimed, it is within the exclusiveknowledge of the defendants.

22. If it is claimed that negligent repairs were made, state: a. When, where, and by whom saidr^airs wwe made; b. The respects in which said repairs were negligently made.

Not applicable.

23. Set for the period of time it is alleged the defect existed.

Not applicable.

24. Set forth the length of time if it is claimed that snow and ice existed at the place of theaccident alleged in the complaint.

Not applicable.

25. Set forth the weather conditions for the date of the accident.

Clear.

Dated: Woodbury, New YorkAugust 28,2015

Page 5 of 6

Yours, etc..

JEKFRHV K. LITMAN, ESQ.

LITMAN & LITMAN. P.C.

Attorneys for Plaintirt^s)

5 Bering Court

Woodbury. NY 11797-2701

Phone: {516) 353-1500

Fax: (516)90«-4210

JeffLilmanEsqf^i-vahoo.comTo:

Law OlTices ofTobia.s & Kuhn

Attorneys for Defendant

CRP/CAPSTONH 14W PROPERTY

OWNER. L.L.C.

100 William Street, Suite 920

New York, NY 10038

(212) 553-8700File No.: Y43L 04134-001

Page 6 of 6

ATTORNEY'S VERIFICATION

STATE OF NEW YORK^

COUNTY OF NASSAU} ss.:

JEFFREY E. LITMAN, an attorney duly licenced to practice law in the Stale ofNcw York,

afftrms the following is tmc under ihe penalties of perjury:

Thai I am the alloraey for the plamliff(s) in the within action and maintain my offices at 5

Bering Court. Woodbury. New York 11797.

That I have read the forcyuing instninicni and l^now the conlenis thereof thai the same is inic

to my own knowledge except as to the matters therein stated to be alleged upon infonnalion and

belief and that as to those matters 1 believe it to be true.

Deponent Ririhcr says that the grounds of his belief as to all matters not stated upon his

knowledge, are based upon wrilien data and reports in my file and upon conversations and

correspondence with the plainlifl^s) and upon the investigation made by the office ol your deponent.

The reason why this verification is made by deponent and not by the piaintiffis) is that the

plaintifT, or one of ihenv reside outside of the County ofNassau, the County wherein your deponent

maintains his office for the practice of his profession.

Dated: Woodbury, New York ^August 28, 2015

JEFFREY E. UTMAN

SUPREME COURT

STATE OF NEW YORK. COUNTY OF NEW YORK Index No. 161190 Year 2014

CATHERINE WALSH,

-against-

Phuntiff(s),

CRP/CAPSTONE 14\V PROPERTY OWNER,

L.L.C.,

DcfendanC($).

RESPONSIVE VERIFIED BILL

OF PARTICULARS

LITMAN & LITMAN, P.C.

Attornty(s) for Plaintiff(s)

OBct »ni Post O&ce Addrtss, Tthpbone

5 BEIUNG COURT

WOODBURY. NEW YORK 11797-2701

(516)353-1500

ToSignature (Rule 130>LI-

JEFFREY E. LITMAN

Attorney(s) for

Service of a copy of tlie within is hereby admiited.

Dated:

PLEASE TAKE NOTICE:

□ NOTICE OF ENTRY

that the within is a (certiRed) true copy oi aduly entered in the office of the clerk of the within named court on

notice of settument

that an order

will be presented for settlement to the HON.within named Court, aton at M.

of which the within is a true copyone of the judges of the

Dated.

Yours, etc. LITMAN & LITMAN. P.C.

