FILED: BRONX COUNTY CLERK 07/21/ :45 PM INDEX NO /2015E NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 07/21/2015 EXHIBIT E

Transcription

1 FILED: BRONX COUNTY CLERK 07/21/ :45 PM INDEX NO /2015E NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 07/21/2015 EXHIBIT E

2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX X GARNET JOHNSON and FREDERICK BENTON No /2015E -against- Plaintiff(s), VERIFIED BILL OF PARTICULARS KATTI GUNYARD, SHEILA WILLIAMS, CHARLES BROWN, ELRAC, LLC, Defendant(s). X Plaintiff(s), by their attorneys at the Gitelis Law Offices, set forth the following, upon information and belief, in response to Defendant(s) CHARLES BROWN. All demands are objected to, to the extent they are overly broad, unduly burdensome, redundant and/or seek information and/or materials that are irrelevant, privileged, testimonial in nature and/or otherwise beyond the scope of discovery or improper: 1) Plaintiff GARNET JOHNSON resides at 946 Reverend James Polite Avenue, Bronx, NY Plaintiff FREDERICK BENTON resides at 103 West 83rd Street, New York, NY ) Plaintiff GARNET JOHNSON has no social security number. Plaintiff FREDERICK BENTON's social security number, which appears in full under a separate heading, ends with the digits xxx-xx ) The accident occurred on May 21, 2013 at approximately 3:28 a.m. 4) The accident occurred at or near the intersection of Barnes Avenue and Pitman Avenue in Bronx, New York. 5) The above stated occurrence, and the results thereof, was in no way due to any negligence on the part of Plaintiffs contributing thereto, but was caused solely and wholly by the negligence of the Defendants in the ownership, operation, management, maintenance and control of their said motor vehicle, the Defendants were negligent in that they failed and neglected to operate, manage and control their motor vehicle in a

3 proper, reasonable, prudent and safe manner so as to avoid the collision, although they could have done so, failed and neglected to properly and adequately slow, stop or otherwise decrease the speed of their motor vehicle so as to avoid the occurrence, although they could have done so, failed and neglected to decrease the speed of their motor vehicle, operated their motor vehicle at an unreasonable and improper rate of speed under the circumstances then and there prevailing, failed and neglected to obey traffic signals in and upon the roadway, although they should have done so, failed and neglected to turn, swerve or otherwise steer their motor vehicle in such a way so as to avoid the collision, although they could have done so, failed and neglected to keep a proper, or any, lookout in and upon the roadway, failed and neglected to observe the conditions then and there existing in and upon the roadway, failed and neglected to honk their horn or otherwise give warning of their approach and of impending danger, failed and neglected to yield the right of way, failed and neglected to make proper use of any signaling or sounding devices, failed and neglected to maintain their motor vehicle, and more particularly the steering, breaking, signaling devices and tires, in proper working condition although they could have done so, failed and neglected to proceed with increased caution, failed to operate their vehicle with due regard to the rights and safety of the Plaintiff, operated their said motor vehicle in a manner which unreasonably endangered the Plaintiff, failed to properly steer, guide, manage and control their said motor vehicle, failed to apply the breaks or slow down or stop in such a manner as would have prevented the occurrence, failed to make adequate and timely observation of, and respond to conditions, failed to observe signs and signals prevailing at the time and place of the occurrence, failed to keep a proper look-out when controlling their said motor vehicle, failed to properly maintain their said vehicle according to law, failed to give adequate and timely signal, notice or warning, operated their said motor vehicle in

4 violation of the traffic rules, regulations, statutes and ordinances in such cases made and provided, and Defendants were careless, reckless and negligent in the ownership, maintenance, operation and control of their said motor vehicle. 6) Plaintiffs sustained the following serious personal injuries: As to the injuries of GARNET JOHNSON: Magnetic Resonance Imaging (MRI) of Plaintiff s Cervical Spine: a. Mild, multilevel discogenic degenerative changes of cervical spine with mild central canal narrowing from the level of C2-C6 and no definite neural foraminal narrowing; MRI of Plaintiff s Lumbar Spine b. At L4-5, there is a diffuse disc bulge with an annular fissure; c. In combination with mild to moderate bilateral facet hypertrophy, this results in mild to moderate bilateral neural foraminal narrowing without central canal narrowing; MRI of Plaintiff s Right Knee d. High-grade, at least partial-thickness tearing of the anterior cruciate ligament; e. Full-thickness tearing of the tibular collateral ligament and proximal popileus within the medial compartment; f. Complex medial meniscal tear; MRI of Plaintiff s Left Ankle g. Increased T2 signal in the medial aspect of the talar dome consistent with non-displaced fracture/bone contusion and/or avascular necrosis, in an appropriate clinical setting;

