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MARLENE DOUGLAS v. DITMAS PARK REHABILITATION AND CARE CENTER, LL...

Docket 525870/2024, New York State, Kings County, Supreme Court (Sept. 24, 2024)
Case TypeTorts - Other Negligence (Public Health Law 2801-D)
TagsTort, Civil, Other, Negligence, Public Health, D
Plaintiff Marlene Douglas as Administratix of the Estate of BARBARA RANKINE
Defendant DITMAS PARK REHABILITATION AND CARE CENTER, LLC d/b/a DITMAS PARK NURSING & REHAB
Defendant John jane Does #1-10 (fictitiously named)
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ANSWER Verified Answer

Document MARLENE DOUGLAS v. DITMAS PARK REHABILITATION AND CARE CENTER, LLC et al, 525870/2024, 5 (N.Y. Sup. Ct., Kings County Oct. 25, 2024)
Denies the allegations in paragraphs 9, 12, 22, 23, 24, 25, 27, 28, 37, 45, and 46 of plaintiff’s Verified Complaint and refers all questions of law and fact to this Honorable Court.
The answering defendant reserves the right to claim the limitations of liability as set forth in CPLR Article 16, for any recovery herein by the plaintiff for non-economic loss.
answering defendant, pursuant to CPLR 4545, such verdict or judgment must be reduced by those amounts which have or will replace or indemnify plaintiff in whole or in part from any collateral source of payment.
ELEVENTH: If the plaintiff is entitled to recover damages from loss of earnings or impairment of earning ability as against this answering defendant, by reason of the matters alleged in the complaint, liability for which is hereby denied, then pursuant to CPLR 4546 the amount of damages recoverable against this defendant, if any, shall be reduced by the amount of federal, state and local income taxes by which the plaintiff would have been obligated to pay.
The causes of action pleaded herein are invalid as this answering defendant exercised all care reasonably necessary to prevent and limit the deprivation and injury to the patient for which liability is asserted herein.
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COMPLAINT Verified

Document MARLENE DOUGLAS v. DITMAS PARK REHABILITATION AND CARE CENTER, LLC et al, 525870/2024, 2 (N.Y. Sup. Ct., Kings County Sep. 24, 2024)
Plaintiff repeats, reiterates, and realleges each and every allegation contained in those paragraphs of the Verified Complaint marked and numbered previously with the same force and effect as if more fully set forth at length herein.
At all relevant times, Defendants, their employees, agents, consultants, and independent contractors deprived Decedent of the rights to which she was entitled pursuant to the aforementioned statutes, laws, rules, and regulations.
At all relevant times, Defendants failed to comply with the requirements for long term care under 42 C.F.R. § 483, the Medicare and Medicaid programs, and all other statutes, laws, rules, and regulations.
Due to Defendants’ failure to maintain the appropriate quality of care, Plaintiff’s Decedent suffered and sustained injuries, illness, infection, and other medical conditions which eventually caused her death on or about October 31, 2021.
WHEREFORE, based on the foregoing, Plaintiff MARLENE DOUGLAS, as Administratrix of the Estate of BARBARA RANKINE demands judgment against Defendants DITMAS PARK REHABILITATION AND CARE CENTER, LLC d/b/a DITMAS PARK NURSING & REHAB and JOHN/JANE DOES #1-10 (fictitiously named) on each cause of action for compensatory, punitive, and statutory damages in an amount to be determined at trial, but which exceeds the jurisdictional limits of all lower courts, with interest, costs, attorneys’ fees, and
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DEMAND FOR: Defendant's 2nd Good Faith Letter regarding Outstanding Discovery Demands

Document MARLENE DOUGLAS v. DITMAS PARK REHABILITATION AND CARE CENTER, LLC et al, 525870/2024, 10 (N.Y. Sup. Ct., Kings County Mar. 3, 2025)
100 Wall Street, 19th Floor New York, NY 10005 Arijeta Kukic Law Clerk
As you are aware, our office represents defendant Ditmas Park Rehabilitation and Care Center, LLC in the above-referenced matter.
review of our file shows that, to date, your office has failed to provide responses to these demands.
Please consider this defendant’s second good faith attempt to obtain the outstanding discovery.
Once again, in order to obviate the need for motion practice, please provide responses within twenty (20) days.
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9

Document MARLENE DOUGLAS v. DITMAS PARK REHABILITATION AND CARE CENTER, LLC et al, 525870/2024, 9 (N.Y. Sup. Ct., Kings County Jan. 10, 2025)

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6

Document MARLENE DOUGLAS v. DITMAS PARK REHABILITATION AND CARE CENTER, LLC et al, 525870/2024, 6 (N.Y. Sup. Ct., Kings County Oct. 25, 2024)

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7

Document MARLENE DOUGLAS v. DITMAS PARK REHABILITATION AND CARE CENTER, LLC et al, 525870/2024, 7 (N.Y. Sup. Ct., Kings County Oct. 25, 2024)

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8

Document MARLENE DOUGLAS v. DITMAS PARK REHABILITATION AND CARE CENTER, LLC et al, 525870/2024, 8 (N.Y. Sup. Ct., Kings County Oct. 25, 2024)

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