A TIORNKYS FOR PI.AINTIFF(S)5 m-RIN'Ci COURT"

\voooin;RY, nfav york 11797-2701

15161353-1500

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINAL

^ OfTiciiil Form No.J MOAUTHORIZATION FOR RELEASF, OF HEALTH INFORMATION PURSUANT TO HIPAA

I This rorm h»s been approved by the New York State Depottment ofllcftltlil

Patient Name 1 DatcofBlnh^ Sncial .Security NumberC/^THERINE WAL^H |Paiiem Address

62 HIGHLAND AVENUE, LEONARDO NJ 07737

I. or my authorized representative, request tliai health inromtalion regarding my carc and treatment he released as set forth on this form:

hi accordance with New York State Law and the Privacy Rule of the Health Insurance Portability and Accountability Act of 1996ilMPAA). I understand that:

1 . This auiliorization may include disclosure of intbrmaiion relating to ALCOHOL and DRUG ABUSE, MENTAL HEALTHI REATMENT. except psychotherapy notes, and CONFIDENHAI. IIIV* RELATED INFORMATION only if I place my initials onthe appropriate line in Item 9(a.l. In the event the health Infomialion described below includes any of these types of inforinallon. and Iinitial the line on the box in hem 9{a). 1 specifically auihori/e release of such information to the pcrsonts) indicated in Item 8,2. It I am authorizing the release of HIV-related, alcohol or drug treatnieiii, or mental iieallh treatment information, the recipient isprohibited from redisclosing such information without my authorization unless permitted to do so under federal or state law. Iunderstand that I have the right to request a list of people who may receive or use my HIV -related information without authorization. IfI experience discrimination because of the release or disclosure of HIV-reiaied information. I may contact the New York State Divisionof Human Right.s at (2l2f 480-2493 or the New York City Commission of Human Rights at 12I2) 306-7450. These agencies arcresponsible for protecting my rights..1, I have ihe right to revoke this authorizjtion at any time by writing to the health care provider listed below. I understand titai I mayrevoke this aiititorizatiun c.xccpl to the extent that action has already been taken based on this authorization.4. I understand that signing this authorization is voluntary. My treatment, payment, enrGlimcni in a healtit plan, or eiigibilit>' forbenefits will not be conditioned upon my authorization of this disclosure.5. Information disclosed under this authorization might be redisclosed by the recipient texcepi as noted above In item 2), and thisredisclosurc may no longer be protected by federal or state law.6. THIS AUTHORIZATION DOES NOT ALT HORIZE VOL TO DISCl.SS MV HEALTH INFOR.MATIDN OR .MEDICAL

C:ARE with anyone other than the attorney or governmental AGENCY SPECIFIED IN ITEM 9 tbt.

7. Nnme and address of heahh provider or entity to release this inrormation:The Mount Sinai Medical Center. One Gustave L. Levy Place New York, NY 10029-6574

8, Name and address ofpersonls) or category- of person to whom this infomialion will be sent:Law Offices of Tobias & Kuhn, 100 William Street, Suite 920 New York, NY 10038

dU>. Specific infonnation to be released:□ Medical Record from (insert dale) to (insert date)[^Lntlre Medical Record, including patient histories, ofilcc notes (except psychotherapy notes), test results, radiology studies, films,

refcrral.s. consults, billing records, insurance records, and records sent to you by other health care providers.QOther: Include: by Iniliaiing)

" Aicohui/Drug TrealmenlMentni Health Information

Authorization to Discuss Health Informution

(b) □ By initialing here v^mhorizeJll^-Rcifllcd Information

Initials'"// Name iifinJividual health care providerto discuss my health information with my attorney, or a governmental agency, listed here:

I Anomcv.'Firm Name or<jovemmcr.tnl .-Xgencv Namci10. Reason for release of information:

I^At request of individual□ Other:

11. Date or event on which this authorization will expire;

END OF LITIGATION

12. If not the patient, name of person signing form:JEFFREY E. LITMAN ATTORNEY AT LAW

13. Aiithority to sign on behalf of patient:POWER OF ATTORNEY PURSUANT TO PUBLIC HEALTH LAW SECTION 18

.^11 items on this form have been completed and ji:^y questions about this form have been amsweied. In addition, I have been provided acopy of the form.

