Preview
FILED: KINGS COUNTY CLERK 04/02/2024 10:00 AM INDEX NO. 500852/2024
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 04/02/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X
VICTOR LUIS LAMA RENTERIA and ZOILA DEMAND FOR VERIFIED
MIYASHIRO, BILL OF PARTICULARS
Plaintiff, Index No. 500852/2024
-against-
EDGE AUTO INC. and DIONNE COCHRANE, NIKE,
INC., NIKE USA, INC., JN PRODUCTION INC., LION
TELEVISION, and ALL3MEDIA INTERNATIONAL
AMERICA, LLC d/b/a LION TELEVISION
Defendants.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE that you are hereby required to serve the following
particulars of each plaintiff’s alleged causes of action herein within twenty (20) days from the
date of service hereof:
1. Set forth the full name of plaintiff and any and all names by which plaintiff has
ever been known, including but not limited to a maiden name.
2. Set forth the date, place of birth, and social security number of plaintiff.
3. Address of plaintiff at time of the alleged accident and at present.
4. The date and time of day of the occurrence.
5. State the location of the accident in sufficient detail to permit identification,
giving direction in which each car was proceeding.
6. Statement of the acts or omissions constituting the negligence claimed.
7. State the owner, make, model, year, and color of each vehicle involved in this
incident.
8. State what part of the respective vehicles came into contact.
9. What ordinances, regulations and statutes does plaintiff claim defendant violated.
10. Describe the injuries sustained by plaintiff, indicating the exact location, nature,
extent, and duration of each injury, their sequelæ, and a description of those claimed to be
permanent.
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11. State whether plaintiff claims any limitation of motion, loss of use, or loss of
function as a result of the injuries alleged and, if so, state the nature, extent, and degree of
permanency thereof.
12. Set forth the names and addresses of all hospitals where plaintiff was treated or
confined as a result of the accident and state the length of time said plaintiff was treated or
confined in said hospitals, together with the dates of admission and discharge following the
accident.
13. State the length of time, giving specific dates, plaintiff was confined to:
A. Bed;
B. Home following the accident.
14. State plaintiff’s occupation and the name and address of plaintiff’s employers:
A. At the time of the accident;
B. At the present time; and/or
if plaintiff was/is self-employed and/or engaged in some other pursuit, so state and give the
address of such employment and/or pursuit.
15. If plaintiff is/was a student, state the names and addresses of the schools attended:
A. On the date of the accident;
B. At present.
16. State the length of time, giving specific dates plaintiff was incapacitated from
employment, school attendance, and/or from attending to his/her usual duties and vocation; the
amount of earnings or wages claimed to have been lost; and the rate of wage or basis of
remuneration received by plaintiff.
17. State the length of time plaintiff claims he/she was:
A. Totally disabled;
B. Partially disabled;
C. Unable to pursue his/her usual occupation.
18. Set forth the amounts claimed to have been sustained as special damages for:
A. Physicians’ services;
B. Medical supplies, including appliances;
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C. Hospital expenses;
D. Nurses’ services;
E. X-rays, CT scans, MRI scans, and other diagnostic testing expenses;
F. Lost wages;
G. Loss of income;
H. All other items of special damages claimed.
19. State the amounts earned by plaintiff two years prior to this accident, giving the
name and address of each employer during said years and the amount earned from each
employer.
20. Set forth in detail the manner in which plaintiff complies with Section 5102 of the
Insurance Law.
PLEASE TAKE FURTHER NOTICE that, in the event you fail to furnish said Bill of
Particulars within said period of twenty (20) days, a motion will be made for an order precluding
each plaintiff from offering any evidence at the trial of the above action for which particulars
have not been furnished.
Dated: New York, New York
April 1, 2024
Yours, etc.,
SMITH MAZURE, P.C.
Attorneys for Defendant
Edge Auto Inc.
39 Broadway, 29th Floor
New York, NY 10006-3053
(212) 964-7400
Our File No. PMA-00927
TO:
Glugeth & Pierguidi, P.C.
Attorney for Plaintiffs
Zoila Miyashiro and Victor Luis Lama Renteria
5 Penn Plaza, 19th Floor
New York, NY 10001
(201) 699-5070
-3-
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NO APPEARANCE TO DATE:
Lion Television
19 Fulton Street, Floor 5
New York, NY 10038
All3Media International LLC
d/b/a Lion Television
JN Production Inc.
Nike USA, Inc.
Nike Inc.