5 h. The distal Achilles tendon is thickened and heterogeneous with increased T2 signal consistent with a partial tear; i. Subcutaneous soft tissue swelling and edema mostly over the lateral aspect of the ankle consistent with recent trauma, in an appropriate clinical setting; j. The flexor tendons, the peroneal tendons, the anterior and posterior talofibular ligaments and the deltoid ligaments are all intact. Right Knee Arthroscopic Surgery on November 13, 2013 k. Right knee examination under anesthesia; 1. Operative arthroscopy; m. Synovectomy of three compartments; n. Debridement of anterior cruciate ligament; o. Medial and lateral meniscectomy; p. Chondroplasty of medial femoral condyle using microfracture technique; and q. Chondroplasty of patella, lateral condyle, trochlea. As to the injuries of FREDERICK BENTON: X-Rays of Plaintiff s Left Hip a. Negative study; X-Rays of Plaintiff s Right Knee b. Mild degenerative arthritic changes are seen; MRI of Plaintiff s Cervical Spine c. Herniations in the C3-4, C4-5, and C5-6; d. Canal impingement produced;

6 e. Hypolordosis; MRI of Plaintiff s Lumbar Spine f. There is a disc bulge at the L4-L5 level where disc material approximates the ventral thecal sac. The bulge measures lmm in maximal AP dimensions; g. There is a disc bulge at the LS-SI level where disc material is seen to approximate the ventral epidural fat; MRI of Platiniff s Right Knee h. Examination is abnormal; i. There is a suprapatellar effusion; j. There is a 4.5 cm popliteal cyst; k. Full-thickness tear involving the posterior horn and body of the lateral meniscus is seen; 1. There is attenuated articular cartilage along with productive changes and subchondral signal changes in the lateral compartment indicated arthrosis. There is also partial maceration of the lateral meniscus; MRI of Plaintiff s Left Hip m. Joint effusion; Right Knee Arthroscopic Surgery on October 17, 2013 n. Right knee arthroscopic partial medial meniscectomy; o. Partial lateral meniscectomy; p. Arthroscopic tricompartmental synovectomy; and q. Arthroscopic removal of loose bodies. 7)

7 Plaintiff GARNET JOHNSON was confined to (a) Bed for seven (7) months immediately following his right knee arthroscopic surgery; and (b) Home for three (3) months following and apart from the time for when he was confined to his bed as enumerated above. Plaintiff FREDERICK BENTON, who lives in a men's shelter, was confined to (c) Bed rest for six (6) months immediately following his left knee arthroscopic surgery. 8) Plaintiff GARNET JOHNSON did not treat at a hospital. Plaintiff FREDERICK BENTON treated at The University Hospital For Albert Einstein College of Medicine, Montefiore Medical Center located atl 11 East 210 th Street, Bronx, NY 10467, on July 20, ) Plaintiffs treated with the following medical centers: a. As to Plaintiff GARNET JOHNSON: North Bronx Medical Healthcare, P.C. Danilo Humberto Sotelo-Garzo, M.D Boston Road Bronx, NY Westchester Radiology & Imaging, P.C. 933 Saw Mill River Road Ardsley, NY NYU Langone Medical Center Varuzhan Dowlatyan th Street Brooklyn, NY 11215

8 Bronx Medical Diagnostic, P.C Buhre Avenue Bronx, NY Bronx Community Medical, P.C. Dr. Konstantinos Zarkadas, MD 910 East Gun Hill Road Bronx, NY St. Joseph's Medical Center Danilo H. Sotelo-Garza, MD 127 South Broadway Yonkers, NY b. As to Plaintiff FREDERICK BENTON: Bronx Community Medical, P.C. Dr. Konstantinos Zarkadas, MD 910 East Gun Hill Road Bronx, NY Bronx Medical Diagnostic, P.C Buhre Avenue Bronx, NY North Bronx Medical Healthcare, P.C. Danilo Humberto Sotelo-Garzo, M.D Boston Road Bronx, NY Dr. Randall V. Ehrlich, MD PC 625 East Fordham Road Bronx, NY Apex Medical, PC Southern Boulevard Bronx, NY Columbus Imaging Center 481 North 13 th Street Newark, NJ Surgicare Surgical Associates of Jersey City, LLC 631 Grand Street Jersey City, NJ 07304