Signature of patient or representative izcd bv law.Date; 8/28/2015

Human (mmunodcfteiency Mrus (h»l caiKcs AIDS. T he Ne^s 1'ork State Public Health Lan protects iaformutioa which reasonably couldidentify' someone 0.1 basing lll\ symptoms or infection and informution regarding 11 person's contacts.

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINAL

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINALOCA Ornciul Korm Nu.; 960

AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA{This form has been approved by the Ncsv \ ork State Department of iicaith|

Patient Name

CaIhERINE WAXlSH * TSocial Security Number

Patient .Address

62 HIGHLAND AVENUE, LEONARDO NJ 07737

I. or my authorized reprcscnialivc, request thai health information regarding my care and treatment he released as set forth on this form:

III accordance with New York State Law and the Privacy Rule of the Health Insurance Portabi1lt>' and Accountability Act of 1996(HIPAA). I understand that:

1. This authorization may include disclosure of information relating to ALCOHOL and DRPC ABl'SE, MENTAL HEALTHTREA'IMENT. except psychotherapy notes, and CONFIDEN'I IAL HIV" RELATED INEORMA'l lON only if 1 place my initials on(he appropriate line in hem 9(a). In the event the health information described below includes any of these types of information, and 1initial (he line on tlie box In Item 9(a). I specincally authorize release ufsuch informHiion to the persoti(s) indicated In Item S.2. [f I arn authorizing the release of HlV-rclaied, alcohol or drug treatment, or mental health treatment information, the recipient isprohibited from redisclosing such information without my authorization unless pemtitled to do .so under federal or state law. 1understand that I have the right to request a list of people who may receive or use my HIV -related information without authorization. Ifi experience discrimination because of the release or disclosure of HIV-related information, 1 nwy contact the New York State Divisionof Human Rights at (212) 480-2493 or the New York Cil>' Commission of Human Rights at (212) 306-7450. These agencies areresponsible for protecting my rights.3. I have the right to revoke this authorization at any time by writing to the health care provider listed below. I understand that I mayrevoke this authorization except to the extent that action has already been taken based on this authorization.4. I understand that signing this authorization is voluntary. Vly treatment, payment, enrollment in a health plan, or eligibility forbenefits will not be conditioned upon my authorization of this di.sclosurc.5. Information disclosed under tliis authorization might be rcdisclosed by the recipient (except as noted above in Item 2), and thisredisciosure may no longer be protected by federal or stale law,

6. THLS ALTHORIZATION DOES NOT AllTHORIZE VOli TO DISCI SS MY HEALTH INFORMATION OR MEDICALCARE WITH ANVO.NK OTHER IHAN THE A ITORNEV OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9 lb\.

7. Name and address of health provider or entity to release this information;Cooper Rehabilitation & Sports, 315 NJ-35, Red BanK, NJ 07701S. Name and address of person(s) or caiegoiy of person to whom this information will be sent:Law Offices of Tobias & Kuhn, 100 William Street, Suite 920 New York, NY 10038

to (insert date)9(ai. Specllic infomutlion to be released:

□ Medical Record from (insert dale)(^Entire Medical Record, including patient histories, office notes (except psychotherapy notes), test results, radiology studies, films,

referrals, consults, billinii records, insurance records, and records sent to you by other health care providers.[x|Other: PHYSICALTHERAPY RECORDS Include: t InJiaiw by InHiaHtifi)

Akohol/Dnig TreatmentMental Health Infoinnation

Authori7.ation to Discu.ss Health Information HIV-Rclated Information

(b) □ By initialing here authorizeIr.iliirls / Name ofindiviilual hcultlt core provider

to discuss my health informatioi^ with my attorney, or a governmental agency, listed here;

(Attornev/1-"imi Name i»r (ioveramcnwl .Aaencv NaiiKi10. Reason for release of information:

I^Ai request of individualU Other:

11. Dale or event on which this authorization will expire:

END OF LITIGATION12. If nut the patient, name of person sisning form:JEFFREY E, LITMAN ATTORNEY AT LAW

13. .Authority to sign on behalf of patient:POWER OF ATTORNEY PURSUANT TO PUBUC HEALTH LAW SECTION 18

All items on ihis form have been completed,copy of the form.

my questions about this form have been answered. In addition. I have been provided a

Date: 8/28/2015Signature of patient or reprcscntaii iutl^i/ed by law.

