Demetrius Karageorgos

Intake Overview: Plaintiff Demetrius Karageorgos, date of birth March 1972 (exact day not confirmed — see Information Gaps), resides at 55 Lennox Road, Apt 2Q, Rockville Centre, NY 11570, Nassau County. His age, occupation, employment status, marital status, and dependents are not reflected in the intake. The incident occurred at the intersection of South Station Plaza and Village Avenue, Rockville Centre, NY, also in Nassau County. Plaintiff's residence and the incident situs are in the same county, which is relevant to venue strategy. This is a motor vehicle accident (car_accident) case and is not a wrongful death matter. The incident occurred on a Monday the 23rd; the month and year were not stated during intake and must be verified before case acceptance. Plaintiff was operating his 2014 black Lexus RX 350 eastbound on South Station Plaza, described as a one-way road running along the Long Island Railroad, after leaving a King Kullen grocery store. As he approached Village Avenue, he proceeded through what he represents was a green light and was struck broadside (T-boned) on the passenger side by another vehicle. The impact rotated plaintiff's vehicle approximately 180 degrees. Both driver-side and passenger-side doors were reported to have been pancaked, and both front and rear passenger-side airbags deployed. Plaintiff's vehicle was declared a total loss by his insurance carrier, Allstate. The sole defendant is identified only as the driver of the other vehicle. No name, address, county, entity affiliation, employer, vehicle owner, insurance information, or vehicle description is captured for the defendant in the intake. Whether the defendant is an individual or a commercial entity is unknown. There is no indication the defendant vehicle is a TLC-licensed taxi or a rideshare vehicle, but this has not been ruled out. There is no indication the defendant is a governmental, quasi-governmental, or municipal entity. Whether police responded to the scene is not expressly stated in the intake, but both drivers gave statements to police and the incident was characterized by police as "driver versus driver," indicating law enforcement was present and a police report was likely generated. Plaintiff reports having subsequently obtained surveillance footage from a nearby establishment called "North Village," a flower and gift shop on Village Avenue, which he states clearly shows the defendant running a solid red light. This matter was referred through a personal acquaintance of James Rubinowitz ("Ed"). The referral is a non-attorney referral. The intake notes that James Rubinowitz indicated he is stepping back from practicing law and would be referring plaintiff to another attorney. No retainer, HIPAA authorization, or limited power of attorney has been signed as of the time of intake. Injuries and Treatment: Plaintiff reports the following injuries, all described in generic symptomatic terms as no formal diagnoses have been identified in the intake: severe left-side muscle strains, left arm pain with a "dead arm" sensation, left shoulder pain, left clavicle pain, neck pain with limited cervical rotation to the left, pins and needles and tingling in the left hand, and pins and needles and tingling in the left foot. Specific diagnoses for each of these complaints will need to be confirmed once medical records are obtained. The neurological symptoms — tingling and pins and needles in the left hand and left foot — may suggest nerve involvement, but no diagnosis, imaging finding, or provider assessment is present in the intake to characterize this further. Plaintiff was treated at Mount Sinai South Nassau. The date of that visit, the treating provider's name, the nature of the encounter (emergency department, admitted inpatient, or outpatient), whether the plaintiff arrived by ambulance or by other means, and the length of any stay are all unknown from the intake. Whether diagnostic imaging (MRI, CT, X-ray, EMG) was performed, of what body parts, and at what facility is not captured. Whether plaintiff has had or has scheduled any surgery arising from this incident is not reflected in the intake. Whether any follow-up or ongoing treatment has occurred beyond the Mount Sinai South Nassau visit is unknown. Regarding New York no-fault: the no-fault carrier has not been identified in the intake beyond the reference to Allstate as the insurer associated with the total-loss determination. Whether a no-fault application (NF-2) has been filed, the identity of the no-fault carrier, and the no-fault claim number are all unknown. Because the incident date is currently unconfirmed, the no-fault filing deadline cannot be precisely calculated, but the NF-2 must be submitted within 30 days of the date of the incident. The attorney should verify the incident date and the no-fault application status immediately upon case acceptance, as failure to meet that deadline can result in denial of no-fault benefits. Key Facts and Liability Considerations: - The incident date is unconfirmed. Only "Monday the 23rd" was provided; the month and year are unknown. The statute of limitations for a New York motor vehicle personal injury action is generally three years from the date of incident. The SOL cannot be assessed, monitored, or calendared until the incident date is confirmed. This is a critical threshold gap. - Liability is disputed. The defendant driver also claimed to have had a green light. Police characterized the incident as "driver versus driver" at the scene, indicating no fault determination was made by responding officers. - Plaintiff reports possession of surveillance footage from "North Village" on Village Avenue that he states shows the defendant running a solid red light. The