Exhibit,Appendix: Rolando Caceres-Caballero v. Pv Holding Corp., John Doe #1 FICTITIOUS NAME AS TRUE IDENTITY IS PRESENTLY UNKNOWN BEING THE OPERATOR OF MOTOR VEHICLE BEARING LICENSE PLATE #N46JYL, John Doe #2 FICTITIOUS NAME AS TRUE IDENTITY IS PRESENTLY UNKNOWN BEING THE OPERATOR OF MOTOR VEHICLE BEARING LICENSE PLACE #HYZ5750

On December 24, 2020 a Exhibit,Appendix was filed involving a dispute between Rolando Caceres-Caballero, and John Doe #1 Fictitious Name As True Identity Is Presently Unknown Being The Operator Of Motor Vehicle Bearing License Plate #N46Jyl, John Doe #2 Fictitious Name As True Identity Is Presently Unknown Being The Operator Of Motor Vehicle Bearing License Place #Hyz5750, Pv Holding Corp., for Torts - Motor Vehicle in the District Court of Kings County.

Preview
(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

Exhibit “B”(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

ROLANDO CACERES-CABALLERO, VERIFIED ANSWER

Plaintiff, Index No. 525881/2020
-against-

PV HOLDING CORP., "JOHN DOE #1" FICTITIOUS

NAME AS TRUE IDENTITY IS PRESENTLY UNKNOWN

BEING THE OPERATOR OF MOTOR VEHICLE BEARING

LICENSE PLATE #N46JYL AND "JOHN DOE #2"

FICTITIOUS NAME AS TRUE IDENTITY IS PRESENTLY

UNKNOWN BEING THE OPERATOR OF MOTOR

VEHICLE BEARING LICENSE PLATE #HY Z5750,

Defendants.

Defendant, PV HOLDING CORP., appearing by the undersigned attorneys, PILLINGER
MILLER TARALLO, LLP, answering the complaint of the Plaintiff, ROLANDO CACERES-
CABALLERO, hereby alleges upon information and belief, as follows:

ANSWERING THE FIRST CAUSE OF ACTION

1. Denies any knowledge or information sufficient to form a belief thereof as to each
and every allegation contained in the paragraphs of plaintiffs Complaint marked and designated
as “1”, “10”, “11”, “12”, “19”, “20”, “21”, “22”, “23”, “24”, “26”, “28”, “31”, “37”, “38” and
“40”.

2. Denies each and every allegation contained in the paragraph of plaintiffs
Complaint marked and designated as paragraph “4”, except admits that on and before June 15,
2020, and at all times herein mentioned, defendant, PY HOLDING CORP., held title to a 2018
Mercedes Benz motor vehicle bearing New Jersey State Registration number N46JY L.

3. Denies each and every allegation contained in the paragraph of plaintiff's

Complaint marked and designated as paragraph “8”, except admits that on June 15, 2020 and

-1-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

at all times herein mentioned, defendant, “JOHN DOE #1” operated the aforesaid motor vehicle
bearing New Jersey Registration number N46JY L pursuant to the terms and conditions of a
rental agreement.

4, Denies each and every allegation contained in the paragraph of plaintiffs
Complaint marked and designated as paragraph “9”, except admits that on and before June 15,
2020, the aforementioned vehicle bearing New Jersey Registration number N46JY L was leased
from an affiliate of defendant, PY HOLDING CORP.

5. Denies each and every allegation contained in the paragraph of plaintiff's
Complaint marked and designated as paragraph “13”, except admits that on and before June
15, 2020 and at all times herein mentioned, defendant, PV HOLDING CORP., held title to a
2018 Mercedes Benz motor vehicle bearing New Y ork State Registration number HY Z5750.

6. Denies each and every allegation contained in the paragraph of plaintiffs
Complaint marked and designated as paragraph “17”, except admits that on June 15, 2020 and
at all times herein mentioned, defendant “JOHN DOE #2” operated the aforesaid motor vehicle
bearing New Y ork State Registration number HY Z5750 pursuant to the terms and conditions of
a rental agreement.

7. Denies each and every allegation contained in the paragraph of plaintiff's
Complaint marked and designated as paragraph “18”, except admits that on and before June
15, 2020 defendant, “JOHN DOE #2” leased the aforementioned vehicle bearing New York
Registration number HY Z25750 from an affiliate of defendant, PV HOLDING CORP.

8. Denies each and every allegation contained in the paragraph of plaintiffs
Complaint marked and designated as paragraph “25”, except admits that on June 15, 2020,
defendant, “JOHN DOE #2” was operating the aforesaid vehicle bearing New York

Registration number HY Z5750.(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

9. Denies each and every allegation contained in the paragraphs of plaintiffs
Complaint marked and designated as “5”, “6”, “7”, “14”, “15” and “16”.