Human Immunodcllciency V'iryif'thal cause.s AID.S. The New ^ »rk Stale I'ulilic llealtii I.aw pruivcts information utiich reasonably couldIdentify someone us liaviiis HIV symptoms or infcclinn and information regarding a person's contacts.

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINAL

COPY, FAX, OR E-MAiL OF AUTHORIZATION IS VALID AS ORIGINAL^ Or.V Official Forin No.: 960

AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PLRSUANT TO HIPAA|Thb rurrn lisis been npproved by the Nv>v Vurk State Drpiirtincnl uf Health]

A

Patient Name

CATHERINE WALSH

Date of Birth Social Security Number

Patient Address

62 HIGHLAND AVENUE, LEONARDO NJ 07737

[. or my authorized representative, request that health inrormation regarding my care and treatment be released as set forth on this form:

In accordance with New York State Law and the Privacy Rule of the Health Insurance Portability and .\ccounlability Act of 1996(HIPA.\). I understand that;

1. This authorization may include disclosure of information relating to ALCOHOL and DRUG ABUSE, MENTAL HEALTHTREATMENT, except psychotherapy notes, and CONKIDENTIAL HIV* RELATED INFORMATION only if I place my initials onthe appropriate line in Item 9{a). In the event the health information described below includes any of these types of information, and 1initial the line on the box in Item 9(a). I specifically authorize release ofsach information to the person(s) indicated in Item 8.2. If! am authorizing the release of HlV-rclated. alcohol or drug treatment, or mental health ireainient information, the recipleiu isprohibited from redlsclosing such information without my authorization unless pemiiitcd to do so under federal or stale law. Iunderstand that 1 have the right to rcque.st a list nf people who may receive or use my HIV-relatcd information without authorization. IfI cxpcricnec discrimination because of the release or disclosure ofHIV-rcltiied inrormation. 1 may contact the New York State Divisionof Human Rights at (212) 480-2493 or the New York City Commission of Human Rights at {212) 306-7450. These agencie.s arcresponsible for protecting my rights.3. 1 have the right to revoke this authorization at any time by writing to the health care provider listed below. I understand that I mayrevoke this authorization except to the extent that action has already been taken based on this authorization.4. 1 understand that signing this authorization is voluntary. My ireaimeni. payment, cnroiimcni in a health plan, or eligibility forbenefits will not be conditioned upon my authorization of this disclosure.5. Information disclosed under this authorization might be rediscloscd by the recipient (except as noted above in Item 2), and thisrcdisclosurc may no longer be protected by federal or state law.

6. THIS AUTHORIZATION DOES NOT AUTHORIZE VOU TO DISCUSS MY HEALTH INFORMATION OR MEDICALCARE WITH ANYONE OTHER THAN THE .A i J ORNEV OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9 fb).7. Name and address of health provider or entity lo release this information:

M. Darryl AntonaccI, MD, FACS 800 5th Ave, New York, NY 100378. Name and address of pcrsonis) or catogorv of person to whom this inlbrmalion will be sent:Law Offices of Tobias & Kuhn.'lOO William Street, Suite 920 New York, NY 100389(aj. Specific information lo be lelcascd:

□ Medical Record from (insert dale) lo (insert datcl^Entire .Vlcdical Record, including patient histories, ofllcc notes (except psychotherapy notes), test results, radiology studies, films,

referrals, consults, billing records, insurance records, and records sent to you by other health care providers.Qother: Include: i/luiicow hv Initialing)

Alcohol/Drug TreatmentMental Health Information1

Authorization to Discuss Health Information

(b) □ By initialing here ' fauthcrize

y\'-Relatcd Information

liiitialito discuss mv health informati^

Name of individual healih care providerwith my attorney, or a govenimcnlal agency, listed here:

