Motion for Appointment re Probate in Martha Portilla v. Ashkan Enayatian, John Doe a driver not yet identified| Trellis.Law

On August 09, 2021 a Exhibit,Appendix was filed involving a dispute between Martha Portilla, and Ashkan Enayatian, John Doe A Driver Not Yet Identified, for Torts - Motor Vehicle in the District Court of Kings County.

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FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
______________________________________________________________________Ç
MARTHA PORTILLA,

Plaintiff, Index No.: 520092/2021

-against- VERIFIED BILL OF
PARTICULARS
ASHKAN ENAYATIAN and JOHN DOE, a driver not

yet identified.

Defendants.
__________________________________-----__-------______________________Ç

Plaintiff, MARTHA PORTILLA, by her attomeys, ELEFTERAKIS, ELEFTERAKIS &

PANEK, as and for a response to Defendant, ASHKAN ENAYATIAN's, Demand for a Verified

Bill of Particulars, sets forth:

1. The subject incident occurred on November 18, 2018 at approximately 4:00 p.m.

2. The subject incident occurred at the roadway known as the Jackie Robinson Parkway near

Exit 4, in Queens County. State of New York. Plaintiff objects to the remainder of this

demand as it (1) is in the form of an interrogatory barred by CPLR 3130, (2) seeks

information that is evidentiary in nature and is,therefore, improper and outside the scope of

a bill of particulars, and (3) is not permitted by CPLR 3043.

3. Defendant was careless, negligent and/or reckless and as follows:

- in to be alert,attentive and
failing vigilant;

- in to a proper
failing keep lookout;

- in to sound sirens, horns, or to engage lights so as to wam the other
failing flashing

RECEIVED
vehicle:

JUL 13 2022

Karen L. Lawrence,
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
" "

- in to observe the road and the presence of other vehicles on the road:
failing

- in to see the other motor
failing timely vehicle;

- in to have their motor vehicle under reasonable and proper
failing control;

- in to and
failing timely properly apply brakes;

- in to and turn mechanisms:
failing timely properly steering

- in to give signal. notice or of said motor vehicle's approach:
failing any waming

- in to take steps and or actions to avoid the accident:
failing necessary

- in to slow and/or while other vehicle:
failing properly stop approaching

- in and their vehicle to collide with and strike other vehicle in the
causing permitting

rear:

- in to a proper distance between the motor vehicles of Defendant and the
failing keep

Plaintiff's vehicle:

- in to the vehicle that Defendant was in a safe manner or
failing stop operating

location:

- in to take steps and/or actions to avoid the
failing necessary accident;

- in the motor vehicle while said vehicle was defective and out
operating mechanically

of repair:

- in said motor vehicle in violation of applicable statute. laws. rules.
operating

regulations and ordinances including but not limited to the Vehicle and Traffic Laws

of the State of New York and the Traffic Regulations of the City of New York and in

otherwise operating the vehicle(s) of Defendant in a careless. reckless and negligent

manner. under the circumstances prevailing at the time of the accident.
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021

" "
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022

The aforesaid accident was due solely and wholly as a result of the careless and negligent

manner in which the Defendant owned, operated. maintained and controlled the aforesaid

location. without the Plaintiff in any way contributing thereto.

4. Part of vehicles on contact: Plaintiff objects to this demand as (1) it is in the form of an

interrogatory barred by CPLR 3130, (2) seeks information that is evidentiary in nature and

is.therefore. improper and outside the scope of a bill of particulars. and (3) is not permitted

by CPLR 3043.

5. Damage to Plaintiffs vehicle: To be provided. if applicable.

6. Make and model: Plaintiff objects to this demand as (1) it isin the fbrm of an interrogatory

barred by CPLR 3130, (2) seeks information that is evidentiary in nature and is. therefore.

improper and outside the scope of a bill of particulars. and (3) is not permitted by CPLR

3043.

7. The following injuries were caused. aggravated. accelerated. precipitated and or enhanced

as a result of Defendant's negligence:

Cervical Spine:

- At C4-C5, broad central dise herniation causes compression upon the cord:
- At C5-C6. ventral osteophyte formation:
- At disc bulge which effaces the subarachnoid
C6-C7, space;
- Disc displacement;
- Myclopathy:
- Radiculopathy:
- Internal derangement;
- Joint effusion:
- Myofascial derangement;
- Marked restriction of range of motion;
- Muscle spasms;
- Need for future physical therapy;
- Need for future pain management:
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021

" "
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022

- Need for future orthopedic care;
- Need for future neurological and
care;
- Need for future of the cervical but not limited to
surgery spine, including
discectomy, laminectomy. fusion, and/or revision, inter alia.