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FILED: KINGS COUNTY CLERK 04/02/2024 10:00 AM INDEX NO. 500852/2024
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X
VICTOR LUIS LAMA RENTERIA and ZOILA NOTICE FOR DISCOVERY
MIYASHIRO,
Index No. 500852/2024
Plaintiff,
-against-
EDGE AUTO INC. and DIONNE COCHRANE, NIKE,
INC., NIKE USA, INC., JN PRODUCTION INC., LION
TELEVISION, and ALL3MEDIA INTERNATIONAL
AMERICA, LLC d/b/a LION TELEVISION
Defendants.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE that, pursuant to the rules of this Court, you are required to
serve upon and deliver to the undersigned and all other parties to this action, the following:
1. Copies of affidavits and/or affirmations and all other proofs as to the service of
process of the summons and complaint upon the Defendant Edge Auto Inc..
2. If a plaintiff is self-employed or obtains income from sources other than
employment, submit copies of plaintiff’s income tax returns for a three (3) year period preceding
the date of the accident as set forth in the complaint.
3. If applicable, duly executed and acknowledged original authorizations permitting
the undersigned to obtain and copy no-fault medical and wage records for each plaintiff for the
period from the date of occurrence to the present.
4. If applicable, if a claim has or will be made pursuant to the terms of Article XVIII
of the Insurance Law of the State of New York (No-Fault Law), with respect to each and every
application:
A. Set forth the name, address, policy number and claim number of each
company to which a claim has been or will be made;
B. Set forth duly executed and acknowledged written authorizations
permitting the undersigned to obtain the records relating to the plaintiff
from each company identified in the response to paragraph “4.A”.
5. If a claim has or will be made pursuant to the terms of the Workers’
Compensation Law, with respect to each and every application:
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A. Set forth the name, address, policy number and claim number to which a
claim has been or will be made, together with the Workers’ Compensation
Board file number;
B. Set forth duly executed and acknowledged written authorizations
permitting the undersigned to obtain the records relating to the plaintiff
from each company identified in the response to paragraph “5.A”.
6. If a disability claim has or will be made pursuant to the terms of the Social
Security Law, with respect to each and every application:
A. Set forth the claim office, the address and the claim number assigned;
B. Set forth duly executed and acknowledged written authorizations
permitting the undersigned to obtain the records relating to the plaintiff.
7. Pursuant to CPLR Section 4545(c) produce and permit the undersigned attorneys
to inspect and copy the contents of:
A. Each and every collateral source of payment, including but not limited to,
insurance agreements, Social Security, workers’ compensation or
employee benefit programs, and any other collateral source of payment for
past or future costs or expenses alleged to have been incurred by the
plaintiff and for which recovery is sought in the instant action;
B. A written statement setting forth any such collateral sources and their
amounts;
C. Duly executed and acknowledged written authorizations permitting the
undersigned to obtain and make copies of all records relating to collateral
source information as set forth herein.
8. Duly executed and acknowledged original authorizations permitting the
undersigned to obtain and copy:
A. Employment records for three years prior to the date of accident to
present;
B. Union records for three years prior to the date of accident to present.
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PLEASE TAKE FURTHER NOTICE that the within demands are continuing
demands. In the event any of the above items are obtained after service of this demand, they are
to be furnished to this office upon receipt.
Dated: New York, New York
April 1, 2024
Yours, etc.,
SMITH MAZURE, P.C.
Attorneys for Defendant
Edge Auto Inc.
39 Broadway, 29th Floor
New York, NY 10006-3053
(212) 964-7400
Our File No. PMA-00927
TO:
Glugeth & Pierguidi, P.C.