10. Denies each and every allegation contained in the paragraphs of plaintiff's
Complaint marked and designated as “27”, “29”, “30”, “32”, “33”, “34”, “35”, “36”, “39” and
“41”, and respectfully refers all questions of law, fact and/or conclusions raised therein to the
Trial Court for determination and interpretation of the correct, true and full contents and import
thereof.

ANSWERING THE SECOND CAUSE OF ACTION

11 = Answering paragraph numbered "42" of the plaintiff's Complaint herein,
defendant, PV HOLDING CORP., repeats, reiterates and realleges each and every denial and
denial of knowledge or information sufficient to form a belief heretofore made in regard to each
and every paragraph of plaintiffs' Complaint, designated as paragraphs "1" through "41"
inclusive, with the same force and effect as though more fully set forth at length herein.

12. Denies each and every allegation contained in the paragraphs of plaintiff's
Complaint marked and designated as “43” and “44”, and respectfully refers all questions of law,
fact and/or conclusions raised therein to the Trial Court for determination and interpretation of
the correct, true and full contents and import thereof .

AS AND FOR A FIRST AFFIRMATIVE DEFENSE

The plaintiff's sole and exclusive remedy is confined and limited to the benefits and
provisions of Article 51 of the Insurance Law of the State of New Y ork.
AS AND FOR A SECOND AFFIRMATIVE DEFENSE
The plaintiff did not sustain a serious injury as defined by Section 5102 of the Insurance
Law of the State of New Y ork, and their exclusive remedy therefore is confined and limited to

the benefits and provisions of Article 51 of the Insurance law of the State of New Y ork.
-3-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

AS AND FOR A THIRD AFFIRMATIVE DEFENSE

The plaintiff's cause of action is barred by Article 51, Section 5104 of the Insurance Law

of the State of New Y ork.
AS AND FOR A FOURTH AFFIRMATIVE DEFENSE

That the plaintiff did not use the available safety devices, including seat belts and
harnesses therein provided, and breached a duty of due care, and that the damages claimed to
have been sustained were caused by the lack of use of the safety devices, including seat belts and
harnesses, in that they did not avail themselves of the safety devices to mitigate the injuries, if
any, herein; and further failed to comply with Section 1229-c of the Vehicle and Traffic Law of
the State of New Y ork.

AS AND FOR A FIFTH AFFIRMATIVE DEFENSE

That the Plaintiff, by not using the available safety devices, including seat belts and
harnesses, acted unreasonably and in disregard of their own best interest and, accordingly, should
not be permitted to recover damages for those injuries that they sustained, which the use of
available safety devices would have obviated; in violation of Section 1229-c of the Vehicle and
Traffic Law of the State of New Y ork.

AS AND FOR A SIXTH AFFIRMATIVE DEFENSE

[hat whatever injuries and/or damages sustained by the Plaintiff, at the time and place
alleged in the Complaint, were in whole or in part the result of the culpable conduct of the
plaintiff.

AS AND FOR A SEVENTH AFFIRMATIVE DEFENSE

Upon information and belief, any past or future costs or expenses incurred or to be
incurred by the plaintiff for medical care, dental care, custodial care or rehabilitative services,

loss of earnings or other economic loss, has been or will with reasonable certainty be replaced or

-4-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

indemnified in whole or in part from a collateral source as defined in Section 4545(c) of the New
Y ork Civil Practice Law and Rules.

If any damages are recoverable against this said answering defendant, the amount of such
damages shall be diminished by the amount of the funds which plaintiff have or shall receive
from such collateral source.

AS AND FOR AN EIGHTH AFFIRMATIVE DEFENSE

That whatever injuries and/or damages sustained by the plaintiff at the time and place
alleged in the Complaint were the result of the plaintiffs assumption of risk in realizing and
knowing the hazards thereof and they assumed all risks necessarily incident to such an
undertaking.

AS AND FOR A NINTH AFFIRMATIVE DEFENSE

laintiff has failed to commence this action in accordance with the directives of Article 3
of the C.P.L.R.

AS AND FOR A TENTH AFFIRMATIVE DEFENSE

laintiff failed to mitigate damages.

AS AND FOR AN ELEVENTH AFFIRMATIVE DEFENSE

laintiff fails to state a cause of action with respect to the causes of action in said
Complaint.

AS AND FOR A TWELFTH AFFIRMATIVE DEFENSE

That pursuant to General Obligations Law §15-108 in the event of a settlement of this
matter by one of the alleged tortfeasors, any verdict thereafter rendered in favor of plaintiff
against another defendant, shall be reduced either by the dollars and cents amount of the
settlement or by the assessed percentage of culpability of the settling tortfeasor as determined by

the jury, whichever is greater.(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

AS AND FOR A THIRTEENTH AFFIRMATIVE DEFENSE

That the answering defendant was faced with a sudden and unexpected circumstance
which left little or no time for thought, deliberation or consideration and/or caused the defendant
to be reasonably so disturbed that defendant had to make a speedy decision without weighing
alternative courses of conduct, and as such the defendant was not negligent as to the actions
taken were reasonable and prudent in the emergency context.

