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Catherine England v. Mildred A. Pagliaro et al

Docket 612040/2023, New York State, Nassau County, Supreme Court (July 28, 2023)
Case TypeTorts - Other Negligence (Premises)
TagsTort, Civil, Other, Negligence, Premises
Plaintiff Catherine England
Defendant Mildred A. Pagliaro
Defendant Andrew J. Pagliaro
...
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ORDER - CERTIFICATION

Document Catherine England v. Mildred A. Pagliaro et al, 612040/2023, 26 (N.Y. Sup. Ct., Nassau County Feb. 25, 2025)
This matter is hereby certified fortrial and plaintiff(s) is/are directed to file a note ofissue within \E0days.
Ifplaintiffdoes not file a note ofissue withirtBFdays, the court will consider the matter abandoned and will, on its own motion dismiss the complaint for failure to prosecute (CPLR 3216(b)(3)).
Uponfiling a note of issue, the matter will be referred for mediation and/ora pretrial conference.
Counsel shall arrange to havelitigants and insurance representatives available for telephone conference at the time of such proceedings.
if counsel have been directed to file the note of issue over objection, items 1 through 9 ofthe Certificate of readiness may be amendedto so indicate.
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ORDER - PRELIMINARY CONFERENCE

Document Catherine England v. Mildred A. Pagliaro et al, 612040/2023, 16 (N.Y. Sup. Ct., Nassau County Mar. 29, 2024)
Within 30 days from the date ofthis order,all parties shall exchange names and addressesofall witnesses, and shall exchange statements of opposing parties and photographs, or, if none, shall provide an affirmation to that effect. b.
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DEPOSITION SCHEDULE RIDER PC Order - Deposition Schedule Rider

Document Catherine England v. Mildred A. Pagliaro et al, 612040/2023, 15 (N.Y. Sup. Ct., Nassau County Mar. 22, 2024)
Index #: Caption: Judge's name: PC Date: Deposition Schedule Rider pursuant to 5(a) of the Preliminary Conference Order: 5a.
Deposition Schedule: Deponent: Date and Time: Location: Agreed to by (Please Type Your Name Below): Plaintiff(s) Defendant(s)
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STIPULATION - SO ORDERED

Document Catherine England v. Mildred A. Pagliaro et al, 612040/2023, 27 (N.Y. Sup. Ct., Nassau County Feb. 27, 2025)
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gies 4. a ok Date eeSR, oe vf PPS HEREBY STIPULATED AND AGREEDby and between the below-namedattorney(s} as follows:
NASSAU COUNTY Cd See
: oS sh Anomey For Defendant ~ Will
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DEMAND FOR: 3rd Good Faith letter attaching Post EBT Demands

Document Catherine England v. Mildred A. Pagliaro et al, 612040/2023, 25 (N.Y. Sup. Ct., Nassau County Jan. 10, 2025)
Please consider this our good faith effort and comply with the above request immediately so we may obtain the relevant discovery in this matter and to avoid the need for judicial intervention.
Duly executed and acknowledged HIPAA COMPLIANT authorization(s) with complete name and address, to obtain any/all records from the Urgent Care facility Plaintiff visited with her daughter, Maureen, on April 29, 2022.
Duly executed and acknowledged HIPAA COMPLIANT authorization with complete name and address, to obtain all physical therapy records including, but not limited to, all diagnostic tests, x-rays, notes, reports, films and bills from the physical therapy provider as testified to by the Plaintiff.on September 20, 2024.
PLEASE TAKE FURTHER NOTICE that the appropriate authorizations should be HIPAA compliant and contain the plaintiff’s name, date of birth, social security number and other applicable identifying information.
DATED: Garden City, NY October 04, 2024 Yours, etc., By: Law Offices of John Trop William C. Kelly Attorney for Defendants
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STATEMENT OF AUTHORIZATION FOR ELECTRONIC FILING

Document Catherine England v. Mildred A. Pagliaro et al, 612040/2023, 24 (N.Y. Sup. Ct., Nassau County Dec. 6, 2024)
(Single Attorney Authorizing Filing Agent Entity) I, ________________________, Esq., ( Attorney Registration No. ______________ ) am an authorized user of the New York State Courts Electronic Filing System (“NYSCEF”) (User ID ____________ ).
I hereby authorize any employee of ________________________________________ who possesses a NYSCEF filing agent ID to file documents on my behalf and at my direction, as a filing agent, in any e-filed matter in which I am counsel of record through the NYSCEF system, as provided in Section 202.5-b of the Uniform Rules for the Trial Courts.
This authorization extends to any consensual matter in which I have previously consented to e-filing, to any mandatory matter in which I have recorded my representation, and to any matter in which I may authorize the filing agent to record my consent or representation in the NYSCEF system.
This authorization, posted once on the NYSCEF website as to each matter in which I am counsel of record, shall be deemed to accompany any document filed in that matter by the filing agent.
This authorization regarding this filing agent shall continue until I revoke it in writing on a prescribed form delivered to the E-Filing Resource Center.
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DEMAND FOR: 2nd Good Faith letter attaching Post EBT Demands

Document Catherine England v. Mildred A. Pagliaro et al, 612040/2023, 23 (N.Y. Sup. Ct., Nassau County Dec. 6, 2024)
Please consider this our good faith effort and comply with the above request immediately so we may obtain the relevant discovery in this matter and to avoid the need for judicial intervention.
Duly executed and acknowledged HIPAA COMPLIANT authorization(s) with complete name and address, to obtain any/all records from the Urgent Care facility Plaintiff visited with her daughter, Maureen, on April 29, 2022.
Duly executed and acknowledged HIPAA COMPLIANT authorization with complete name and address, to obtain all physical therapy records including, but not limited to, all diagnostic tests, x-rays, notes, reports, films and bills from the physical therapy provider as testified to by the Plaintiff.on September 20, 2024.
PLEASE TAKE FURTHER NOTICE that the appropriate authorizations should be HIPAA compliant and contain the plaintiff’s name, date of birth, social security number and other applicable identifying information.
DATED: Garden City, NY October 04, 2024 Yours, etc., By: Law Offices of John Trop William C. Kelly Attorney for Defendants
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