9 10) Plaintiff GARNET JOHNSON was not employed and makes no claim for lost wages. Plaintiff FREDERICK BENTON employed and earned $600 per week. 11) Plaintiff FREDERICK BENTON worked at Shimmy Fingers Tattoos. Plaintiff GARNET JOHNSON was totally disabled from his normal life activities for seven (7) months following his right knee arthroscopic surgery, and was partially disabled for the three (3) months following the seven (7) months of total disability. Plaintiff FREDERICK BENTON was totally disabled from his normal life activities for six (6) months following his left knee arthroscopic surgery. 12) Plaintiff GARNET JOHNSON was born Plaintiff FREDERICK BENTON was born 13) Plaintiffs special damages are as follows: As for Plaintiff GARNET JOHNSON (a) Physician services - none (b) Medical supplies - none (c) Loss of earnings - none (d) X-rays - none (e) Hospital expenses - none (f) Nurses' services - none (g) All others not specified above - none As for Plaintiff FREDERICK BENTON (h) Physician services (i) Medical supplies (j) Loss of earnings (k) X-rays (1) Hospital expenses

10 (m)nurses services (n) All others not specified above 14) Defendant(s) violated all applicable sections of the New York State Vehicle and Traffic Law and the New York City Traffic Rules and Regulations concerning the safe and proper operation of a motor vehicle upon the public ways and streets of the State of New York including but not limited to Vehicle and Traffic Law Sections 375, 388, 1101, 1110, 1111, 1113, 1120, 1121, 1122, 1123, 1124, 1125, 1126, 1128, 1129, 1146, 1160, 1161, 1163, 1164, 1166, 1172, 1180, 1180-a, 1180-b, , 1202, 1203, 1211, 1212, 1213, 1214, 1225-a, 1226, and 1229-c, and sections 4-03, 4-04, 4-05, 4-06, 4-07, 4-08, 4-09, and 4-12 of the Traffic Regulations of the City of New York, along with all other applicable Statutes, Ordinances, Rules, and Regulations that the Court will take Judicial Notice of at the time of trial. 15) Plaintiffs were not students at the time of the accident. 16) Plaintiffs' injuries are permanent in nature and are permanent loss of use of a body organ, member, function or system; permanent consequential limitation of use of a body organ or member; significant limitation of use of a body function or system, or a medically determined injury or impairment of a non permanent nature which prevents the injured person from performing substantially all of the material acts which constitute such person's usual and customary daily activities for not less that ninety days during the one hundred eighty days immediately following the occurrence of the injury or impairment. 17) Plaintiffs did not sustain nor are not claiming any property damage. 18) Plaintiffs have not received nor applied for Medicare benefits. 19) Plaintiffs have not received nor applied for Medicare benefits. 20) Plaintiffs do not have a Medicare card or health insurance claim numbers.

11 21) Plaintiffs have not been receiving SSDI benefits for 24 months. 22) Plaintiffs do not suffer from end stage renal failure or ALS disease. Plaintiff reserves the right to supplement and/or amend any and all responses in the event that additional information becomes available. Dated: Brooklyn, New York June 18, 2015 Yours, etc. To: CARMAN, CALLAHAN, & INGHAM, LLP Attorneys for Defendant CHARLES BROWN 266 Main Street Farmingdale, New York P: (516) Edward G. Eiseman, Esq. GITELIS LAW OFFICES Attorney for Plaintiff(s) 2004 Coney Island Avenue Brooklyn, New York P: (347) F: (347)