As a result of the above injuries, Plaintiff suffers from persistent pain to the cervical

spine; curtailment of the range of motion of the cervical spine, loss of function, loss of

strength, aggravation, exacerbation and precipitation of a pre-existing latent and
asymptomatic degenerative condition, difficulty in sleeping, pain radiating to the leR and

right upper extremity, all with involvement of the surrounding soñ tissues, nerve endings,
blood vessels, muscles, tendons and ligaments, all with resultant pain, deformity and
disability.

Lumbosacral Spine:

- At L3-L4, subligamentous disc with encroachment on the neural foramina
bulging
and bilateral facet hypertrophy;
- At L4-L5, subligamentous disc the ventral thecal sac with bilateral
bulging flattening
facet hypertrophy;
- At subligamentous disc with of the ventral thecal sac and
L5-Sl, bulging flattening
bilateral facet hypertrophy;
- Myelopathy;
-
Radiculopathy;
- Intemal derangement;
- Joint effusion;
- Disc displacement;
- Myofascial derangement;
- Marked restriction of range of motion;
- Muscle spasms;
- Need for future physical therapy;
- Need for future pain management;
- Need for future orthopedic care;
- Need for future neurological care; and
- Need for future of the lumbosacral but not limited to
surgery spine, including
discectomy, laminectomy, fusion, and/or revision, inter alia.

As a result of the above injuries, Plaintiff suffers from persistent pain to the
lumbosacral spine; curtailment of the range of motion of the lumbosacral spine, loss of

function, loss of strength, aggravation, exacerbation and precipitation of a pre-existing
latent and asymptomatic degenerative condition, difficulty in sleeping, pain radiating to the
len and right lower extremity, all with involvement of the surrounding soR tissues, nerve

endings, blood vessels, muscles, tendons and ligaments, all with resultant pain, deformity
and disability.
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
" "

Head/Brain:

- Cortical within the left medial orbitofrontal left posterior-superior
atrophy region,
temporal sulcus and the right entorhinal region;
- Foci of abnormal signal with the white
intensity matter;
- Significant major metabolite ratio alteration on MR most
Spectroscopy analysis,
compatible with traumatic brain injury;
- Traumatic brain injury;
- Post concussive syndrome;
-
Headaches;
- Light headedness;
- Need for future physical therapy;
- Need for future pain management;
- Need for future orthopedic care;
- Need for future neurological care;
- Need for cognitive therapy;
- Need for psychiatric treatment;
- Need for internal medicine;
- Need for occupational and
therapy;
- Need for future of the head/brain.
surgery

As a result of the above injuries, Plaintiff suffers from persistent pain to the

head/brain; loss of function, loss of strength, aggravation, exacerbation and precipitation of
a pre-existing latent and asymptomatic degenerative condition, difficulty in sleeping, all
with involvement of the surrounding soft tissues, nerve endings, blood vessels, muscles,
tendons and ligaments, all with resultant pain, deformity and disability.

Other:

- Muscle weakness:
- and
Body numbness;
- Bilateral shoulder injury;

The foregoing injuries directly affected the bones, tendons, tissues, muscles

ligaments, nerves, blood vessels and soft tissue in and about the involved areas.

Associated and concomitant impairments and negative effects upon Plaintiff pre
accident enjoyment of life, day-to-day existence, activities, functions, employment and
involvements.

Limitation, diminution and/or effect of functions. activities, vocation, avocation and
all other activities in which the Plaintiff engaged prior to the underlying accident.
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021

"
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
"

Inability to resume pre-accident social relations, contacts and participation.

Associated pains, disabilities, discomforts, impairments, impediments, limitations of
function and activities.

Restriction and limitation of motion and pain on motion and possible loss of use of
the above mentioned parts, atrophy, anxiety and mental anguish, and all having
substantially prevented this Plaintiff from enjoying the normal fruits of activities, social,
educational and economical.

These injuries have increased the probability of arthritic conditions as well as

probability of injury due to decreased strength.

Upon information and belief the effects of Plaintiffs injuries (with the exception of

those, if any, of a superficial and/or transitory nature) are considered to be of a permanent
and/or long lasting nature, and same are continuing to cause measurable diminution of

integrity in the use and motion of traumatized involved parts and soft tissue structures, and
are continuing to adversely affect and impair Plaintiff's feeling of well-being, general
physical condition and all of her daily physical activities.