AS AND FOR A FOURTEENTH AFFIRMATIVE DEFENSE

Defendant, PV HOLDING CORP. is a company that is engaged in the trade or business
of renting or leasing vehicles, including, but not limited to the vehicle alleged in the complaint
herein. The aforesaid defendant has no active negligence or criminal wrongdoing related to the
alleged accident in which personal injuries are claimed to have been sustained by the plaintiff
herein. As such, under Federal legislation, specifically, 49 United States Code Chapter 301,
Subdivision 1, Section 30106 entitled "Rented or Leased Motor Vehicle Safety and
Responsibility", the defendant is not liable under the laws of the State of New Y ork for the
injuries alleged in the complaint that may have resulted or arisen out of the use, operation or
possession of the vehicle stated in the complaint. The plaintiff's complaint therefore fails to state
a cause of action as against defendant for which dismissal will be sought together with cost,

expenses and attorney fees.

‘WHEREFORE, defendant, PV HOLDING CORP., demands judgment dismissing the
Complaint of the plaintiff, together with the costs and disbursements of this action.

Dated: Elmsford, New Y ork
February 23, 2021(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

Y ours, etc.,

PILLINGER MILLER TARALLO, LLP

By: Dawid S. duonewitz
Attorneys for Defendant
PV HOLDING CORP.
555 Taxter Road, 5th Floor
Elmsford, NY 10523
(914) 703-6300
PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attomney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

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ROLANDO CACERES-CABALLERO, DEMAND FOR A BILL
OF PARTICULARS
Plaintiff,
Index No. 525881/2020
-against-

PV HOLDING CORP., "JOHN DOE #1" FICTITIOUS
NAME AS TRUE IDENTITY IS PRESENTLY UNKNOWN
BEING THE OPERATOR OF MOTOR VEHICLE BEARING
LICENSE PLATE #N46J)YL AND "JOHN DOE #2"
FICTITIOUS NAME AS TRUE IDENTITY IS PRESENTLY
UNKNOWN BEING THE OPERATOR OF MOTOR
VEHICLE BEARING LICENSE PLATE #HY Z5750,

Defendants.

SIRS:

PLEASE TAKE NOTICE, that you are hereby required to file and serve the following
verified particulars of plaintiff's alleged cause of action herein, within twenty (20) days from the
date of service hereof:

1. State the date, and approximate time of day of the occurrence.
2. State the exact location of the occurrence in sufficient detail, including:
a the direction in which defendant's vehicle was proceeding; and
b. on which street, which side thereof, and in which direction it is claimed

the plaintiff's vehicle was proceeding at the time of the alleged contact.

3. Set forth a statement of the acts, or omissions constituting the negligence
claimed of the undersigned defendant.

4. State the Title, including Chapter, and Section, of each and every Statute,
Ordinance, Regulation, and Rule claimed to have been violated by defendant.

5. State which part of the respective vehicles came into contact with one another.

6. If it is claimed that the motor vehicle referred to in the complaint was
defective;(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

Identify the part, or parts of the vehicle claimed to be defective;

Specify the exact nature of each such defect claimed; and

c. State whether it will be claimed that the answering defendants had actual,
or constructive notice thereof.

7. If actual notice of any defective or dangerous condition is claimed, give the
date, time, place, manner, by whom and to whom such notice was given, and state
whether said notice was in writing, or oral, and specify the substance of such notice.

8. If constructive notice of any defect or dangerous condition is claimed, state
the nature of the condition, and the length of time the condition existed.

9. If it is claimed that negligent repairs were made, state when, where and by
whom on behalf of the answering defendant they were made, and in what respects
such repairs were negligently performed.

10. State whether the motor vehicle referred to in the complaint was repaired,
altered, modified or adjusted in any way while in the plaintiff's possession prior to
the accident. If so, give the date, place, and nature of such repairs, alterations,
modifications, or adjustments.

11. If it is claimed that the answering defendant caused, or created the condition,
state the name of the persons who caused, or created it, and the date when said
condition was caused, or created.

12. Give a general description of the manner in which plaintiff's claim the
accident occurred.

13. Describe in detail the nature, extent, location, and duration of each and every
injury alleged to have been sustained by the plaintiff, and which, if any, are claimed
to be permanent.

14. State, in an action designated in subdivision (a) of Section 5104 of the
Insurance Law, for personal injuries arising out of negligence in the use or operation
of a motor vehicle in this state, in what respect plaintiff has sustained a serious injury,
as defined in subdivision (d) of Section 5102 of the Insurance Law, or economic loss
greater than basic economic loss, as defined in subdivision (a) of Section 5102 of the
Insurance Law.

15. State the length of time, giving specific dates, plaintiff was confined,
following the alleged incident, to:

a hospital;
b. bed; and
c. home.(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

16. State the length of time, giving specific dates, plaintiff was incapacitated from
employment, attendance at school, and/or household duties as a result of the alleged
injuries.