12 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX GARNET JOHNSON and FREDERICK BENTON, Plaintiff(s), Index No /2015E -against- KATTI GUNYARD, SHEILA WILLIAMS, CHARLES BROWN, ELRAC, LLC Defendant(s). VERIFIED BILL OF PARTICULARS Gitelis Law Offices Attorney At Law Attorney for Plaintiff(s), 2004 Coney Island Avenue Brooklyn, NY ATTORNEY CERTIFICATION The undersigned. an attorney admitted to practice in the courts of New York State, certifies that, upon information. belief and reasonable inquiry. the contentions contained in the above referenced document (s) are not frivolous. Dated: Brooklyn, NY June 18, 2015 Edward G Eisemaai, Esq. PLEASE TAKE NOTICE that the within is a (certified) true copy a Entered in the office of the clerk of the within named Court on, 201_ that on Order of which the within is a true copy will be presented for settlement of the Hon. One of the judges of the within named Court, at on 201_, at Dated, Brooklyn, NY June 18, 2015 Yours, etc Edward G Eiseman, Esq. Attorney for the Plaintiff(s) GITELIS LAW OFFICES ATTORNEY AT LAW 2004 CONEY ISLAND AVENUE BROOKLYN, NY 11223

13 proper, reasonable, prudent and safe manner so as to avoid the collision, although they could have done so, failed and neglected to properly and adequately slow, stop or otherwise decrease the speed of their motor vehicle so as to avoid the occurrence, although they could have done so, failed and neglected to decrease the speed of their motor vehicle, operated their motor vehicle at an unreasonable and improper rate of speed under the circumstances then and there prevailing, failed and neglected to obey traffic signals in and upon the roadway, although they should have done so, failed and neglected to turn, swerve or otherwise steer their motor vehicle in such a way so as to avoid the collision, although they could have done so, failed and neglected to keep a proper, or any, lookout in and upon the roadway, failed and neglected to observe the conditions then and there existing in and upon the roadway, failed and neglected to honk their horn or otherwise give warning of their approach and of impending danger, failed and neglected to yield the right of way, failed and neglected to make proper use of any signaling or sounding devices, failed and neglected to maintain their motor vehicle, and more particularly the steering, breaking, signaling devices and tires, in proper working condition although they could have done so, failed and neglected to proceed with increased caution, failed to operate their vehicle with due regard to the rights and safety of the Plaintiff, operated their said motor vehicle in a manner which unreasonably endangered the Plaintiff, failed to properly steer, guide, manage and control their said motor vehicle, failed to apply the breaks or slow down or stop in such a manner as would have prevented the occurrence, failed to make adequate and timely observation of, and respond to conditions, failed to observe signs and signals prevailing at the time and place of the occurrence, failed to keep a proper look-out when controlling their said motor vehicle, failed to properly maintain their said vehicle according to law, failed to give adequate and timely signal, notice or warning, operated their said motor vehicle in

14 violation of the traffic rules, regulations, statutes and ordinances in such cases made and provided, and Defendants were careless, reckless and negligent in the ownership, maintenance, operation and control of their said motor vehicle. 6) Plaintiffs sustained the following serious personal injuries: As to the injuries of GARNET JOHNSON: Magnetic Resonance Imaging (MRI) of Plaintiff s Cervical Spine: a. Mild, multilevel discogenic degenerative changes of cervical spine with mild central canal narrowing from the level of C2-C6 and no definite neural foraminal narrowing; MRI of Plaintiff s Lumbar Spine b. At L4-5, there is a diffuse disc bulge with an annular fissure; c. In combination with mild to moderate bilateral facet hypertrophy, this results in mild to moderate bilateral neural foraminal narrowing without central canal narrowing; MRI of Plaintiff s Right Knee d. High-grade, at least partial-thickness tearing of the anterior cruciate ligament; e. Full-thickness tearing of the tibular collateral ligament and proximal popileus within the medial compartment; f. Complex medial meniscal tear; MRI of Plaintiff s Left Ankle g. Increased T2 signal in the medial aspect of the talar dome consistent with non-displaced fracture/bone contusion and/or avascular necrosis, in an appropriate clinical setting;

