FILED: QUEENS COUNTY CLERK 08/02/2017 07:29 AM
`FILED:
`OUEENS COUNTY CLERK 08m2017 07:29 AM
`NYSC 3F DOC. NO. 81
`NYSCEF DOC. NO. 81
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`IND
`EX NO.
`712701/2015
`INDEX NO. 712701/2015
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` VYSC
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` flIV flD
` 3F:
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`08/02/2017
`RECEIVED NYSCEF: 08/02/2017
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`EXHIBIT C
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`FILED: QUEENS COUNTY CLERK 08/02/2017 07:29 AM
`FILED: OUEENS COUNTY CLERK 08m2017 07:29 AM
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`NYSCEF DOC. NO. 81
`NYSCEF DOC. NO. 81
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`INDEX NO. 712701/2015
`INDEX NO~ ”2701/2015
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`RaCaIVaD VYSCEF: 08/02/2017
`RECEIVED NYSCEF: 08/02/2017
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF QUEENS
`---MW__."c...c.._-._______._____m,_____.._x.
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`KATTY PELAEZ. individually. and PV-
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`an infant under the age of fourteen by is mother and
`natural guardian, KATTY PELAEZ.
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`,
`Index No.: 712701115
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`-against—
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`Pieintifis.
`.
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`PHYSICIANS
`AFFIRMATION
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`MARIA YAMILLE MORALES. AVINELL S. ABDOOL,
`JAGDISHWARIE ABDOOL,.and OMAR D. VIGUNA.
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`Defendants.
`........__..-..____._m__......__..,“.;____________x
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`I. JAMES M. LIGOURI, D.O.. arn licensed to practice medicine In the State of New
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`York, and as such I certify the following as true, under the penalty of perjury. pursuant
`to CPLR £2106:
`'
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`1.
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`lam board certified in neurology with an office et1999 Marcus Avenue, -
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`New Hyde Park, New York 110432.
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`2.
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`On August 11 . 2014 KATI'Y PELAEZ came to my office for evaluation
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`and treatment with complaints of episodic headaches in the teft occipital region, Neck .
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`pain with numbness and tingling of the Left Hand, Low Back pain with radiating pain in _
`the Left Leg toltowing an accident on July 4, 2014. Ms. Pelee: was weerin. her seat
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`belt and was a backseat passenger 'when the front of the vehicle she was a passenger
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`in was hit. She experienced immediate Neck and Low Back Pain.
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`l diagnosed. KATTY
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`PELAEZ with Cervical delculopathy and Lumbosa‘cral Radioulopsthy. I recommended
`Ms. Pelaez continue physical therapy and discussed with the patientthe possibility of
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`trigger point andlor epidural injections and to follow up in four weeks.
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`3.
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`On September 10. 2014 I examined KATTY PELAEZ. At that visit, she
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`

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`FILED: QUEENS COUNTY CLERK 08/02/2017 07:29 AM
`FILED: OUEENS COUNTY CLERK 08m2017 07:29 AM
`
`NYSCEF DOC. NO.
`81
`NYSCEF DOC. NO. 81
`
`712701/2015
`INDEX NO. 712701/2015
`INDEX NO.
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`
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`RfiCfiIVfiD VYSCEF:
`08/02/2017
`RECEIVED NYSCEF: 08/02/2017
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`
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`complained of Left Occipitel pain, Neck pain. Lower Back Pain, Left Le. pain and Left
`Hand numbness. l conducted a physical examination of Plaintiff and diagnosed Plaintiff
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`as suffering from Cervical Radiculcpathy. Lumbosacrai Radlculopethy, and Occlpitel
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`Neuralgia on the left. KATTY FELAEZ underwent injection of trigger point(s), three or
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`more muscle groups. total number of injections: 4 injections Lidocaine 2% Sccc. See
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`my annexed report dated September 10, 2014 report. incorporated, and affirmed I
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`hereto. I recommended Ms. Pelaez continue physical therapyr and to follow up in four
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`weeks.
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`4.
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`On October a, 2014,
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`l examined KATFY PELAEZ, at that visit, she
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`complained of Left Occipitel pain. Neck pain, and Back pain. -i conducted a physlcal
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`examination of Ptaintiff and diagnosed Plainttff as suffering from Cervical Derangement.
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`Lumbosacral Derangement, and Occlpitel Neuralgia on the left. KATTY PELAEZ
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`underwent injection of trigger polnt(s) Total number of injections: 4 injections Lidcceine 2%
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`30¢ injection into the left cervical paraepinal muscles injection into the lefttrapezius muscle
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`x2 injection into the right trapezius muscle x1. KA‘I'W PELAEZ tolerated the procedure
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`well;
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`there were no complications and that she should follow up in four weeks- I
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`recommended Ms. Pelee: continue physical therapy and exercise therapy and to follow up
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`in four weeks.
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`5.
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`On November 5. 2014.
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`l examined KATW PELAEZ. At that visit. she
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`complained of Left Occipitel pain, Neck pain. and Back pain.
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`i conducted a physical
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`examination of Plaintiff and diagnosed Plaintiff as suffering from Cervical Derangement,
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`Lumbosecrel Derangement, and Occipital Neurslgie on the left. KATTY PELAEZ
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`underwent injection of trigger polntts) Total number of injections: 4 injections Lidcceine 2%
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`

