`FILED: BRONX COUNTY CLERK 09m2015 02:21 PM
`
`NYSCEF DOC. NO. 19
`NYSCEF DOC. NO. 19
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`INDEX NO. 20927/2015E
`INDEX NO~ 20927/20153
`
`
`
`
`
`RaCaIVaD VYSCEF: 09/30/2015
`RECEIVED NYSCEF: 09/30/2015
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF BRONX
`
`----------------------------------------------------------------------x
`LUIS QUIROGA,
`
`Plaintiff,
`
`SECOND
`SUPPLEMENTAL
`VERIFIED BILL OF
`
`PARTICULARS
`
`—against-
`
`Index N0.: 20927 /2015B
`
`CARING SUPPORTED HOUSING, LLC.,
`CARING SUPPORTED HOUSING DEVELOPMENT
`FUND CORPORATION, MDG DESIGN &
`CONSTRUCTION, LLC.,
`
`Defendants.
`——————————————————————————————————————————————————————————————————————X
`
`PLEASE TAKE NOTICE,
`
`the plaintiff, by his attorneys, BLOCK O’TOOLE &
`
`MUPRHY, LLP, supplements all previously served Verified Bills of Particulars, based upon
`
`information and belief, as follows:
`
`LUMBAR SPINE
`
`On September 4, 2015, the Plaintiff LUIS QUIROGA underwent an MRI of Lumbar Spine
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`performed at Doshi Diagnostic Imaging Services.
`
`Impression:
`
`-
`
`—
`—
`—
`—
`
`LS—Slz There is a broad based disc herniation with significant lateral recess stenosis
`and bilateral foraminal impingement;
`LS—Sl: Anterior thecal sac impingement is present;
`L4-5: There is a right foraminal herniation with a right foraminal annular tear;
`L4—5: There is a right foraminal impingement and right lateral recess stenosis;
`L4—5: Anterior thecal sac impingement is present;
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`THE PLAINTIFF RESERVES THE RIGHT TO SUPPLEMENT AND/OR
`
`AMEND THIS VERIFIED BILL OF PARTICULARS UP TO AND INCLUDING AT
`
`THE TIME OF TRIAL.
`
`
`
`Dated: New York, New York
`September 30, 2015
`
`Yours etec,
`
`
`
`David L. Scher
`
`BLOCK O’TOOLE & MURPHY
`
`Attorney for Plaintiff
`LUIS QUIROGA
`
`One Penn Plaza, Suite 5315
`New York, New York 10119
`
`(212) 736—5300
`
`To:
`
`Colleen Hastie, Esq.
`TRAUB LIEBERMAN STRAUS & SHREWSBERRY, LLP.
`Attorney for Defendant(s)
`CARING SUPPORTED HOUSING DEVELOPMENT
`FUND CORPORATION CARING SUPPORTED HOUSING, LLC
`Mid—Westchester Executive Park
`
`Seven Skyline Drive
`Hawthorne, New York 10532
`(914) 347—2600
`
`Kathleen Mulholland, Esq.
`CAMACHO MAURO MULHOLLAND, LLP
`Attorney for Defendants
`MDG DESIGN & CONSTRUCTION, LLC
`350 Fifth Avenue, Suite 5101
`New York, New York 10118
`(212) 947—4999
`
`
`
`ATTORNEY'S VERIFICATION
`
`DAVID L. SCHER, an attorney duly admitted to practice before the Courts of the State of
`
`New York, affirms the following to be true under the penalties of perjury:
`
`I am an attorney at BLOCK O’TOOLE & MURPHY, LLP, attorneys of record for
`
`Plaintiff, LUIS QUIROGA,
`
`in the action within.
`
`I have read the annexed SECOND
`
`SUPPLEMENTAL VERIFIED BILL OF PARTICULARS and know the contents thereof,
`
`and the same are true to my knowledge, except those matters therein which are stated to be alleged
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`upon information and belief, and as to those matters I believe them to be true, My belief, as to
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`those matters therein not stated upon knowledge, is based upon facts, records, and other pertinent
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`information contained in my files.
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`The reason this verification is made by me and not Plaintiff is that the Plaintiff is not
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`presently in the county wherein the attorneys for the Plaintiff maintain their offices.
`
`Dated: New York, New York
`September 30, 2015
`
`
`
`DAVID L. SCHER
`
`
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