Attorney for Plaintiffs
Zoila Miyashiro and Victor Luis Lama Renteria
5 Penn Plaza, 19th Floor
New York, NY 10001
(201) 699-5070
CAT/aml
31
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FILED: KINGS COUNTY CLERK 04/02/2024 10:00 AM INDEX NO. 500852/2024
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 04/02/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X
VICTOR LUIS LAMA RENTERIA and ZOILA
MIYASHIRO, NOTICE FOR DISCOVERY
Plaintiff, Index No. 500852/2024
-against-
EDGE AUTO INC. and DIONNE COCHRANE, NIKE,
INC., NIKE USA, INC., JN PRODUCTION INC., LION
TELEVISION, and ALL3MEDIA INTERNATIONAL
AMERICA, LLC d/b/a LION TELEVISION
Defendants.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE that, pursuant to the rules of this Court and CPLR §§2305
and 3120, you are hereby required to serve upon and deliver to the undersigned and all other
parties to this action, the following:
1. (A) Duly executed and acknowledged written authorizations, pursuant to
CPLR §§2305 and 3120 and pursuant to HIPAA §164.508 within 30 days of this demand,
permitting EDGE AUTO INC. to obtain and make copies of all records from any and all of the
following:
(i) Hospitals;
(ii) Treating and examining physicians;
(iii) Therapists;
(iv) Nursing services;
(v) Emergency medical services;
(vi) Pharmacies;
(vii) All other health care providers;
and all such records (concerning not only the injuries alleged in this action, but also all prior and
subsequent injuries to and affecting the same parts of the body) are to include, but are not limited
to:
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(B) Handwritten and typed chart entries and handwritten and typed office and
other notes, including, but not limited to, the patient’s history, admittance, treatments,
procedures, discharge, bills, x-rays, CT scans, MRIs and other diagnostic tests, including, but not
limited to, reports, films, narrative reports pursuant to Uniform Court Rules §202.17, technicians
reports, tests, and records including, but not limited to, all laboratory test, the results of which
treatment and/or care was rendered to each plaintiff concerning injuries alleged.
(C) Second set of the aforementioned written authorizations are to be provided
within 30 days of service of the Note of Issue.
(D) Third set of the aforementioned written authorizations are to be provided
within 30 days of the trial.
2. In addition, plaintiff is to provide copies of detailed, written reports of examining
and/or treating physicians and/or other health care providers setting out, inter alia, said
physicians’ and/or health care providers’ findings and conclusions, including, but not limited to,
a detailed recital of the injuries and conditions as to which testimony will be offered at trial, and
referring to and identifying those x-rays, CT-scans, MRI scans, laboratory test, and technicians;
and reports that will be offered at trial.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR §§2305 and 3120, as
amended, plaintiff is required to provide authorizations to be served with subpoenas duces tecum
requesting the production of the plaintiff’s medical records. Failure to provide authorizations
allowing for the medical provider to respond to a subpoena duces tecum will lead to an objection
at the time of the filing of the Note of Issue and Statement of Readiness by plaintiff’s counsel to
the matter being placed upon the trial calendar in violation of CPLR §§2305 and 3120.
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PLEASE TAKE FURTHER NOTICE that, an authorization form is attached in
compliance with HIPAA requirements. The attached authorization form is a sample to be used
in providing medical reports, CT scans, MRIs, x-ray films, office notes, and technician and test
reports.
PLEASE TAKE FURTHER NOTICE that, if other and further discoverable medical
treatment and/or health care providers are ascertained through discovery or subpoena practice, a
continuing demand is made upon plaintiff to provide executed and acknowledged authorization
that are compliant with CPLR §§2305 and 3120 and HIPAA §164.508 within 30 days of a
request, of filing of the Note of Issue, and of trial, and defendant reserves the right to move to
strike the case from the calendar and/or move for dismissal and/or preclusions for plaintiff’s
failure to comply with this continuing demand for discoverable materials.
PLEASE TAKE FURTHER NOTICE that the above demands are deemed continuous
and that, upon further discovery, each plaintiff must comply with said demands.
Dated: New York, New York
April 1, 2024
Yours, etc.,
SMITH MAZURE, P.C.
Attorneys for Defendant
Edge Auto Inc.
39 Broadway, 29th Floor
New York, NY 10006-3053
(212) 964-7400
Our File No. PMA-00927
TO:
Glugeth & Pierguidi, P.C.
Attorney for Plaintiffs
Zoila Miyashiro and Victor Luis Lama Renteria
5 Penn Plaza, 19th Floor
New York, NY 10001
(201) 699-5070
-3-
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OCA Official Form No.: 960
AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA
[This form has been approved by the New York State Department of Health]
Patient Name Date of Birth Social Security Number
Zoila Miyashiro
Patient Address
I, or my authorized representative, request that health information regarding my care and treatment be released as set forth on this form:
In accordance with New York State Law and the Privacy Rule of the Health Insurance Portability and Accountability Act of 1996
(HIPAA), I understand that:
1. This authorization may include disclosure of information relating to ALCOHOL and DRUG ABUSE, MENTAL HEALTH
TREATMENT, except psychotherapy notes and CONFIDENTIAL HIV* RELATED INFORMATION only if I place my initials on
the appropriate line in Item 9(a). In the event the health information described below includes any of these types of information and I
initial the line on the box in Item 9(a), I specifically authorize release of such information to the persons indicated in Item 8.