(.Allomev'rimi N:ime or (iovemmcnul Aeeiicv Najiltf)10. Reason for release of information;

.At request of individual□ Other:

11. Dale or event on which this authorization will expire:

END OF LITIGATION12. if not the patient, name of person signing fonn:JEFFREY E. LITMAN ATTORNEY AT LAW

13. Authority to sign on beluilf of patient:POWER OF ATTORNEY PURSUANT TO PUBLIC HEALTH LAW SECTION IB

All items on this form have been completed and my questions about this form have been answered. In addition. I have been provided acopy of the form,

Signature of patient

Human Imniunntleficicncv

lent or represcntc^e;intleficicncy Viras thai <

Dale: 8/28/2015by law.

DS. I he New York Siaie I'lihlk Nealth l.iiw prnierls informaiinn which rcasnnabi.v cniiididcnti^ someone as having lil\ syiiiptuni.<i or infect Ion ami informiilion regarding a person's contacts.

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINAL

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINAL

1 lot'!' ^ Official Korm No.: 960AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA

jjhjs form bas been approved by ibc New ork Stale Department of Healtbj

Patient Name

CAfHERINEWALfH \Date of Birth

5/26/1964

Social Security Number

058-62-7763

Patient Address

62 HIGHLAND AVENUE. LEONARDO NJ 07737

1. or iny tuiiliuri/ed representative, request that health infomiation regarding my carc and treatment be released as set Torth an this form;

In accordance with New York Slate Law and the Privacy Rule of the Health Insurance Portability and Accountability Act of 1996(HIPAA), I understand that:

1 , This authorization may include disclosure of information relating to AI.COIIOI. and DKIT; ABUSE* MENTAL HEALTHTREATMENT, except psychotherapy notes, and CONFIDENTIAL HIV* RELATED INFORMATION only If I place my initials on(lie appropriate line in Item 9(a). In the event the health information described below includes any of these types of information, and Iinitial the line on the box in Item 9ia). I speciilcally authorize release of such inforntalion to (he personisi indicated in Item 8.2. If I am authorizing the release of HIV-related, alcohol or drug treatment, or mental health treatment Information, the recipient isprohibited from redisclosing such information without my authorization unless pcrmiticd to do so under federal or state law. 1understand that I have the right to request a list of people who may receive or use my HIV-rclaicd infurTnation without authorization, ifI experience discrimination because of the release or disclosure of HIV-related information. I may contact the New York State Divisionof Human Rights at (212) 480.249.1 or the New York C ity Commissian of Human Rights at (212) .>06.7450. These agencies areresponsible for protecting my rights.

I have the right to revoke this authorization at any time by writing to the health carc provider listed below. I understand that I mayrevoke this authorization except to the extent that action ha.s already been taken based on this authorization.4. I understand that signing litis authorization is voluntary. My ireatmenl. payment, eiirolltneni In a health plan, or eligibility forbenefits will not be conditioned upon my authorization of this disclosure.5. Information di.sclosed under this authorization might be rcdisclosed by the recipient le.xcepi as noted above in Item 2). and thisrcdisclosure may no longer be protected by federal or state law.C. THIS Al THORIZATION DOES NOT Al TIIORIZK VOU TO DISCUSS .VfV HEALTH INFORMATION OR MEDICAL

CARE Wl lli ANYONE OTHER THAN THE ATTOR^E^ OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9<bY

7, Name and address of health provider or entity to release this information;Dr. Glenn J. Jakobsen, Physical Medicitie & Rehab, 5455 Kings Hway, Brooklyn, NY 11203S. Name and address of per.son(s) or category of person to whom this intormaiiun will be sent;Law Offices of Tobias & Kuhn, 100 William Street, Suite 920 New York, NY 10038