All of the above injuries, upon information and belief are permanent in that Plaintiff
suffers associated tearing of muscles, ligaments and tendons and healing of these structures
with scarring and nerve root irritation, recurrent pain and restriction of motion with
exacerbation and remissions and significant residual disabilities and limitations.

Said injuries have directly and indirectly adversely affected the nerves, tissue, blood

vessels, blood supply, muscles, ligaments, cartilages, tendons, bones and soft parts in and
about the sites of the above described areas of injury, including the central nervous

systems, muscular system and skeletal system.

Additionally, with advancing years, there will be naturally and medically related
complications and exacerbations that will lead to the need for surgical intervention.

Plaintiff, to her detriment, will continue to sustain permanent loss and impairment of
her physical and mental health and will continue to need physical therapy and medical care
indefinitely.

Plaintiff will continue to sustain loss, impairment, impediment, diminution and
retardation of the enjoyment of life.

As a result of the above, Plaintiff has become unable to perform her usual and daily
activities and will in the future be unable to perform her usual daily activities and
employment.
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021

"
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
"

All of the aforementioned injuries, resulting disabilities and involvements, are

associated with further soft tissue injury to areas traumatically affected, including injury,
tearing, derangement and damage to the associated muscle groups, ligaments, tendons,
blood vessels and blood supply, spinal connective and nerves and nerve tissue, epithelial

tissue, soft tissue, all concomitant to the specific injuries and related to the many portions

mentioned herein-above, with resultant pain, deformity and disability, stiffness, tenderness,
weakness and partial restriction and limitation of motion and pain on motion and possible
loss of use of the above mentioned parts, atrophy, anxiety and mental anguish.

The injuries the Plaintiff sustained have the potential to have exacerbated,
aggravated, accelerated and/or otherwise enhanced a latent, asymptomatic and/or

degenerative condition, and have the potential to have increased Plaintiff's susceptibility
for injury due to such a condition.

Plaintiff claims all injuries sustained in the subject incident, besides those injuries

transitory in nature, are permanent.

8. Plaintiff was confined as follows:

(a) Hospital: See Plaintiffs Response to Combined Demands.

(b) It is impossible to state with reasonable certainty the exact division of time Plaintiff

was actually confined to bed. except to state that there were periods of bed

confinement; Further, Plaintiff can more appropriately respond to this demand at her

deposition.

was actually confined to home, except to state that there were periods of home

confinement: Further. Plaintiff can more appropriately respond to this demand at her

deposition.

9. Plaintiff is not setting forth claim for lost earnings at this time. As such. Plaintiff objects to

this demand as it(1) is in the fonn of an interrogatory barred by CPLR 3130. (2) seeks

information that is evidentiary in nature and is.therefore. improper and outside the scope of
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021

"
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
"

a hill of particulars. and (3) is not permitted by CPLR 3043.

10. Plaintiff claims the following in Special Damages:

(a) Physician's services: .........................Apx. $25,000.00 and continuing;

"(a)"
(b) Medical supplies:.............................See item herein;

a. Loss of earnings: .............................Plaintiff is currently not setting forth a

claim for loss of eamings. Plaintiff reserves the right to amend and/or supplement

this response;

Nurses' "(a)"
(c) services:..............................See item herein;

"(a)"
(d) Hospital expenses: ...........................See item herein;

"(a)"
(e) X-rays expenses: .............................See item herein; and

(f) Other items of special damages: ........... Plaintiff is claiming past, present. and

future medical bills and past, present. and future pain and suffering. amounts which will be

determined at trial by the trier of fact. Plaintiff's special damages are continuing and Plaintiff

expressly reserves the right to prove any additional and future costs at the time of trial.

It is anticipated that Plaintiff(s) will require future treatment for the body parts alleged herein,

including but not limited to: Epidural steroid injections, facet injections. radiofrequency ablation,

physical therapy, chiropractic treatment, analgesics, MRI's, medications, pain management,

surgery follow-ups. greater occipital nerve block injections. nerve conduction studies. CAT

"lubrication"
scans. diagnostic studies, anesthesia. implants. trigger point injections. joint

injections, spinal cord stimulator. surgery and revision surgery.

Anticipated future medical costs are estimated at S2,000,000.00.

PLEASE TAKE NOTICE, PLAINTIFF'S SPECIAL DAMAGES ARE CONTINUING.
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021

"
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
"

"10"
(g) See Plaintiff's response to Defendant's demand numbered herein.

School/Student: Not applicable.

