Preview
(FILED: SUFFOLK COUNTY CLERK 0672272021 09:46 AM INDEX NO. 606238/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/22/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
wee eee cece eee e eee eeeee eee eeneeeeeeeeee X
CONSTANCE MANSFIELD, DEMAND FOR SOCIAL
SECURITY EARNINGS
Plaintiff, INFORMATION
-against- Index No. 606238/2021
EMILY A. DAMATO and ANTHONY S. DAMATO,
Defendants.
COUNSELORS:
PLEASE TAKE NOTICE that, pursuant to Article 31 of the CPLR, you are hereby
required to produce for discovery, inspection, and photocopying at the offices of Pillinger Miller
Tarallo, LLP, 555 Taxter Road, 5th Floor, Elmsford, NY 10523, within 20 days after receipt of
this notice, the following:
1. A duly executed Request for Social Security Eamings Information (Form SSA-
7050-FF4) releasing itemized Statement of Earnings - Certified.
2. Anauthorization permitting Pillinger Miller Tarallo, LLP and/or GEICO to obtain
plaintiff’ s itemized Statement of Earnings - Certified.
PLEASE TAKE FURTHER NOTICE, that this demand shall be deemed to continue
during the pendency of this action. Furthermore, if plaintiff fails to timely comply with this
demand, motion will be made to either dismiss this action or to preclude plaintiff from offering
at the time of trial of this action any evidence pertaining to, or contained in the items demanded.
PLEASE TAKE FURTHER NOTICE that, upon your failure to produce the aforesaid
documents, at the time and place required in this notice, defendants will oppose any attempts to
1 of 3(FILED: SUFFOLK COUNTY CLERK 0672272021 09:46 AM INDEX NO. 606238/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/22/2021
place this case on the trial calendar of this court and/or appropriate motions for relief will be
made to this court.
PLEASE TAKE FURTHER NOTICE that, in lieu of producing the items demanded
herein, you may serve and submit to the undersigned true and conformed copies of the items
demanded herein at any time prior to the aforesaid date.
Dated: Elmsford, New Y ork
June 18, 2021
Y ours, etc.,
Kenneth A. Finder
PILLINGER MILLER TARALLO, LLP
KENNETH A. FINDER
Attorneys for Defendants
Emily A. Damato and Anthony S. Damato
555 Taxter Road, 5th Floor, Elmsford, NY 10523
Office No: (914) 703-6300
PMT File No. GIC-01948/KAF
TO:
WINKLER KURTZ, LLP
Attorney for Plaintiff
Constance Mansfield
1201 Route 112, Suite 200
Port Jefferson, NY 11776
Phone: (631) 928-8000
File No:
2 of 3(FILED: SUFFOLK COUNTY CLERK 0672272021 09:46 AM INDEX NO. 606238/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/22/2021
INDEX NO. 606238/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
Xx
CONSTANCE MANSFIELD,
PLAINTIFF,
-AGAINST-
EMILY A. DAMATO AND ANTHONY S. DAMATO,
DEFENDANTS.
-X
DEMAND FOR SOCIAL SECURITY EARNINGS INFORMATION
PILLINGER MILLER TARALLO, LLP
Attorneys for Defendants
Emily A. Damato and Anthony S. Damato
555 Taxter Road, 5th Floor, Elmsford, NY 10523
(914) 703-6300
GIC-01948/KAF
CERTIFICATION PURSUANT TO 22 NY.C.R.R. § 130-1. Ja
Kenneth A. Finder hereby certifies that, pursuant to 22 N.Y.C.R.R. § 130-1.1a, the foregoing DISCLOSURE
DEMAND is/are neither frivolous nor frivolously presented. Kennetiva. Finder
Dated: Elmsford, New Y ork
June 18, 2021 KENNETH A. FINDER
PLEASE TAKE NOTICE
that the within is a true copy of a entered in the office of the clerk of the within named Court on
that a of which the within is a true copy will be presented for settlement to the Hon. one of
the judges of the within named Court at , onat 9:30 am.