9(a). Specific information to be released;□ Medical Record from (insert dale) to (insert date)(X|[:ntlre .Medieal Record, including patient histories, office notes (except p.sycholhcrapy notes), test rcsult.s, radiology studies, films,

referrals, consults, billing records, insurance records, and records sent (c you by other healih care providers.□other: Include; (hielivaiL' by /niiialitig)

Alcohol/Drug Treatment'' Mental Health lofonnation

AuihorizalioQ to Discuss Health Information

(b) J By iniiialing here _ _ yl^uthorizcMin^'Related Information

initials. / Name afindtvidiai health core providerto discuss my health information with my attorney, or a governmental agency, listed here:

(Atiomcv.Titm Name or Govcmmcwal Agency Name)10. Reason for release of Informailon;

At request ofindividual□ Other:

11. Date or event on which this authorization will expire;

END OF LITIGATION12. If nol the patient, natnc of person sianing form:JEFFREY E. LITMAN ATTORNEY AT LAW

I.T Aiiiliority tosign on bebairorpatleni:POWER OF ATTORNEY PURSUANT TO PUBUC HEALTH LAW SECTION 18

All iletiis on this form hacopy of the Ibrm.

been completed jpr^my questions about this form have been answered, in addition, I have been provided a

Date; 8/28/2015cd h\- law..Signature of patient or representative

Human Immunodeficiency Virus ihiitci^<» .-VIDS. 'I'he New >'»rk Sinte Public llcniih Law protects iDformatioQ which reasonably couldidentify someone us having HIV symptoms or iafccliun and informutiun regarding a pcrsnnN cnntacls.

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINAL

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINALOCA Official Vorm No.: 960

AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA|TltLs form bas been approved by the New York Stale Department of Hcallh|

Patient Name

C^^HERINeWALfH V '-"iDate of Birth

Paiieiii .Address

62 HIGHLAND AVENUE, LEONARDO NJ 07737

I. or my aulhorizcd reprcscmalivc. request that health inforniaiioti regarding nw care and treatment be released as .set forth on this form:

In accordance vviih New York State Law and the Privacy Rule of the Health Insurance Portability and Accountability Act of 1996(HIPAA). 1 understand that;

1. This authorization may include disclosure of information relating to ALCOHOL and DRl'G ABUSE. MLNTAL IIKALTIITREATMENT, except psycholhcrap) notes, and CONFIDENTIAL HIV* RELATED INFORIM.ATlOiN only if I place my initials onthe appropriate line in hem 9(a), In the event the health infonnation described below includes any of these t) pcs of information, and Iinitial the line on the bo.x in Item 9(a). I spccillcally authorize release of such information to the persontsl indicated in hem 8.2. If I am auiliorizing the release of HlV-rclatcd. alcohol or drug ireatnieni, or mental health treatment information, the recipient isprohibited from redlsclosing such informaiton wiihoiii iny authorization unless permitted to do so under federal or state law. Iunderstand that I have (he right to request a list of people who may receive or use my HlV-rclatcd infoimalion without authorization. IfI experience dLscrimination because of the relea,se or disclosure of HlV-rciatcd information. I may contact the New York Slate Divisionof Human RighLs at (212) 480-2493 or the New York City Commission of Human Rights at (212) 306-7450. These agencies areresponsible for protecting my rights.3. 1 have the right to revoke this authorization at any time by writing to the health care provider listed below. I understand thai 1 mayrevoke this auihorization except to the c.xtcni that action has already been taken based on this authorization.4. I understand that signing this authorization is voluntary. My ircatmcm. payment, enrollment in a health plan, or eligibility forbenefits will not be conditioned upon my aiithorizaiion of this disclosure.5. Information disclosed under this aiithorizatiun might be rcdisclosed by the recipient (except as noted above in hem 2), and thisredisciosiire may no longer be protected by federal or state law.

6. THIS At THORIZATION DOES NO I AH ! IIORIZK VOH TO DISCLSS MY HEALTH INFORMATION OR .MEDICAL

CARE WITH ANYONE OTHER THAN THE ATTORNEY OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9 ib).