17. State the total amounts claimed as special damages, including names and
addresses for:

physicians' services;

medical supplies;

nurses' services;

hospital expenses;

x-ray expenses;

loss of earnings; and

any other items of special damages.

Aamoeorp

18. State:

Plaintiff's occupation;

name, and address of plaintiff's employer at the time of the alleged
occurrence;

average daily, weekly or monthly earnings; and

if plaintiff was a student, the name, and address of plaintiff's school at the
time of the occurrence.

19. State the date of birth, and Social Security Number of each plaintiff.

20. State the full legal name, and address of the plaintiff at the:

a time of the occurrence; and
b. present time.

21. State whether plaintiff has made application for No-Fault benefits; and if so,
set forth the name, and address of the company to which application was made, the
policy number under which the benefits were paid, and the file number assigned to
the application by the company.

22. Is the plaintiff a Medicare recipient or do plaintiff expect to become one
within the next (30) months.

a. __If plaintiff is a Medicare recipient, set forth the HICN/Medicare claim

number;

b. Has the subject occurrence and alleged injuries been report to Medicare;

i) Set forth the date it was reported;

c. If the matter has been reported to Medicare, has plaintiff received a
response letter from Medicare.

23. Is plaintiff suffering from end stage renal failure or Lou Gehrig’s
disease.

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NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

24. If loss of services is being claimed, set forth the particulars of such a claim
in detail, including the exact nature and extent of those services lost and the length of
time and the dates thereof.

25. If property damages are being claimed, set forth:

Itemized statement of each and every item damaged;

Cost of repair and/or replacement;

Disposition of damaged property;

Make, model, year of manufacture of plaintiffs vehicle and the

reasonable marked value of same immediately prior to and

immediately after the alleged occurrence;

e. Manner in which plaintiff arrived at damage for each and every item;
and

f. Manner in which plaintiff mitigated their damages, including the

amount, if any, recovered in salvage and the name and address of

salvagor and the gross and net recovery.

Boop

26. With respect to the claim of negligent entrustment, set forth each and every act or
omission on behalf of defendant, PV HOLDING CORP. which constitutes
negligent entrustment.

27. Set forth the manner in which plaintiff will claim that the driver of the PV
HOLDING CORP. vehicle was incompetent to operate the vehicle.

28. Set forth what special knowledge defendant had conceming a characteristic or
condition pertaining to the operator of the vehicle which rendered his use of the
vehicle unreasonably dangerous.

PLEASE TAKE FURTHER NOTICE, that in the event that the plaintiff has no

knowledge of any of the above matters, the plaintiff shall so state.

PLEASE TAKE FURTHER NOTICE, that in the event of your failure to furnish such a
Verified Bill of Particulars within the said period of twenty (20) days, a Motion will be made for an
Order precluding the plaintiff from giving any evidence of the trial of the above items, of which
particulars have not been delivered in accordance with the demand.

Dated: Elmsford, New Y ork
February 23, 2021

-11-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

Y ours, etc.,

PILLINGER MILLER TARALLO, LLP

By: Dawid S. Auonewitz
Attorneys for Defendant
PV HOLDING CORP.
555 Taxter Road, 5th Floor
Elmsford, NY 10523
(914) 703-6300
PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attomney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-12-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10

RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS

ROLANDO CACERES-CABALLERO,

Plaintiff,

-against-

PV HOLDING CORP. and PV HOLDING CORP.,

Defendants.

DEMAND TO PRODUCE
PROPERTY DAMAGE
INFORMATION

Index No. 707085/2020

PLEASE TAKE NOTICE, that pursuant to CPLR §3101, et seq., the undersigned

demands that if property damage is alleged, you are required to produce, within twenty (20) days,

true, accurate and complete copies of the following:

PLEASE TAKE FURTHER NOTICE, thai

Repair estimates for plaintiff's motor vel

damaged;

Purchase invoices, contracts of sale, an
to replace the damaged vehicle;

Duly executed authorization to obtain

icle;

Purchase invoices, contracts of sale, and bill of sale for the motor vehicle allegedly

bill of sale for any motor vehicle purchased

Photographs of the damaged motor vehicle; and

he records of any liability insurance carrier

with respect to any claim for property damage to plaintiff's vehicle.

your failure to comply with the foregoing

demands will serve as the basis of a motion seeking, in whole or part, an order precluding each

plaintiff from introducing into evidence and for otherwise using the above demanded items for

any purpose whatsoever upon the trial of this action.

-13-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

PLEASE TAKE FURTHER NOTICE, that the above demand is a continuing demand
and all responsive information that is made known or becomes available after service of the
above demand shall be furnished to the undersigned attorneys in a timely fashion.

Dated: Elmsford, New Y ork
February 23, 2021
Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: Dawid S. duonewitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attomey for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-14-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

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ROLANDO CACERES-CABALLERO, DEMAND PURSUANT TO
CPLR §3101@)
Plaintiff,
Index No. 525881/2020
-against-

Defendants.