intake does not confirm that the firm has obtained or reviewed this footage; its preservation and chain of custody should be addressed immediately upon case acceptance. - The defendant is entirely unidentified in the intake — no name, address, insurer, vehicle information, or employer is known. This is a threshold gap for any liability or coverage analysis. - Whether the defendant vehicle is commercially owned, TLC-licensed, or a rideshare vehicle is unknown, which prevents any assessment of applicable coverage limits. - Plaintiff's insurer is identified as Allstate, which declared plaintiff's vehicle a total loss. Whether Allstate is also the no-fault carrier, and whether plaintiff carries uninsured or underinsured motorist (UM/SUM) coverage, is unknown. - Plaintiff's age, occupation, and employment status are not in the intake, limiting any preliminary assessment of lost earnings or economic damages exposure. - Plaintiff's marital status and dependents are unknown; no assessment of a potential loss of consortium claim can be made. - No preexisting conditions, prior injuries, prior surgeries, or prior treatment involving the claimed body parts (left shoulder, left arm, left clavicle, cervical spine) are noted in the intake. This absence should be confirmed, not assumed. - No Medicare, Medicaid, workers' compensation, or self-funded ERISA plan lien or subrogation exposure is identified in the intake, but health insurance coverage and lien status are unknown. - No parallel criminal proceedings against the defendant are referenced in the intake. - Plaintiff is not identified as a minor or incapacitated individual; no guardianship or estate administration issues are apparent. - The extraction confidence score is 0.62, flagging meaningful uncertainty in the extracted data. Key fields — including incident date, defendant identity, and treatment details — should be re-confirmed directly with the plaintiff. - No retainer, HIPAA authorization, or limited power of attorney has been executed as of intake. These must be secured promptly upon case acceptance, particularly given the unresolved no-fault deadline. - Plaintiff's exact date of birth was not confirmed; only the birth month and year (March 1972) were provided during the call. The exact day was recorded as the 1st as a placeholder only. Information Gaps: - Incident date (month and year): not provided in the intake. This is the single most critical gap — it drives the statute of limitations, the no-fault filing deadline, and all calendaring decisions. - Plaintiff's exact date of birth: only month and year (March 1972) were given; the specific day is unconfirmed. - Plaintiff's occupation, employment status at the time of the incident, marital status, and dependents: all unknown; needed for damages modeling and loss of consortium assessment. - Defendant driver's full name, address, county, and contact information: entirely unknown; needed before any demand, litigation, or coverage investigation can proceed. - Defendant vehicle information: make, model, year, license plate, and registered owner are all unknown. - Whether the defendant vehicle is commercially owned, TLC-licensed (taxi), or a rideshare (Uber/Lyft) vehicle: unknown; directly affects coverage limit analysis. - Defendant's insurance carrier, policy number, and coverage limits: unknown. - Whether a police report was filed and whether plaintiff has obtained a copy: not confirmed in the intake (law enforcement presence is implied but not expressly stated). - Plaintiff's no-fault application (NF-2) status: unknown; must be confirmed immediately given the 30-day filing deadline running from the incident date. - No-fault carrier identity and claim number: unknown. - Whether Allstate is acting as the no-fault carrier or only as the property damage carrier: unclear. - Whether plaintiff carries UM/SUM coverage under his Allstate policy: unknown. - Mount Sinai South Nassau visit details: date of visit, nature of encounter (ER, inpatient admission, outpatient), treating provider name, length of stay, and discharge status are all unknown. - Whether plaintiff arrived at Mount Sinai South Nassau by ambulance or private vehicle: unknown; ambulance provider identity would be needed if applicable. - Diagnostic imaging (MRI, CT, X-ray, EMG): whether any was performed, of what body parts, on what dates, and at what facility — all unknown. - Specific diagnoses for all claimed injuries: none are confirmed; only symptomatic descriptions are available. - Whether plaintiff has undergone any surgery related to this incident: unknown. - Whether any surgery or further treatment is currently scheduled: unknown. - Follow-up treating providers beyond Mount Sinai South Nassau: unknown. - Whether treatment is ongoing: unknown. - Plaintiff's health insurance carrier: unknown; needed to assess lien and subrogation exposure. - Medicare, Medicaid, or self-funded ERISA plan involvement: unknown. - Prior injuries, surgeries, or treatment involving the left shoulder, left arm, left clavicle, cervical spine, or neurological complaints in the left upper or lower extremity: not addressed in the intake. - Whether plaintiff was previously represented by another attorney or firm for this incident: unknown. - Status and preservation of the surveillance footage from "North Village": whether the firm has received or secured a copy is unknown; urgent given the risk of footage being overwritten or lost. - Whether there are any witnesses beyond what the surveillance footage may show: unknown. --- PRELIMINARY MEDICAL CHRONOLOGY Date unknown — Mount Sinai South Nassau — Type of encounter unknown (ER visit, inpatient admission, or outpatient); treating provider name unknown; records not yet obtained. [RECORDS TO BE REQUESTED]