7. Name and address of health provider or cnlily to release this information:Sadlier Publishing, 9 Pine Street, New York, NY 10005

8. Name and address of person(s) or category of person to whom this infomiation will be sent:Law Offices of Tobias & Kuhn, 100 William Street, Suite 920 New York, NY 10038

9(ai, Specific information to be released;□ Medical Record from (insert date) to (insen date)^Entire Medical Record, including patient histories, office notes (except psychotherapy notes), test results, radiology studies, films,

referrals, consults, billing records, insurance records, and records sent to you by oilier health care providers.[pother: EMPLOYMENT RECORDS \nc\udc: {hidicait: hy fniiiaiitig)

~ Alcohol/Drug TreatmentMental Health Information

.Authorization to Discuss Health Information

(b) G By initialing here 1 authorize

•^'^IV-Rciatcd Information

Ini^s ' Name of individual health care providerto discuss my health information with my attorney, or a governmental agency, listed here:

I .Anomcvl'irin Name or GoNcmmcntal .Agcno Name)10. Reason for release of infomiation:

[>^At request of individual□ Other;

11. Date or event uii which this authorization will expire;

END OF LITIGATION12. If nut Ihe patient, name of person siitninu form:JEFFREY E. LITMAN ATTORNEY AT LAW

13. .Authority to sign on behalf of patient:POWER OF ATTORNEY PURSUANT TO PUBLIC HEALTH LAW SECTION 18

All items on this form ha^^bccn completed my questions about this form have been answered. In addition. I have been provided acopy of the form.

Dale: 8/28/2015Signature of patient or representative aiiihorizcd by law.

' ilumao Immunodeficiency N'iruv that cau«:c\ AIDS. The Nciv ^'ork State Public Health l.fl» protects information which rcasoaahly couldIdcnii^' someone as having lll\' symptoms or inreclion and information regarding s person's contacts.

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINAL

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINAL0(.'/V Ofilcial Form No.; 960

AlfTHORIZ.ATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA

|Tbis form lins been approved by the New York Stato Dvpiirtmciil of Mcniih}

Patient Name ^ _

CAT^gWD^AtlH fTw-«aBaf.eSocial Securit^^mbcr

Patient .Address

62 HIGHLAND AVENUE. LEONARDO NJ 07737

t. or niy authorized representative, request that health Inrormation regarding my carc and ireaiinent be released as set forth on this form:

In accordance with New Yoriv State l.aw and the Privacy Rule of the Health Insurance Ponability and Accountahlliiy Act of 1996IHIPAA). 1 understand that:

1. This auihorizHtion may include disclosure of infoimation relating to ALCOHOL and DRL'G .ABUSE. MENTAL HEALTHTREATMENT, except psvchotherapy notes, and CONFIDENTIAL HIV* RELATED INFORMATION only if! place my initials onthe appropriate line in Item 9(a). In the event the health information described below includes any of these types of information, and Iinitial the line on (he box in hem 9(a). I specifically authorize release of such information to the persortls) indicated in Item 8.2. in am authorizing the release ofHlYNrclated, alcohol or drug treatment, or mental health treatment information, the recipient isprohibited from redisclostng such information without my authorization unless permitted to do so under federal or state law. Iunderstand that I have the right to request a list of people who may receive or use my HIV -related information without authorization. IfI experience discriminaticMi because of the release or disclosure of HlV-rciatcd information. I may conlaci the New York State Divisionof Human Rights at (212) 480-2-193 or the New York City Commission of Human Rights at (212) 306-7450, These agencies areresponsible for protecting my rights.3. I have the right to revoke this authorization at any time by writing to the health care provider listed below. I understand that I mayrevoke this authorization except to the extent that action has already been taken based on (his authorization.4. I understand thai signing this authorization is voluntary. My treatment, payment, cnrollntcnl In a health plan, or eligibility forbenefits will not be conditioned upon my authorization of this disclosure.3. Information disclosed under this authorization might be rcdisciosed by the recipient (except as noted above in Item 2). and thisredisclosure may no longer be protected by federal or state law.