PLEASE TAKE NOTICE, that the answering defendant, PV HOLDING CORP., by the
undersigned attomeys, PILLINGER MILLER TARALLO, LLP, hereby demands, pursuant to
CPLR §3101(d), that each plaintiff provide to said attomeys at 555 Taxter Road, 5h Floor,
Elmsford, New Y ork 10523, within thirty (30) days of the date of service hereof, the following:

1. The name(s) and address(es) of each person that each plaintiff expect to call to give
expert testimony at the trial of this action;

2. Disclose, in reasonable detail, of the qualifications, including, but not limited to,
educational background and degrees, publications, memberships in professional organizations and
societies, certifications and licenses, and employment history, of each person that each plaintiff
expect to call to give expert testimony at the trial of this action;

3. For each person that each plaintiff expect to call to give expert testimony at the trial
of this action, disclose, in reasonable detail, of the facts upon which the expert will rely in
formulating his opinions and conclusions, and, the source or sources of the expert's knowledge
concerning such facts, including, but not limited to, where applicable, the statistics, studies, surveys,
reports, test results, analyses and all other source material relied upon by the experts;

-15-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

4. For each person that each plaintiff expect to call to give expert testimony at the trial
of this action, disclose, in reasonable detail, the subject matter of the testimony, including, but not
limited to, the opinions to which the expert is expected to testify, the conclusions to which the
expert is expected to testify, and the grounds for the opinions and conclusions to which the expert is
expected to testify;

5. With respect to physicians or other medical providers, for each person that each
plaintiff expect to call to give expert testimony at the trial of this action, disclose, in reasonable
detail of (in addition to all of the above) the following:

a Whether the expert is licensed in this state;

b. | Whether the expert is licensed to practice medicine in any other state;

c. Whether the expert is certified in a specialty in this state or any other state
and if so, set forth the specialty(ies);

d. Whether the expert has authored any medical book(s), treatise(s), article(s),
publications(s) and/or written material(s) in the field of his/her expertise and
if so, set forth the name and date of said book(s), treatise(s), article(s),
publications(s), and/or written material(s);

e A description of every medical, dental and/or hospital record, report, note
and/or chart upon which the expert will rely; and

f. A list of the name(s) and date(s) of all books, treatises, articles, publications
and/or written materials upon which the expert will rely.

PLEASE TAKE FURTHER NOTICE, that in the event no such expert(s) is/are expected

to be called as (an) expert witness(es) at the trial of this action, then a sworn statement to that effect
is hereby demanded to be produced.

PLEASE TAKE FURTHER NOTICE, that the above demands are continuing demands
and all responsive information that is made known or becomes available after service of the above
demands shall be furnished to the undersigned attomeys in a timely fashion.

PLEASE TAKE FURTHER NOTICE that your failure to comply with the foregoing
demands will serve as the basis of a motion seeking, in whole or part, an order precluding each
plaintiff from introducing into evidence and for otherwise using the above demanded items for
any purpose whatsoever upon the trial of this action.

PLEASE TAKE FURTHER NOTICE, that defendant, will move at the time of trial or

prior thereto for an Order precluding the giving of testimony by an expert for whom full and

-16-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

complete information had not been furnished in compliance with the above demands. Further, the
failure to fully comply with the above demands in a timely fashion may also be grounds for an
Order striking the complaint, dismissing the action and/or such other relief as the Court deems just
under the circumstances.

Dated: Elmsford, New Y ork
February 23, 2021
Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: Dawid S. Auonewitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attorney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-17-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

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ROLANDO CACERES-CABALLERO, DEMAND PURSUANT TO
CPLR §4545
Plaintiff,
Index No. 525881/2020
-against-

Defendants.

PLEASE TAKE NOTICE, that demand is hereby made upon the attomeys for the
plaintiff that they serve upon the undersigned, a statement as to whether any part of the cost of
medical care, custodial care, rehabilitation services, loss of earnings or other economic loss
sought to be recovered herein was replaced or indemnified, in whole or in part, from any
collateral sources, including but not limited to insurance, Social Security (except those benefits

provided under Title 18 of the Social Security Act), Workers’ Compensation, or employee

benefit programs, and if so, the full name and address of each organization or program providing

such replacement or indemnification together with an itemized statement of the amount in which

each such claimed item of economic loss was replaced or indemnified by each such organization

of program.

- 18 -(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

Demand is additionally made for duly executed and properly addressed original
authorizations permitting the undersigned to inspect and copy any records reflecting any
collateral source or payment identified in response to the foregoing demand.

PLEASE TAKE FURTHER NOTICE, that your failure to comply with the foregoing
demand within twenty (20) days will serve as the basis for a Motion for appropriate relief
pursuant to the C.P.L.R.

Dated: Elmsford, New Y ork
February 23, 2021
Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: Dawid S. Auonewitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attorney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-19-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

wee e teen cen een ene een een nee eee nee nee ee nnn ee coneeeeneeee X
ROLANDO CACERES-CABALLERO, DEMAND FOR
ACCIDENT REPORTS
Plaintiff,
Index No. 525881/2020
-against-

Defendants.