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`FILED: QUEENS COUNTY CLERK 08/02/2017 07:29 AM
`FILED: OUEENS COUNTY CLERK 08m2017 07:29 AM
`
`NYSCEF DOC. NO. 81
`NYSCEF DOC. NO. 81
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`INDEX NO. 712701/2015
`INDEX NO~ ”2701/2015
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`RaCaIVaD VYSCEF: 08/02/2017
`RECEIVED NYSCEF: 08/02/2017
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`30c injection into the left cervical paresplnal m uscles injection into the tort trepezius muacle
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`x2 injection into the right trapezius muscle x1.- KATTY PELAEZ tolerated the procedure
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`' well; there were no complications and that she should follow up in four weeks.
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`I
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`recommended Ms. Pelaez continue physical therapy and exercise therapy and to follow up
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`in four weeks.
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`6.
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`On December 3, 2014, I examined KATTY PELAEZ. At that visit, she
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`complained of Left Occipitel pain. Neck pain, Back pain. and numbness to the Left Arm.
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`I conducted a physical examination of Plaintiff and diagnosed Plaintiff as suffering from
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`Cervical Derangement, Lumbosacral Derangement, and Occlpital Neurslgis on the left.
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`KATTY PELAEZ undement injection of trigger point(s) Total number of injections: 4
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`injections Lidocaine 2% 3cc injection into the Left Comical Paraspinal Muscles injection
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`into the Left Tropezius Muscle at? injection into the Right Trepezius Muscle x1. KATTY
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`PELAEZ tolerated the procedure well; there were no complications and that she should
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`follow up in four weeks. i recommended Ms. Pelee: continue physical therapy and
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`exercise therapy and to follow up in four weeks.
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`7.
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`8.
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`The prognosis for a full end complete recovery remains poor.
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`This affirmation is based upon my treatment and objective diagnosis of
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`Ms. Pelee: and the medical findings provided within the medical records and medical
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`reports that are in my possession.
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`9.
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`The injuries. disabilities, and impairments indicated herein are, to a
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`reasonable degree of medical certainty. causally related to the accident occurring on
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`July 4, 2014. Plaintiff sustained a permanent loss of use of a function or system,
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`significant limitations of use of a body function or system, and inability to perform her
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`

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`FILED: QUEENS COUNTY CLERK 08/02/2017 07:29 AM
`FILED:
`OUEENS COUNTY CLERK 08m2017 07:29 AM
`NYSC 3F DOC. NO. 81
`NYSCEF DOC. NO. 81
`
`IND
`EX NO.
`712701/2015
`INDEX NO. 712701/2015
`
` VYSC
`
` flIV flD
` 3F:
`
`08/02/2017
`RECEIVED NYSCEF: 08/02/2017
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`usual and customary daily activities.
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`Dated: Kew Gardens, New York
`July 12.2017
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`James M. Ligouri., 0.0.
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