6. THIS ALTIIORIZATION DOES NOT AUTHORIZE 'Oll TO DISCUSS M\ HEALTH INFOR.MATION OR MEDICALCARE WITH ANYONE OTHER THAN THE .ATTORNEY OR GOVER.NMENTAL AGENCY SPECIFIED IN ITEM 9 lb).

7. Name and address ofhealtlt provider or entity lo release this irtforinaiion;The Hartford Financial Services Group, Inc. One Hartford Plaza Hartford, Connecticut 061558- Name and address of per.son(s) or category of person to whom this infotmaiion will be sent;Law Offices of Tobias & Kuhn, 100 William Street, Suite 920 New York, NY 10036

10 (Insert date)

9(a). Specillc information lo be released:□ Medical Record from (insen date)[^Entire Medical Record, including patient histories, office notes (e.xcepi psychotherapy notes), test results, radiology studies, films,

referrals. consiiU.s. billine records, insurance records, and records sent to vou b> other health care providers.gotlK-r: WORKERS'COMPENSATION FILE D/A Include: (Im/iaile bv Initialing)

11/10/2011 FILE NO. YZC89484C ^-^Alcohol/Drue TreatmentMental Health Information

Authorization to Discu.ss Health Information ^ y^-4H^V-Rclated Information(b)aRy initialing here //f authorize

lnilia).s// Nnme of indivichiiil hcallh c.irc pri>\ iderCO discuss my itealth information with my attorney, or a govcmmimial agency, listed here:

(Anomevi'Fimi Name orGovcrnmL-nml Asi«ne\ Name)10. Reason for release of information:

j^At request of individual□ Other:

11. Dale or event on which this authorization will expire:

END OF LmGATION12. If not ihe patient, name of person signina form:JEFFREY E. LITMAN ATTORNEY AT LAW

13. .Authority in sign on behalf of patient:POWER OF ATTORNEY PURSUANT TO PUBLIC HEALTH LAW SECTION 18

All ilcms un this form havecopy of the form.

>ny questions about this fonn have been aiisvvcretl. in addition. I have been provided a

Date: 8/28/2015Signature of patient or represenianvc aumorlzed bv law.

Humao Immunodeficiency Mrus that causes The .Nen York Sinte Fulllic lleailh l.a« prulccts infurmaiion which reasunably cnuldidentify sumcunens havinc IID' symptoms nr Infection and liiruriniiiiori rL-garilinu a iicminN loiiIjcIs.

COPY, FAX, OR E-MAIL OF AUTHORIZATION IS VALID AS ORIGINAL

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SUPREME COURT

STATE OF NEW YORK. COUNTY OF NEW YORK Index No. 161190 Year 2014

CATHERINE WALSH,

-against-

Plaintiff(s),

CRP/CAPSTONE 14W PROPERTY OWNER,L.L.C.,

I

AFFIRMATION IN

OPPOSITION

LITMAN & LITMAN, P.C.

Attorney(s) for Plaintiff(s)

Office and Post Office Address, Telephone

5 BERING COURT

WOODBURY, NEW YORK 11797-2701

(516)353-1500

To

Signature (Rule 130-1.1--

Print name beneath

JEFFREY E. LITMAN

Attorney(s) for

Service of a copy of the within is hereby admitted.

Dated:

PLEASE TAKE NOTICE:

□ NOTICE OF ENTRY

that the within is a (certified) true copy of aduly entered in the office of the clerk of the within named court on

□ NOTICE OF SETTLEMENT

that an orderwill be presented for settlement to the HON.within named Court, aton at

of which the within is a true copyone of the judges of the

M.

Dated,

Yours, etc. LITMAN & LITMAN, P.C.ATTORNEYS FOR PLArNTIFF(S)5 BERING COURT

WOODBURY, NEWYORK 11797-2701(516)353-1500