On March 09, 2018 a
Party Notice
was filed
involving a dispute between
Miriam Galeano Vegara,
and
Adolfo V. Beltre,
Little Richie Bus Co,
Little Richie Bus Service Inc,
for Torts - Motor Vehicle
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 08/20/2019 02:10 PM INDEX NO. 703599/2018
NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 08/20/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
_______ X
MIRIAM GALEANO VERGARA, Index No. 703599/18
Plaintiff, NOTICE FOR DISCOVERY AND
-against- INSPECTION
LITTLE RICHIE BUS CO., LITTLE RICHIE BUS
SERVICE INC. and ADOLFO V. BELTRE,
Defendants.
------ X
PLEASE TAKE NOTICE, that pursuant to Article 31 of the New York Civil
Practice Law and Rules, defendants, LITTLE RICHIE BUS CO., LITTLE RICHIE BUS
SERVICE INC. and ADOLFO V. BELTRE, hereby demands that you produce and serve
upon and deliver to the undersigned, within twenty (20) days from the date of service of
this demand, at the offices of BAMUNDO, ZWAL & SCHERMERHORN, LLP, 111
John Street, New York, New York 10038, the following for discovery, inspection,
copying and photographing:
1. A duly executed authorization to secure the records regarding plaintiffs
ablation as testified to at her August 2, 2019 Suppkmental Deposition.
2. A duly executed authorization to secure the films and reports for the
October 2018 MRI taken of her lumbarspine.
3. A duly executed authorization to secure all pharmacy records at CVS
Pharmacy as testified to at plaintiffs August 2, 2019 examination before
trial.
4. A duly executed authorization to secure the loan documents which plaintiff
testified financed her lumbar surgery.
1 of 2
FILED: QUEENS COUNTY CLERK 08/20/2019 02:10 PM INDEX NO. 703599/2018
NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 08/20/2019
PLEASE TAKE FURTHER NOTICE, that this notice shall be deemed continuing so as
to require supplemental answers in the event that additional information is obtained of a character
called for by this notice between the time a resperise is served and the time of trial.
PLEASE TAKE FURTHER NOTICE, that upon your failure to respond, the defendant
will, at the time of the trial, object to and move to preclude against the testimony of any witness
and/or introduction of any evidence concerning that information which has been demanded by this
notice, but not fully supplied.
Dated: New York, New York
August 20, 2019
Yours, etc.,
. .
BAMUNDO, ZWAL & SCHERMERHORN, LLP
James . Schermerhorn, Esq.
Atto eys for Defendants
111 John Street, Suite 1100
New York, New York 10036
(212) 608-8840
File No. LBC 6881-PP
TO:
WILLIAM SCHWITZER & ASSOCIATES, P.C.
Attorneys for Plaintiff
10*
820 Second Avenue, Floor
New York, New York 10017
(212) 685-7800
2 of 2
Document Filed Date
August 20, 2019
Case Filing Date
March 09, 2018
Category
Torts - Motor Vehicle
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FILED: QUEENS COUNTY CLERK 08/20/2019 02:10 PM INDEX NO. 703599/2018 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 08/20/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS _______ X MIRIAM GALEANO VERGARA, Index No. 703599/18 Plaintiff, NOTICE FOR DISCOVERY AND -against- INSPECTION LITTLE RICHIE BUS CO., LITTLE RICHIE BUS SERVICE INC. and ADOLFO V. BELTRE, Defendants. ------ X PLEASE TAKE NOTICE, that pursuant to Article 31 of the New York Civil Practice Law and Rules, defendants, LITTLE RICHIE BUS CO., LITTLE RICHIE BUS SERVICE INC. and ADOLFO V. BELTRE, hereby demands that you produce and serve upon and deliver to the undersigned, within twenty (20) days from the date of service of this demand, at the offices of BAMUNDO, ZWAL & SCHERMERHORN, LLP, 111 John Street, New York, New York 10038, the following for discovery, inspection, copying and photographing: 1. A duly executed authorization to secure the records regarding plaintiffs ablation as testified to at her August 2, 2019 Suppkmental Deposition. 2. A duly executed authorization to secure the films and reports for the October 2018 MRI taken of her lumbarspine. 3. A duly executed authorization to secure all pharmacy records at CVS Pharmacy as testified to at plaintiffs August 2, 2019 examination before trial. 4. A duly executed authorization to secure the loan documents which plaintiff testified financed her lumbar surgery. 1 of 2 FILED: QUEENS COUNTY CLERK 08/20/2019 02:10 PM INDEX NO. 703599/2018 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 08/20/2019 PLEASE TAKE FURTHER NOTICE, that this notice shall be deemed continuing so as to require supplemental answers in the event that additional information is obtained of a character called for by this notice between the time a resperise is served and the time of trial. PLEASE TAKE FURTHER NOTICE, that upon your failure to respond, the defendant will, at the time of the trial, object to and move to preclude against the testimony of any witness and/or introduction of any evidence concerning that information which has been demanded by this notice, but not fully supplied. Dated: New York, New York August 20, 2019 Yours, etc., . . BAMUNDO, ZWAL & SCHERMERHORN, LLP James . Schermerhorn, Esq. Atto eys for Defendants 111 John Street, Suite 1100 New York, New York 10036 (212) 608-8840 File No. LBC 6881-PP TO: WILLIAM SCHWITZER & ASSOCIATES, P.C. Attorneys for Plaintiff 10* 820 Second Avenue, Floor New York, New York 10017 (212) 685-7800 2 of 2