2. If I am authorizing the release of HIV-related, alcohol or drug treatment, or mental health treatment information, the recipient is
prohibited from redisclosing such information without my authorization unless permitted to do so under federal or state law. I understand
that I have the right to request a list of people who may receive or use my HIV-related information without authorization. If I experience
discrimination because of the release or disclosure of HIV-related information, I may contact the New York State Division of Human
Rights at (212) 480-2493 or the New York City Commission of Human Rights at (212) 306-7450. These agencies are responsible for
protecting my rights.
3. I have the right to revoke this authorization at any time by writing to the health care provider listed below. I understand that I may
revoke this authorization except to the extent that action has already been taken based on this authorization.
4. I understand that signing this authorization is voluntary. My treatment, payment, enrollment in a health plan, or eligibility for benefits
will not be conditioned upon my authorization of this disclosure.
5. Information disclosed under this authorization might be redisclosed by the recipient (except as noted above in Item 2), and this
redisclosure may no longer be protected by federal or state law.
6. THIS AUTHORIZATION DOES NOT AUTHORIZE YOU TO DISCUSS MY HEALTH INFORMATION OR MEDICAL
CARE WITH ANYONE OTHER THAN THE ATTORNEY OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9(b).
7. Name and address of health provider or entity to release this information:
8. Name and address of person(s) or category of person to whom this information will be sent:
Smith Mazure, P.C., 39 Broadway, 29th Floor, New York, NY 10006-3053
9(a). Specific information to be released:
Medical Record from (insert date) June 25, 2021 to (insert date) present
Entire Medical Record, including patient histories, office notes (except psychotherapy notes), test results, radiology studies,
films, referrals, consults, billing records, insurance records, and records sent to you by other health care providers.
Other: Include: (Indicate by Initialing)
Alcohol/Drug Treatment
Mental Health Information
Authorization to Discuss Health Information HIV-Related Information
(b). By initialing here I authorize
Initials Name of individual health care provider
to discuss my health information with my attorney or a governmental agency listed here:
Smith Mazure, P.C.
(Attorney/Firm Name or Governmental Agency Name)
10. Reason for release of information: 11. Date or event on which this authorization will expire:
At request of individual Three years or when claim is resolved.
Other: Legal claim for injuries sustained
12. If not the patient, name of person signing form: 13. Authority to sign on behalf of patient:
All items on this form have been completed and my questions about this form have been answered. In addition, I have been provided a
copy of the form.
Date:
Signature of patient or representative authorized by law
* Human Immunodeficiency Virus that causes AIDS. The New York State Public Health Law protects information which
reasonably could identify someone as having HIV symptoms or infection and information regarding a person’s contacts.
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X
VICTOR LUIS LAMA RENTERIA and ZOILA DEMAND FOR LIST
MIYASHIRO, OF ATTORNEYS
Plaintiff, Index No. 500852/2024
-against-
EDGE AUTO INC. and DIONNE COCHRANE, NIKE,
INC., NIKE USA, INC., JN PRODUCTION INC., LION
TELEVISION, and ALL3MEDIA INTERNATIONAL
AMERICA, LLC d/b/a LION TELEVISION
Defendants.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE that, pursuant to CPLR 2103(e), demand is made of you to
supply to the undersigned a list of those defendants who have appeared in the action, and the
names and addresses of the attorneys representing them, if any.
Dated: New York, New York
April 1, 2024
Yours, etc.,
SMITH MAZURE, P.C.
Attorneys for Defendant
Edge Auto Inc.
39 Broadway, 29th Floor
New York, NY 10006-3053
(212) 964-7400
Our File No. PMA-00927
TO:
Glugeth & Pierguidi, P.C.
Attorney for Plaintiffs
Zoila Miyashiro and Victor Luis Lama Renteria
5 Penn Plaza, 19th Floor
New York, NY 10001
(201) 699-5070
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NO APPEARANCE TO DATE:
Lion Television
19 Fulton Street, Floor 5
New York, NY 10038
All3Media International LLC
d/b/a Lion Television
JN Production Inc.
Nike USA, Inc.
Nike Inc.