PLEASE TAKE NOTICE, that the answering defendant, PV HOLDING CORP., by the
undersigned attorneys, PILLINGER MILLER TARALLO, LLP, hereby demands, pursuant to
CPLR §3101(g), that each plaintiff provide to said attorneys at 555 Taxter Road, 5" Floor,
Elmsford, New York 10523, within twenty (20) days after the date of service hereof, the

following:

1. True and accurate copies of any written report(s) of the occurrence alleged in the
complaint prepared in the regular course of business operations or practices of any person, firm,

corporation, association or other public or private entity.

PLEASE TAKE FURTHER NOTICE, that your failure to comply with the foregoing

demands will serve as the basis of a Motion seeking, in whole or part, an order precluding each

-20-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

plaintiff from introducing into evidence and for otherwise using the above demanded items for

any purpose whatsoever upon the trial of this action.

Dated: Elmsford, New Y ork
February 23, 2021
Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: Dawid S. Auonewitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attorney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-21-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

we ceeeen ence cee ee nee nee eee cee eeneeneeeee eee eeneneneeeeeeeeeneneeneeeees X
ROLANDO CACERES-CABALLERO, DEMAND FOR MEDICAL
INFORMATION,
Plaintiff, REPORTS AND
AUTHORIZATIONS

-against-
Index No. 525881/2020

PV HOLDING CORP., "JOHN DOE #1" FICTITIOUS
NAME AS TRUE IDENTITY IS PRESENTLY UNKNOWN
BEING THE OPERATOR OF MOTOR VEHICLE BEARING
LICENSE PLATE #N46JYL AND "JOHN DOE #2"
FICTITIOUS NAME AS TRUE IDENTITY IS PRESENTLY
UNKNOWN BEING THE OPERATOR OF MOTOR
VEHICLE BEARING LICENSE PLATE #HY Z5750,

Defendants.

SIRS:

PLEASE TAKE NOTICE, that the answering defendant, PY HOLDING CORP., by the
undersigned attomeys, PILLINGER MILLER TARALLO LLP, hereby demands, pursuant to
Article 31 of the CPLR and the Uniform Rules of the Court, that each plaintiff provide to said
attomeys at 555 Taxter Road, 5h E loor, Elmsford, New Y ork 10523, within (30) days from the date

of service hereof, the following:

1. The name(s) and address(es) of all physicians or other health-care providers of every
description who have consulted, examined or treated each plaintiff for each of the conditions
llegedly caused by, or exacerbated by, the occurrence described in the complaint, including the
late(s) of such consultation(s), examination(s) or treatment(s);

2. Duly executed and acknowledged written authorizations directed to any hospital,
clinic or health care facility, including, but not limited to, Emergency Medical Service (EMS) or
any ambulance service, in which each injured plaintiff herein was or continues to be treated or
confined due to the occurrence set forth in the complaint so as to permit the securing of a copy of
the entire hospital record or records including x-rays and technicians' reports;

-22-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

3. Duly executed and acknowledged written authorizations to allow answering
defendant to obtain the complete office medical records, relating to each plaintiff, of each physician
or health care provider identified in response to "1" above;

4. Copies of all medical reports, records, narrative records and statements received
form physicians or health care providers identified in response to "1" above. These shall include a
detailed recital of the injuries and conditions as to which testimony will be offered at the trial of this
action, referring to and identifying those x-rays and technicians’ reports which will be offered at the
trial of this action;
5. Duly executed and acknowledged written authorizations to allow answering
defendant to obtain complete pharmacy and/or surgical supply records with respect to any drugs,
surgical supplies and/or prostheses prescribed for each plaintiff from one (1) year prior to the
occurrence described in the complaint to the present date;

6. Within the time period of the date of the occurrence to the present, true and accurate
copies of all bills, invoices and statements for medical treatment of every description, or any bills,
invoices and statements incidental to medical treatment of every description, including, but not
limited to, bills, invoices and statements for drugs, medication or pharmaceuticals of every
description, relating to the injuries (to each plaintiff) allegedly caused or exacerbated by the
occurrence described in the complaint;

7. Duly executed and acknowledged written authorizations directed to any hospital,
clinic or health care facility, including, but not limited to, Emergency Medical Service (EMS) or
any ambulance service, in which each injured plaintiff herein was treated, examined and/or confine
prior to the date of the occurrence alleged in the complaint with relation to any physical or mental
condition of each plaintiff that was allegedly exacerbated and/or aggravated by the occurrence
alleged in the complaint;

8. Duly executed and acknowledged written authorizations to allow answering
defendant to obtain the complete office medical records, relating to each plaintiff, of each physician
or health care provider identified in response to "7" above;

9. Copies of all medical reports, records, narrative records and statements receiver
from physicians or health care providers identified in response to "7" above. These shall include a
detailed recital of the injuries and conditions as to which testimony will be offered at the trial of this
action, referring to and identifying those x-rays and technicians’ reports which will be offered at the
trial of this action;

10. In the case of death, duly executed and acknowledged written authorizations to
allow answering defendants to obtain the complete Medical Examiner's records and reports,
including the autopsy report, with respect to the decedent.

