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TAMIKA PEARSON as Mother and Natural Guardian of v. CONIFER REALTY LLC e...

Docket 604818/2024, New York State, Nassau County, Supreme Court (Mar. 20, 2024)
Case TypeTorts - Other Negligence (Premises Liability)
TagsTort, Civil, Other, Negligence, Premises Liability
Plaintiff Tamika Pearson AS MOTHER AND NATURAL GUARDIAN OF Infant Plaintiff, C.W., and Individually
Defendant CONIFER REALTY LLC
Defendant CONIFER TWIN OAKS, LLC
...
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ANSWER WITH CROSS-CLAIM(S) ANSWER & COMBINED DEMANDS

Document TAMIKA PEARSON as Mother and Natural Guardian of v. CONIFER REALTY LLC et al, 604818/2024, 14 (N.Y. Sup. Ct., Nassau County Dec. 19, 2024)
(g) A duly executed HIPAA compliant authorization for the entire contents of the litigation funding company’s file including, but not limited to, any and all advertising materials, applications, estimates, medical information, brochures, contracts, agreements, liens and correspondence.
and the applicable case law, you are hereby required to produce for discovery and supply to the undersigned attorneys for defendant within twenty (20) days from the date of service of this demand, the following information, documents and items requested for the purpose of inspection and/or copying:
Any and all other medical data (including CAT scans, MRI's, EEG's, EKG's, and other diagnostic tests) not hereinabove specifically referred to upon which you will rely upon or offer for consideration in the proceeding, along with the complete billing records of such provider(s) that pertain to the diagnosis, care, evaluation and treatment of the plaintiff.
State whether any hardcopies exist for any post, e-mails, tweets, replies, retweets, direct messages, status updates, wall comments, groups joined, activity streams, and blog entries you have deleted from each such account, as identified above in response to demand No. 6.
Duly executed and acknowledged written authorizations (containing full name and addresses of all doctors/hospitals) and fully compliant with HIPAA regulations permitting the attorneys for this defendant(s) to obtain and make copies of any and all records from any video conference/telemedicine appointment/contacts for any treating clinicians during the COVID-19 lockdown or since the outbreak of the corona virus.
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STIPULATION - TIME TO ANSWER

Document TAMIKA PEARSON as Mother and Natural Guardian of v. CONIFER REALTY LLC et al, 604818/2024, 13 (N.Y. Sup. Ct., Nassau County Dec. 17, 2024)
WHEREBY,IT IS HEREBYSTIPULATEDANDAGREED,by and between the above parties, that for whoma committee has been appointed, or incompetent whereas no party ts an infant the time that to answer and/or appear In this matter is extended until for defendant D'lorio Landscaping, Corp., January 17, 2025, and defendant Landscaping, Corp., hereby agrees to waive any defenses based D'lorio and on service of the complaint; IT IS FURTHERSTIPULATEDANDAGREEDthat this stipulation may be signed in counter-part, that and that ink or wet signatures, this stipulation maybe filed signatures maybe used in lieu of electronic notice to the parties.
with the Court without any further Dated: Melville, NewYork December/1 2024
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11

Document TAMIKA PEARSON as Mother and Natural Guardian of v. CONIFER REALTY LLC et al, 604818/2024, 11 (N.Y. Sup. Ct., Nassau County Sep. 20, 2024)

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COMPLAINT (AMENDED) Amended Complaint

Document TAMIKA PEARSON as Mother and Natural Guardian of v. CONIFER REALTY LLC et al, 604818/2024, 9 (N.Y. Sup. Ct., Nassau County Aug. 28, 2024)
At all times herein mentioned, Defendant CONIFER REALTY, LLC was and still is a domestic limited liability company duly organized and existing under and by virtue of the laws of the State of New York.
At all times herein mentioned, Defendant CONIFER TWIN OAKS, LLC was and still is a domestic limited liability company duly organized and existing under and by virtue of the laws of the State of New York.
At all times herein mentioned, Defendant CONIFER REALTY, LLC owned the premises, appurtenances and fixtures located at or about 21 Manor Avenue, Hempstead, New York, County of Nassau, also known as the “Twin Oaks Apartments” and including the parking lot area (the “Subject Premises”).
At all times herein mentioned, Defendant CONIFER REALTY, LLC negligently, recklessly and carelessly permitted the Subject Premises to be, become and remain in a dangerous and defective unsafe condition.
At all times herein mentioned, Defendant CONIFER TWIN OAKS, LLC negligently, recklessly and carelessly permitted the Subject Premises to be, become and remain in a dangerous and defective unsafe condition.
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ADR - ATTORNEY CERTIFICATION ATTORNEY GOOD FAITH ADR CERTIFICATION

Document TAMIKA PEARSON as Mother and Natural Guardian of v. CONIFER REALTY LLC et al, 604818/2024, 28 (N.Y. Sup. Ct., Nassau County Mar. 19, 2025)
of 22 NYCRR§202.11, requirements Pursuant to the has conferred with opposmg counsel about in whole or of this resolution case, in part.
at the undersigned certifies that he/she stored information, and any other issues to the use of alternate dispute resolution
to resolve all or some issues in the litigation, and (4) any voluntary and informal exchange of information that the parties agree would help aid prelimmary of the case settlement early the above matters prwr is aware of his/her about The undersigned obhgation confer the to to be mcorporated mto the proposed and comphance conferences.
Any agreements will and/or comphance conference orders.
prelimmary chent ADRoptions The undersigned has discussed with his/her through the 10'h Judicial and those offered by private such as mediat on, neut al eveluation, / , Distnct Dated 03/19/2025 entitics, Signature available fu t ~ / ajid arbitration Print Name" MichaelP Kelly, Esq Attorney For D'lono Landscaping Corp
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ADR - ATTORNEY CERTIFICATION

Document TAMIKA PEARSON as Mother and Natural Guardian of v. CONIFER REALTY LLC et al, 604818/2024, 27 (N.Y. Sup. Ct., Nassau County Mar. 19, 2025)
the requirements of 22 NYCRR§202.11, Pursuant to has conferred with opposing counsel about in whole or in part, of resolution
this case, the undersigned certifies that he/she including discovery of electronically stored information, and any other issues to (2) discovery, be discussed the use of alternate at the conference.
Any agreements will be incorporated and/or compliance conference orders.
preliminary client ADRoptions The undersigned such as mediation, preliminary prior to the the proposed into has discussed with his/her District and those offered by private entitics, available through neutral culuation, the 10th Judicial and arbitration.
Dated: 3/17/25 Signature: Print Name: Brandon S. Finz Attomey For: Plaintiff
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26

Document TAMIKA PEARSON as Mother and Natural Guardian of v. CONIFER REALTY LLC et al, 604818/2024, 26 (N.Y. Sup. Ct., Nassau County Feb. 26, 2025)

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