15 h. The distal Achilles tendon is thickened and heterogeneous with increased T2 signal consistent with a partial tear; i. Subcutaneous soft tissue swelling and edema mostly over the lateral aspect of the ankle consistent with recent trauma, in an appropriate clinical setting; j. The flexor tendons, the peroneal tendons, the anterior and posterior talofibular ligaments and the deltoid ligaments are all intact. Right Knee Arthroscopic Surgery on November 13, 2013 k. Right knee examination under anesthesia; 1. Operative arthroscopy; m. Synovectomy of three compartments; n. Debridement of anterior cruciate ligament; o. Medial and lateral meniscectomy; p. Chondroplasty of medial femoral condyle using microfracture technique; and q. Chondroplasty of patella, lateral condyle, trochlea. As to the injuries of FREDERICK BENTON: X-Rays of Plaintiff s Left Hip a. Negative study; X-Rays of Plaintiff s Right Knee b. Mild degenerative arthritic changes are seen; MRI of Plaintiff s Cervical Spine c. Herniations in the C3-4, C4-5, and C5-6; d. Canal impingement produced;

16 e. Hypolordosis; MRI of Plaintiff s Lumbar Spine f. There is a disc bulge at the L4-L5 level where disc material approximates the ventral thecal sac. The bulge measures lmm in maximal AP dimensions; g. There is a disc bulge at the LS-SI level where disc material is seen to approximate the ventral epidural fat; MRI of Platiniff s Right Knee h. Examination is abnormal; i. There is a suprapatellar effusion; j. There is a 4.5 cm popliteal cyst; k. Full-thickness tear involving the posterior horn and body of the lateral meniscus is seen; 1. There is attenuated articular cartilage along with productive changes and subchondral signal changes in the lateral compartment indicated arthrosis. There is also partial maceration of the lateral meniscus; MRI of Plaintiff s Left Hip m. Joint effusion; Right Knee Arthroscopic Surgery on October 17, 2013 n. Right knee arthroscopic partial medial meniscectomy; o. Partial lateral meniscectomy; p. Arthroscopic tricompartmental synovectomy; and q. Arthroscopic removal of loose bodies. 7)

17 Plaintiff GARNET JOHNSON was confined to (a) Bed for seven (7) months immediately following his right knee arthroscopic surgery; and (b) Home for three (3) months following and apart from the time for when he was confined to his bed as enumerated above. Plaintiff FREDERICK BENTON, who lives in a men's shelter, was confined to (c) Bed rest for six (6) months immediately following his left knee arthroscopic surgery. 8) Plaintiff GARNET JOHNSON did not treat at a hospital. Plaintiff FREDERICK BENTON treated at The University Hospital For Albert Einstein College of Medicine, Montefiore Medical Center located atl 11 East 210 th Street, Bronx, NY 10467, on July 20, ) Plaintiffs treated with the following medical centers: a. As to Plaintiff GARNET JOHNSON: North Bronx Medical Healthcare, P.C. Danilo Humberto Sotelo-Garzo, M.D Boston Road Bronx, NY Westchester Radiology & Imaging, P.C. 933 Saw Mill River Road Ardsley, NY NYU Langone Medical Center Varuzhan Dowlatyan th Street Brooklyn, NY 11215

18 Bronx Medical Diagnostic, P.C Buhre Avenue Bronx, NY Bronx Community Medical, P.C. Dr. Konstantinos Zarkadas, MD 910 East Gun Hill Road Bronx, NY St. Joseph's Medical Center Danilo H. Sotelo-Garza, MD 127 South Broadway Yonkers, NY b. As to Plaintiff FREDERICK BENTON: Bronx Community Medical, P.C. Dr. Konstantinos Zarkadas, MD 910 East Gun Hill Road Bronx, NY Bronx Medical Diagnostic, P.C Buhre Avenue Bronx, NY North Bronx Medical Healthcare, P.C. Danilo Humberto Sotelo-Garzo, M.D Boston Road Bronx, NY Dr. Randall V. Ehrlich, MD PC 625 East Fordham Road Bronx, NY Apex Medical, PC Southern Boulevard Bronx, NY Columbus Imaging Center 481 North 13 th Street Newark, NJ Surgicare Surgical Associates of Jersey City, LLC 631 Grand Street Jersey City, NJ 07304