-23-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

PLEASE TAKE FURTHER NOTICE, that upon your failure to comply with the above
demands, answering defendant will move this Court, at or before the trial of this action, to preclude
each plaintiff from: offering any evidence of the conditions described in the reports or records
demanded; offering in evidence any part of the hospital records, medical reports and records, x-ray
reports or reports of other technicians not made available pursuant to applicable rules; and offering

any testimony of any physicians whose medical reports have not been served pursuant to the above

demands.

PLEASE TAKE FURTHER NOTICE, that the above demands are continuing demands
and all responsive information that subsequently is made known or becomes available shall be
furnished to the undersigned in a timely fashion.

Dated: Elmsford, New Y ork
February 23, 2021
Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: Dawid S. duonewitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attorney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-24-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

ween nnn nn nnn nn nnn nnn nn nn nn nnn nn nen nn enn nen eee en eee nee xX
ROLANDO CACERES-CABALLERO, DEMAND FOR NAMES
AND ADDRESSES OF
Plaintiff, ALL WITNESSES
-against- Index No. 525881/2020

Defendants.

SIRS

PLEASE TAKE NOTICE, that the answering defendant, PV HOLDING CORP., by the
undersigned attorneys, PILLINGER MILLER TARALLO LLP, hereby demands, pursuant to
CPLR §3101(a) and pertinent case law, that each plaintiff provide to said attorneys at 555 Taxter
Road, 5" Floor, Elmsford, New Y ork 10523, in writing and under oath, within thirty (30) days of
the service of this demand, the names(s) and address(es) of each person known and/or claimed
by each plaintiff to be a witness to any of the following:

1. The occurrence alleged in the complaint;

2. Any acts, omissions or conditions which allegedly caused the occurrence alleged in
the complaint;

3. Any actual notice allegedly given to defendant or their agents, servants or
employees, of any condition(s) which allegedly caused the occurrence alleged in the complaint;

4. The nature and duration of any alleged condition which allegedly caused the
occurrence alleged in the complaint;

-25-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

5. Any repairs, at any time, made to the alleged location/condition which allegedly
caused the occurrence alleged in the complaint;

6. The alleged injuries, losses and/or damages; and
7. Any admissions or statements made by defendant.
PLEASE TAKE FURTHER NOTICE, that if no such witness(es) is/are known or
claimed to/by the party/parties you represent, so state in a swom reply to the above demands.
PLEASE TAKE FURTHER NOTICE, that the undersigned will object upon trial of this
action to the testimony of any witness(es) not identified in response to the above demands.
PLEASE TAKE FURTHER NOTICE that the above demands are continuing demands,
and all responsive information that subsequently is made known or becomes available shall be
furnished to the undersigned in a timely fashion.

Dated: Elmsford, New Y ork
February 23, 2021
Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: Dawid S. duonewitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attorney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-26-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

weet eee ee een een een ee nee ne eee nee ene ee anne enneeenneeeeee X
ROLANDO CACERES-CABALLERO, DEMAND FOR NO-
FAULT INFORMATION
Plaintiff,
Index No. 525881/2020
-against-

Defendants.

SIRS

PLEASE TAKE NOTICE, that demand is hereby made upon the attomeys for the
plaintiff that they serve upon the undersigned an authorization permitting the office of the
undersigned to obtain plaintiff's application for records and reports and physical examination

reports relating to plaintiff's claim for and receipt of No-Fault benefits.

address of each organization or insurance company providing such benefits, the policy number of

the vehicle under which such benefits were provided, and the claim or file number assigned to

plaintiff's claim for No-Fault benefits.

-27-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

PLEASE TAKE FURTHER NOTICE, that your failure to comply with the foregoing
demand within twenty (20) days will serve as the basis for a Motion for appropriate relief
pursuant to the C.P.L.R.

Dated: Elmsford, New Y ork
February 23, 2021
Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: Dawid S. duonewitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attorney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

- 28 -(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

ween nnn nn nnn nn nnn nnn nn nn nn nnn enn nnn nn nen nen eee eee xX
ROLANDO CACERES-CABALLERO, DEMAND TO PRODUCE
PHOTOGRAPHS
Plaintiff,
Index No. 525881/2020
-against-

Defendants.

SIRS:

PLEASE TAKE NOTICE, that pursuant to CPLR §3101 Et Seq., the undersigned
demands that plaintiff produce any and all photographs, if any, of the scene of the occurrence and/or
plaintiff's injuries and/or the instrumentalities involved in the occurrence and/or any real property
damaged as a result of the occurrence. If no such photographs are in the possession, custody or
control of any parties you represent in this action, so state in reply to this demand.