CAT/aml
31
-2-
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NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 04/02/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X
VICTOR LUIS LAMA RENTERIA and ZOILA DEMAND FOR PHOTOGRAPHS
MIYASHIRO,
Index No. 500852/2024
Plaintiff,
-against-
EDGE AUTO INC. and DIONNE COCHRANE, NIKE,
INC., NIKE USA, INC., JN PRODUCTION INC., LION
TELEVISION, and ALL3MEDIA INTERNATIONAL
AMERICA, LLC d/b/a LION TELEVISION
Defendants.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE that, pursuant to the applicable portions of the C.P.L.R., you
are hereby required to produce for inspection and photocopying any and all photographs
depicting:
1. The scene of the accident.
2. The vehicles involved in the incident both before and after (if applicable).
3. Any bodily injuries alleged to have been suffered by plaintiff (if applicable).
4. Any property damage alleged to have been suffered by plaintiff (if applicable).
5. The instrumentality which caused the damages (if applicable).
Said production is to take place at the offices of SMITH MAZURE, P.C., 39 Broadway,
29th Floor, New York, NY 10006-3053, on May 15, 2024, at 2:00 o’clock in the afternoon.
PLEASE TAKE FURTHER NOTICE that legible photocopies received at this office
on or before the date specified above will be deemed acceptable.
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PLEASE TAKE FURTHER NOTICE that the undersigned reserves the right to
demand duplicate prints of photographs, the reasonable cost of which will be borne by
undersigned.
PLEASE TAKE FURTHER NOTICE that if you are in possession of now, or
subsequent to the date of this demand, come into possession of video, movie, or any other type of
television or electronic media produced photographs of either the scene, the vehicle, the plaintiff,
property damage, or instrumentality, demand is made for the production thereof at the offices of
Smith Mazure, P.C..
Dated: New York, New York
April 1, 2024
Yours, etc.,
SMITH MAZURE, P.C.
Attorneys for Defendant
Edge Auto Inc.
39 Broadway, 29th Floor
New York, NY 10006-3053
(212) 964-7400
Our File No. PMA-00927
TO:
Glugeth & Pierguidi, P.C.
Attorney for Plaintiffs
Zoila Miyashiro and Victor Luis Lama Renteria
5 Penn Plaza, 19th Floor
New York, NY 10001
(201) 699-5070
NO APPEARANCE TO DATE:
Lion Television
19 Fulton Street, Floor 5
New York, NY 10038
All3Media International LLC
d/b/a Lion Television
JN Production Inc.
-2-
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Nike USA, Inc.
Nike Inc.
CAT/aml
31
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X
VICTOR LUIS LAMA RENTERIA and ZOILA NOTICE FOR DISCOVERY
MIYASHIRO, AND INSPECTION
PURSUANT TO CPLR 3101(d)
Plaintiff,
Index No. 500852/2024
-against-
EDGE AUTO INC. and DIONNE COCHRANE, NIKE,
INC., NIKE USA, INC., JN PRODUCTION INC., LION
TELEVISION, and ALL3MEDIA INTERNATIONAL
AMERICA, LLC d/b/a LION TELEVISION
Defendants.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE that demand is hereby made upon you to produce, pursuant
to CPLR 3101(d), the following within twenty (20) days of receipt of this demand:
1. Identify with specificity, including name and last known business address, each
expert witness you or the party you represent intends to call at time of trial.
2. State with specificity, the qualifications of each and every expert witness you or
the party you represent intends to call at time of trial, including, but not limited to educational
backgrounds, professional licenses obtained and state where gained, related academic
experience, work experience, relevant articles published, lectures given and professional
associations with which the expert may be affiliated.
3. State with specificity the subject matter in reasonable detail upon which the expert
is expected to testify at the time of trial.
4. With respect to each expert, state:
A. The facts and opinions upon which the expert is expected to testify at time
of trial;
B. When this expert was retained by counsel;
C. With whom the expert has consulted in reaching his opinions and
conclusions with regard to this matter and provide their last known
business address;
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D. Whether this expert has had occasion to visit the scene of this occurrence,
and provide the dates involved.
5. Provide a summary of the grounds of each expert’s opinion and attach any data in
support of each opinion and conclusion.
6. Attach a complete copy of each expert’s report, including photographs, exhibits,
diagrams, charts, and any other material prepared by this expert in connection with this retainer.
7. State whether any of the named experts have previously testified on behalf of
your law office in other litigation. If so, provide case name and index number.
PLEASE TAKE FURTHER NOTICE that the within demand is a continuing demand
and, in the event that an expert is retained subsequent to your response to this demand, you are to
provide updated answers to the foregoing discovery demands. Your failure to do so will result in
the preclusion of any testimony of any expert not identified pursuant to this demand.
Dated: New York, New York
April 1, 2024
Yours, etc.,
SMITH MAZURE, P.C.
Attorneys for Defendant
Edge Auto Inc.