PALLINGER MILLER TARALLO, LLP
Attorneys for Defendants
Emily A. Damato and Anthony S. Damato
555 Taxter Road, 5th Floor, Elmsford, NY 10523
(914) 703-6300
PMT File No. GIC-01948/KAF
KAF/mh
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Preview
(FILED: SUFFOLK COUNTY CLERK 0672272021 09:46 AM INDEX NO. 606238/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/22/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK wee eee cece eee e eee eeeee eee eeneeeeeeeeee X CONSTANCE MANSFIELD, DEMAND FOR SOCIAL SECURITY EARNINGS Plaintiff, INFORMATION -against- Index No. 606238/2021 EMILY A. DAMATO and ANTHONY S. DAMATO, Defendants. COUNSELORS: PLEASE TAKE NOTICE that, pursuant to Article 31 of the CPLR, you are hereby required to produce for discovery, inspection, and photocopying at the offices of Pillinger Miller Tarallo, LLP, 555 Taxter Road, 5th Floor, Elmsford, NY 10523, within 20 days after receipt of this notice, the following: 1. A duly executed Request for Social Security Eamings Information (Form SSA- 7050-FF4) releasing itemized Statement of Earnings - Certified. 2. Anauthorization permitting Pillinger Miller Tarallo, LLP and/or GEICO to obtain plaintiff’ s itemized Statement of Earnings - Certified. PLEASE TAKE FURTHER NOTICE, that this demand shall be deemed to continue during the pendency of this action. Furthermore, if plaintiff fails to timely comply with this demand, motion will be made to either dismiss this action or to preclude plaintiff from offering at the time of trial of this action any evidence pertaining to, or contained in the items demanded. PLEASE TAKE FURTHER NOTICE that, upon your failure to produce the aforesaid documents, at the time and place required in this notice, defendants will oppose any attempts to 1 of 3(FILED: SUFFOLK COUNTY CLERK 0672272021 09:46 AM INDEX NO. 606238/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/22/2021 place this case on the trial calendar of this court and/or appropriate motions for relief will be made to this court. PLEASE TAKE FURTHER NOTICE that, in lieu of producing the items demanded herein, you may serve and submit to the undersigned true and conformed copies of the items demanded herein at any time prior to the aforesaid date. Dated: Elmsford, New Y ork June 18, 2021 Y ours, etc., Kenneth A. Finder PILLINGER MILLER TARALLO, LLP KENNETH A. FINDER Attorneys for Defendants Emily A. Damato and Anthony S. Damato 555 Taxter Road, 5th Floor, Elmsford, NY 10523 Office No: (914) 703-6300 PMT File No. GIC-01948/KAF TO: WINKLER KURTZ, LLP Attorney for Plaintiff Constance Mansfield 1201 Route 112, Suite 200 Port Jefferson, NY 11776 Phone: (631) 928-8000 File No: 2 of 3(FILED: SUFFOLK COUNTY CLERK 0672272021 09:46 AM INDEX NO. 606238/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/22/2021 INDEX NO. 606238/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Xx CONSTANCE MANSFIELD, PLAINTIFF, -AGAINST- EMILY A. DAMATO AND ANTHONY S. DAMATO, DEFENDANTS. -X DEMAND FOR SOCIAL SECURITY EARNINGS INFORMATION PILLINGER MILLER TARALLO, LLP Attorneys for Defendants Emily A. Damato and Anthony S. Damato 555 Taxter Road, 5th Floor, Elmsford, NY 10523 (914) 703-6300 GIC-01948/KAF CERTIFICATION PURSUANT TO 22 NY.C.R.R. § 130-1. Ja Kenneth A. Finder hereby certifies that, pursuant to 22 N.Y.C.R.R. § 130-1.1a, the foregoing DISCLOSURE DEMAND is/are neither frivolous nor frivolously presented. Kennetiva. Finder Dated: Elmsford, New Y ork June 18, 2021 KENNETH A. FINDER PLEASE TAKE NOTICE that the within is a true copy of a entered in the office of the clerk of the within named Court on that a of which the within is a true copy will be presented for settlement to the Hon. one of the judges of the within named Court at , onat 9:30 am. PALLINGER MILLER TARALLO, LLP Attorneys for Defendants Emily A. Damato and Anthony S. Damato 555 Taxter Road, 5th Floor, Elmsford, NY 10523 (914) 703-6300 PMT File No. GIC-01948/KAF KAF/mh 3 of 3