On May 01, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Darryl Nowak,
and
Sea Wolf Marine Transportation, Llc,
Weeks Marine,Inc.,
Wittich Brothers Marine, Inc,
for Torts - Other (Slip and fall)
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 07/12/2020 05:19 PM INDEX NO. 154000/2018
NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 07/12/2020
3V
New Jersey 151 Bodman Place, Suite 200, Red Bank,
NJ 07701
BETANCOURT Telephone:732.530.4646Telefax: 732.530.9536
VAN HEMMEN
GRECO & New York 75 SouthBroadway
- 4th Floor, White NY 10601
Plains,
KENYON LLC Telephone:914.997.1100Telefax: 914.997.1101
March 15, 2020
Via Mail and Email
NAPOLI SHKOLNIK, PLLC
Attorneys for Plaintiff
11th
360 Lexington Ave,
New York, New York 10017
Attn: Joseph P. Napoli, Esq.
Re: Darryl Nowak v. Sea Wolf Marine Transportation, LLC., Wittich
Brothers Marine, Inc., and Weeks Marine Inc,.
Index No. 154000/2018
Dear Sirs,
Would you please supplement plaintiff's Response To Notice Of Discovery And
Inspection to address the following deficiencies:
Demand No.3
All bills, receipts, canceled checks or other documents evidencing items of damage
to plaintiff arising out of the allegations contained in plaintiff's Complaint.
Response:
To be provided if applicable.
Deficiency.
Plaintiff failed to produce the requested documents.
Demand No.15
The W-2 forms given or mailed to plaintiff from all employers for the period 2012
to present.
Response:
See response to Demand for Income Tax Returns
www.bvgklaw.com
FILED: NEW YORK COUNTY CLERK 07/12/2020 05:19 PM INDEX NO. 154000/2018
NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 07/12/2020
Deficiency.
Plaintiff failed to produce the requested documents.
Demand No.18
All documents submitted to plaintiff's union to obtain medical, vacation, pension,
and/or disability benefits provided or arranged for by the union and authorizations
directed to plaintiff's union for the release of same.
Response:
To be provided if applicable.
Deficiency.
Plaintiff failed to produce the requested documents.
Demand No.20
Authorizations permitting Betancourt, Van Hemmen, Greco & Kenyon LLC, or their
authorized representatives, to obtain copies of the records of:
Workers'
a. Compensation records from the Compensation Carrier and the
Compensation Board;
b. Employment records;
c. Health Insurance carrier (to obtain collateral source records); and
d. Union records.
(Defendant requires the full names and addresses of all above-named to expedite
procurement of these records.)
Response:
To be provided if applicable.
Deficiency.
Plaintiff failed to produce the requested documents.
Very truly yours,
BETANCOURT, VAN HEMMEN, GRECO & KENYON LLC
By: s/ Ronald Betancourt
RB/oa
Document Filed Date
July 12, 2020
Case Filing Date
May 01, 2018
Category
Torts - Other (Slip and fall)
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FILED: NEW YORK COUNTY CLERK 07/12/2020 05:19 PM INDEX NO. 154000/2018 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 07/12/2020 3V New Jersey 151 Bodman Place, Suite 200, Red Bank, NJ 07701 BETANCOURT Telephone:732.530.4646Telefax: 732.530.9536 VAN HEMMEN GRECO & New York 75 SouthBroadway - 4th Floor, White NY 10601 Plains, KENYON LLC Telephone:914.997.1100Telefax: 914.997.1101 March 15, 2020 Via Mail and Email NAPOLI SHKOLNIK, PLLC Attorneys for Plaintiff 11th 360 Lexington Ave, New York, New York 10017 Attn: Joseph P. Napoli, Esq. Re: Darryl Nowak v. Sea Wolf Marine Transportation, LLC., Wittich Brothers Marine, Inc., and Weeks Marine Inc,. Index No. 154000/2018 Dear Sirs, Would you please supplement plaintiff's Response To Notice Of Discovery And Inspection to address the following deficiencies: Demand No.3 All bills, receipts, canceled checks or other documents evidencing items of damage to plaintiff arising out of the allegations contained in plaintiff's Complaint. Response: To be provided if applicable. Deficiency. Plaintiff failed to produce the requested documents. Demand No.15 The W-2 forms given or mailed to plaintiff from all employers for the period 2012 to present. Response: See response to Demand for Income Tax Returns www.bvgklaw.com FILED: NEW YORK COUNTY CLERK 07/12/2020 05:19 PM INDEX NO. 154000/2018 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 07/12/2020 Deficiency. Plaintiff failed to produce the requested documents. Demand No.18 All documents submitted to plaintiff's union to obtain medical, vacation, pension, and/or disability benefits provided or arranged for by the union and authorizations directed to plaintiff's union for the release of same. Response: To be provided if applicable. Deficiency. Plaintiff failed to produce the requested documents. Demand No.20 Authorizations permitting Betancourt, Van Hemmen, Greco & Kenyon LLC, or their authorized representatives, to obtain copies of the records of: Workers' a. Compensation records from the Compensation Carrier and the Compensation Board; b. Employment records; c. Health Insurance carrier (to obtain collateral source records); and d. Union records. (Defendant requires the full names and addresses of all above-named to expedite procurement of these records.) Response: To be provided if applicable. Deficiency. Plaintiff failed to produce the requested documents. Very truly yours, BETANCOURT, VAN HEMMEN, GRECO & KENYON LLC By: s/ Ronald Betancourt RB/oa