19 10) Plaintiff GARNET JOHNSON was not employed and makes no claim for lost wages. Plaintiff FREDERICK BENTON employed and earned $600 per week. 11) Plaintiff FREDERICK BENTON worked at Shimmy Fingers Tattoos. Plaintiff GARNET JOHNSON was totally disabled from his normal life activities for seven (7) months following his right knee arthroscopic surgery, and was partially disabled for the three (3) months following the seven (7) months of total disability. Plaintiff FREDERICK BENTON was totally disabled from his normal life activities for six (6) months following his left knee arthroscopic surgery. 12) Plaintiff GARNET JOHNSON was born September 17, Plaintiff FREDERICK BENTON was born October 10, ) Plaintiffs special damages are as follows: As for Plaintiff GARNET JOHNSON (a) Physician services - none (b) Medical supplies - none (c) Loss of earnings - none (d) X-rays - none (e) Hospital expenses - none (f) Nurses' services - none (g) All others not specified above - none As for Plaintiff FREDERICK BENTON (h) Physician services (i) Medical supplies (j) Loss of earnings (k) X-rays (1) Hospital expenses

20 (m)nurses services (n) All others not specified above 14) Defendant(s) violated all applicable sections of the New York State Vehicle and Traffic Law and the New York City Traffic Rules and Regulations concerning the safe and proper operation of a motor vehicle upon the public ways and streets of the State of New York including but not limited to Vehicle and Traffic Law Sections 375, 388, 1101, 1110, 1111, 1113, 1120, 1121, 1122, 1123, 1124, 1125, 1126, 1128, 1129, 1146, 1160, 1161, 1163, 1164, 1166, 1172, 1180, 1180-a, 1180-b, , 1202, 1203, 1211, 1212, 1213, 1214, 1225-a, 1226, and 1229-c, and sections 4-03, 4-04, 4-05, 4-06, 4-07, 4-08, 4-09, and 4-12 of the Traffic Regulations of the City of New York, along with all other applicable Statutes, Ordinances, Rules, and Regulations that the Court will take Judicial Notice of at the time of trial. 15) Plaintiffs were not students at the time of the accident. 16) Plaintiffs' injuries are permanent in nature and are permanent loss of use of a body organ, member, function or system; permanent consequential limitation of use of a body organ or member; significant limitation of use of a body function or system, or a medically determined injury or impairment of a non permanent nature which prevents the injured person from performing substantially all of the material acts which constitute such person's usual and customary daily activities for not less that ninety days during the one hundred eighty days immediately following the occurrence of the injury or impairment. 17) Plaintiffs did not sustain nor are not claiming any property damage. 18) Plaintiffs have not received nor applied for Medicare benefits. 19) Plaintiffs have not received nor applied for Medicare benefits. 20) Plaintiffs do not have a Medicare card or health insurance claim numbers.

21 21) Plaintiffs have not been receiving SSDI benefits for 24 months. 22) Plaintiffs do not suffer from end stage renal failure or ALS disease. Plaintiff reserves the right to supplement and/or amend any and all responses in the event that additional information becomes available. Dated: Brooklyn, New York June 18, 2015 Yours, etc. To: CARMAN, CALLAHAN, & INGHAM, LLP Attorneys for Defendant CHARLES BROWN 266 Main Street Farmingdale, New York P: (516) Edward G. Eiseman, Esq. GITELIS LAW OFFICES Attorney for Plaintiff(s) 2004 Coney Island Avenue Brooklyn, New York P: (347) F: (347)

22 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX GARNET JOHNSON and FREDERICK BENTON, Plaintiff(s), Index No /2015E -against- KATTI GUNYARD, SHEILA WILLIAMS, CHARLES BROWN, ELRAC, LLC Defendant(s). VERIFIED BILL OF PARTICULARS Gitelis Law Offices Attorney At Law Attorney for Plaintiff(s), 2004 Coney Island Avenue Brooklyn, NY ATTORNEY CERTIFICATION The undersigned. an attorney admitted to practice in the courts of New York State, certifies that, upon information. belief and reasonable inquiry. the contentions contained in the above referenced document (s) are not frivolous. Dated: Brooklyn, NY June 18, 2015 Edward G Eisemaai, Esq. PLEASE TAKE NOTICE that the within is a (certified) true copy a Entered in the office of the clerk of the within named Court on, 201_ that on Order of which the within is a true copy will be presented for settlement of the Hon. One of the judges of the within named Court, at on 201_, at Dated, Brooklyn, NY June 18, 2015 Yours, etc Edward G Eiseman, Esq. Attorney for the Plaintiff(s) GITELIS LAW OFFICES ATTORNEY AT LAW 2004 CONEY ISLAND AVENUE BROOKLYN, NY 11223