1 1. Plaintiff sustained a serious injury as defined in Section 5102(d) of the Insurance Law of

the State of New York in that Plaintiff sustained permanent loss of use of a body organ.

member. function or system; a permanent consequential limitation of use of a body organ

or member: a significant limitation of use of a body function or system; and/or a medically

determined injury or impairment of a non-permanent nature which prevented Plaintiff from

performing substantially all of the material acts which constituted her usual and customary

daily activities for not less than 90 days during the 180 days immediately following the

subject accident. Additionally. Plaintiff has sustained economic loss and excessive basic

economic loss in that Plaintiff has or will in the future incurred medical, hospital and other

reasonable necessary expenses that have or will exceed $50,000.00.

12. - 13. Negligent entrustment: Not applicable.

14. - Actual or constructive notice: Not applicable.
(a) (c)

15. -17. Plaintiff claims approximately $50,000,000 in total damages.

18. - 19. Defendant violated New York Vehicle & Traffic Law 1 100, 1 101, 1 129, 1 146.
§§

1 180. 1212. 1226, 1229 and New York City Traffic Rules, tit. 34, §§ 4-02(c). 4-02(d). and

4-06 and New York City Traffic Rules. tit.34. §§ 4-02(c). 4-02(d). and 4-06. In addition,

the Court will take judicial notice at trial of those statutes and ordinances violated by

Defendant not mentioned herein.

PLEASE TAKE FURTHER NOTICE that Plaintiff reserves her right to amend and/or

supplement the above responses. up to and including the time of trial. if and when additional
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
" "

information becomes available.

Dated: New York, New York

July 12. 2022

Yours. etc..
ELE KIS. ELEFTERAKIS & PANEK

David Sullivan, Esq.
Attorneys for Plaintiff
380'
80 Pine Street, Floor
New York, New York 10005

(212) 532-1116

To: LAW OFFICES OF KAREN L. LAWRENCE
Attorney for Defendant,
ASHKAN ENAYATIAN
1225 Franklin Avenue, Suite 100

Garden City, New York 11530-1659
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
" "

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_________________________________________________________-------______Ç

MARTHA PORTILLA, Index No.: 520092/2021

Plaintiff.
VERIFICATION
-against-

ASHKAN ENAYATIAN and JOHN DOE, a driver not

yet identified.

Defendants.
_______________________________________________________________________Ç

STATEOFNEWYORK )
) ss:
COUNTY OF NEW YORK )

I.the undersigned. an attomey admitted to practice in the courts of New York State. state

under penalty of perjury that I am one of the attorneys for Plaintiff in the within action; that I

have read the foregoing VERIFIED BILL OF PARTICULARS and know the contents thereof

and that the statements contained therein are true to my own knowledge. except as to the matters

therein stated to be alleged on information and belief, and as to those matters I believe to be true.

The reason this verification is made by me and not by my client is that my client does not reside

in the County where I maintain my offices. The grounds of my belief as to all matters not stated

upon my own knowledge are the materials in my file and the investigations conducted by my

office.

Dated: New York. New York

July 12, 2022

David Sullivan.Esq.
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
________________-___--------------------------------------------------Ç
MARTHA PORTILLA. Index No.: 520092/2021

Plaintiff. RESPONSE TO
COMBINED DEMANDS
-against-

ASHKAN ENAYATIAN and JOHN DOE. a driver not
yet identified,

Defendants.
-------------------------__------------______----___-----------------Ç

Plaintiff, MARTHA PORTILLA, by her attorneys. ELEFTERAKlS. ELEFTERAKIS &

PANEK. as and for a response to Defendant. ASHKAN ENAYATIAN's, Combined Demands,

sets forth as follows:

COMBINED DEMAND FOR DISCOVERY AND INSPECTION

1. - Witness: Plaintiff is unaware of witnesses at this time other than those
(a) (d) any

individuals listed on the police report. Plaintiff reserves her right to amend this response.

2. Plaintiff is not in possession of any party statements at this time. Plaintiff reserves her

right to amend this response.

3. - Plaintiff is not in possession of photographs of scene of alleged
(a) (b) any

occurrence at this time. Plaintiff will refer Defendants to any publicly available images

obtainable through the internet. including but not limited to. Google Street View. Further,

Plaintiff reserves his right to amend this response.

4. Accident report: Not applicable.
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
" "

5. Diagrams, drawings, notes, records: Objection. Defendant's demand is vague,

overbroad, unduly burdensome and not likely to lead to the disclosure of discoverable evidence.

Defendant'
6. Any notes. records, memoranda, diagrams, and drawings: Objection. s

demand is vague, overbroad, unduly burdensome and not likely to lead to the disclosure of

discoverable evidence.