PLEASE TAKE FURTHER NOTICE, that your failure to comply with the foregoing
demands will serve as the basis of a motion seeking, in whole or part, an order precluding each
plaintiff from introducing into evidence and for otherwise using the above demanded items for

any purpose whatsoever upon the trial of this action.

-29-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

Dated: Elmsford, New Y ork
February 23, 2021
Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: Dawid S. duonewitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attorney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-30-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

weet eee ee een een een ee nee ne eee nee ene ee anne enneeenneeeeee X
ROLANDO CACERES-CABALLERO, DEMAND FOR POST
OFFICE ADDRESS
Plaintiff,
Index No. 525881/2020
-against-

Defendants.

SIRS:

PLEASE TAKE NOTICE, that pursuant to CPLR Article 31, the undersigned, being the
attomeys for the answering defendant in the above entitled action, hereby demands that you furnish a
verified statement setting forth plaintiffs post-office address and the place of his/her/their residence,
including therein the street number or other designations sufficient to permit ready location.

PLEASE TAKE FURTHER NOTICE, in the event of your failure to comply with this
demand within twenty (20) days after the service hereof, a motion will be made to enforce such demand.

Dated: Elmsford, New Y ork
February 23, 2021 Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: David S. Monawitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

-31-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

To:

THE YANKOWITZ LAW FIRM, P.C.
Attorney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-32-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

ween nnn nn nnn nnn nnn nnn nn ee nn nnn nn nn nn ne nen eee enn ee enn eee nee xX
ROLANDO CACERES-CABALLERO, DEMAND FOR SCHOOL
RECORDS AND
Plaintiff, AUTHORIZATIONS
-against- Index No. 525881/2020

Defendants.

PLEASE TAKE NOTICE, that the answering defendant, PV HOLDING CORP., by the
undersigned attorneys, PILLINGER MILLER TARALLO, LLP, hereby demands, pursuant to
CPLR §3101 and §3120, that each plaintiff provide to said attomeys at 555 Taxter Road, 5h
Floor, Elmsford, New York 10523, within thirty (30) days after the date of service hereof, the
following:

1. Duly executed and acknowledged written authorizations required to permit
defendant to obtain each plaintiff's complete school records, including, without limitation, grade
achievements, physical examinations, extracurricular activities information, gym/athletic records
and the complete student file for each plaintiff for each school attended from five (5) years prior

to the occurrence alleged in the complaint, the year of said occurrence and up to the present date.

-33-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

PLEASE TAKE FURTHER NOTICE, that failure to comply with the above demand
will serve as the basis for a motion, at the time of trial or prior thereto, for the appropriate relief
pursuant to the CPLR.

Dated: Elmsford, New Y ork
February 23, 2021
Y ours, etc.,

PILLINGER MILLER TARALLO, LLP
By: Dawid S. duonewitz

Attorneys for Defendant

PV HOLDING CORP.

555 Taxter Road, 5th Floor

Elmsford, NY 10523

(914) 703-6300

PMT File No. DA-AVIS-00316

To:

THE YANKOWITZ LAW FIRM, P.C.
Attorney for Plaintiff

ROLANDO CACERES-CABALLERO
175 East Shore Road

Great Neck, NY 11023

(516) 622-6200

-34-(FILED: KINGS COUNTY CLERK 0870472021 I1:18 AM INDEX NO. 525881/2020

NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 08/04/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

ween cen een een eee nen nee nee nee ee ene eneeenneeeneeee X
ROLANDO CACERES-CABALLERO, DEMAND PURSUANT TO
CPLR §2108
Plaintiff,
Index No. 525881/2020
-against-

PV HOLDING CORP., "JOHN DOE #1" FICTITIOUS
NAME AS TRUE IDENTITY IS PRESENTLY UNKNOWN
BEING THE OPERATOR OF MOTOR VEHIC

Case Info

Judge

Karen B Rothenberg Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

August 04, 2021

Case Filing Date

December 24, 2020

County

Parties

ARONOWITZ, DAVID S. Attorney for the Defendant
FRAIL, KIERAN FRANCIS Attorney for the Defendant
HYMAN, TODD Attorney for the Defendant
John Doe #1 FICTITIOUS NAME AS TRUE IDENTITY IS PRESENTLY UNKNOWN BEING THE OPERATOR OF MOTOR VEHICLE BEARING LICENSE PLATE #N46JYL Defendant
John Doe #2 FICTITIOUS NAME AS TRUE IDENTITY IS PRESENTLY UNKNOWN BEING THE OPERATOR OF MOTOR VEHICLE BEARING LICENSE PLACE #HYZ5750 Defendant
PV HOLDING CORP. Defendant
Rolando Caceres-caballero Plaintiff
WIDOM, STEVEN RUBIN Attorney for the Plaintiff
YANKOWITZ, JACK A Attorney for the Plaintiff
YANKOWITZ, SKYLAR KODY Attorney for the Plaintiff
ROBERT GLICK Attorneys for Defendants

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