39 Broadway, 29th Floor
New York, NY 10006-3053
(212) 964-7400
Our File No. PMA-00927
TO:
Glugeth & Pierguidi, P.C.
Attorney for Plaintiffs
Zoila Miyashiro and Victor Luis Lama Renteria
5 Penn Plaza, 19th Floor
New York, NY 10001
(201) 699-5070
NO APPEARANCE TO DATE:
Lion Television
19 Fulton Street, Floor 5
New York, NY 10038
-2-
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All3Media International LLC
d/b/a Lion Television
JN Production Inc.
Nike USA, Inc.
Nike Inc.
CAT/aml
31
-3-
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X
VICTOR LUIS LAMA RENTERIA and ZOILA DEMAND FOR THE
MIYASHIRO, NAMES AND ADDRESSES
OF ALL WITNESSES
Plaintiff,
Index No. 500852/2024
-against-
EDGE AUTO INC. and DIONNE COCHRANE, NIKE,
INC., NIKE USA, INC., JN PRODUCTION INC., LION
TELEVISION, and ALL3MEDIA INTERNATIONAL
AMERICA, LLC d/b/a LION TELEVISION
Defendants.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE that the undersigned hereby demands, pursuant to CPLR
3101(a), that you set forth in writing and under oath, within ten (10) days of the service of this
demand upon you, the name and address of each person claimed, by any party you represent, to
be a witness to any of the following:
A. The occurrence alleged in the complaint; and/or
B. Any acts, omissions or conditions which allegedly caused the occurrence
alleged in the complaint; and/or
C. Any actual notice allegedly given to any defendant or any employee of
defendant of any condition which allegedly caused the occurrence alleged
in the complaint; and/or
D. The nature and duration of any alleged condition which allegedly caused
the occurrence alleged in the complaint.
If no such witnesses are known to you, so state in reply to this demand. The undersigned
will object upon trial to the testimony of any witnesses not so identified.
PLEASE TAKE FURTHER NOTICE that the within demand is a continuing demand.
In the event any of the above items are obtained after service of this demand, they are to be
furnished to this office.
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NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 04/02/2024
Dated: New York, New York
April 1, 2024
Yours, etc.,
SMITH MAZURE, P.C.
Attorneys for Defendant
Edge Auto Inc.
39 Broadway, 29th Floor
New York, NY 10006-3053
(212) 964-7400
Our File No. PMA-00927
TO:
Glugeth & Pierguidi, P.C.
Attorney for Plaintiffs
Zoila Miyashiro and Victor Luis Lama Renteria
5 Penn Plaza, 19th Floor
New York, NY 10001
(201) 699-5070
NO APPEARANCE TO DATE:
Lion Television
19 Fulton Street, Floor 5
New York, NY 10038
All3Media International LLC
d/b/a Lion Television
JN Production Inc.
Nike USA, Inc.
Nike Inc.
CAT/aml
31
-2-
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------X
VICTOR LUIS LAMA RENTERIA and ZOILA DEMAND FOR
MIYASHIRO, STATEMENTS PURSUANT
TO CPLR 3101(e) and 3120
Plaintiff,
Index No. 500852/2024
-against-
EDGE AUTO INC. and DIONNE COCHRANE, NIKE,
INC., NIKE USA, INC., JN PRODUCTION INC., LION
TELEVISION, and ALL3MEDIA INTERNATIONAL
AMERICA, LLC d/b/a LION TELEVISION
Defendants.
----------------------------------------------------------------------X
PLEASE TAKE NOTICE that demand is hereby made upon you to produce, pursuant
to CPLR 3101(e) and 3120, and to permit us to discover, inspect, copy and photocopy any
statement in the possession, custody or control of any party you represent in this action or in your
file, actually or allegedly made by or taken from any defendant we represent in this action, or
from any agent, servant or employee of any such defendant at:
DATE & : May 15, 2024, at 2:00 p.m.
TIME
PLACE : Smith Mazure, P.C.
39 Broadway, 29th Floor
New York, NY 10006-3053
(212) 964-7400
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or to mail said photocopies to this office before said date.
Dated: New York, New York
April 1, 2024
Yours, etc.,
SMITH MAZURE, P.C.
Attorneys for Defendant
Edge Auto Inc.
39 Broadway, 29th Floor
New York, NY 10006-3053
(212) 964-7400
Our File No. PMA-00927
TO:
Glugeth & Pierguidi, P.C.
Attorney for Plaintiffs
Zoila Miyashiro and Victor Luis Lama