7. - 1 1. Plaintiff will call health care providers at the time of trial who will based
testify

upon the history of the trauma, the physical complaints made by Plaintiff, the physical

examinations conducted by the health care provider, the results of diagnostic tests performed on

Plaintiff, review of medical records and report of other health care providers who have treated

and examined Plaintiff. the substance of which are contained in the narrative reports of said

physician, as well as the health care providers education, training and expertise in its particular

field of medicine.

An expert response pursuant to CPLR 3101 (4) (d) (1) will be provided prior to trial.

12. Maintenance and repair records for one year prior: Objection. Defendant's

demand is vague, overbroad, unduly burdensome and not likely to lead to the disclosure of

relevant evidence.

13. Copies of any letters or written communications citing defective conditions: Not

applicable.

14. a. Objection. Defendant's demand is vague, overbroad, unduly burdensome and

not likely to lead to the disclosure of discoverable evidence as PlaintifT is currently not setting

forth a claim for lost earnings.
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022
" "

(a) School records: Not applicable.

15. Income Tax Records: Objection. Plaintiff was not self-employed, therefore a demand

for tax records is palpably improper. See Otto v. Triangle Aviation Services, Inc., 258 A.D.2d

448, 684 N.Y.S.2d 612 (2d Dep't 1999); Nanbar Realty Corp. v. Pater Realty Co., 242 A.D.2d

208, 661 N.Y.S.2d 216 ( 1stDep't 1997).

16. - 17. No-fault: Enclosed herein is an authorization to obtain Plaintiff's No-fault file,

maintained by Geico Insurance

18. - Workers Compensation: Not applicable.
(a) (b)

19. - claim: To be provided, if applicable.
(a) (b) Disability

20. - Upon information and belief, Plaintiff's collateral source is No-fault file
(a) (d) only

maintained by Geico Insurance

Enclosed herein are an authorization to obtain Plaintiff's collateral source records.

21. Marriage Certificate: Not applicable.

22. Infant son/daughter: Not applicable.

23. Withholding statements, pay envelopes. deposit slips: Objection. Defendant's

demand is vague, overbroad, unduly burdensome and not likely to lead to the disclosure of

discoverable evidence as Plaintiff is currently not setting forth a claim for lost earnings.

24. Copies of any and all bills, statements or receipts for non-medical expenses:

Objection. Defendant's demand is vague, overbroad, unduly burdensome and not likely to lead

to the disclosure of discoverable evidence.

25. Copies of bills and/or estimates for the repair of Plaintiff s vehicle: To be provided,

if applicable.
FILED: KINGS COUNTY CLERK 11/10/2022 09:31 AM INDEX NO. 520092/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 11/10/2022

26. Any releases. and any other type of settlement agreements: Not applicable.

27. Photographs, Blow-ups. recordings. charts. graphs. sketches etc.: To be provided. if

applicable.

28. All documents, papers or evidence at trial:To be provided. ifapplicable.

DEMAND FOR COPIES OF PLAINTlFF'S MEDICAL REPORTS

1. - 3. Enclosed herein are medical records and authorizations to obtain medical records

from the following facilities:

a. The Brooklyn Hospital Center. 121 DeKalb Avenue, Brooklyn, New York

11201;

b. Stand Up MRI of Queens. P.C.. 167-20 Union Tumpike, Flushing, New York

11366;

c. Physicians Open MRI. 1991 Marcus Avenue. Suite 110. Lake Success, New

York 11042:

d. Physical Medicine and Rehabilitation of New York. 95-20 Queens Boulevard,

Rego Park. New York 11374;

32nd
e. Alpha 3T MRI & Diagnostic Imaging. 145 East Street, Ground Floor,

New York 10016:

f. NYC Medical & Neurological Offices. P.C.. 91-31 Queens Boulevard.

Case Info

Judge

Ingrid Joseph Track Judge’s New Case

Case No.

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Document Filed Date

November 10, 2022

Case Filing Date

August 09, 2021

County

Parties

Ashkan Enayatian Defendant
ELEFTERAKIS, NICHOLAS Attorney for the Plaintiff
John Doe a driver not yet identified Defendant
Martha Portilla Plaintiff
RABINOWITZ, MATTHEW IRA Attorney for the Plaintiff
SHAPIRO, ADAM PHILIP Attorney for the Defendant
SULLIVAN, DAVID Attorney for the Plaintiff
CLAIRE MARTIN Attorney
KENNETH PINCZOWER Attorneys for Defendants
DAVID SUH Attorneys for Plaintiffs

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Exhibit,Appendix: Martha Portilla v. Ashkan Enayatian, John Doe a driver not yet identified

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