Motion for Discovery in Nicole Sutton v. 413 Throop Ave Llc, Core Scaffold Systems Inc.| Trellis.Law

On November 18, 2020 a No Value was filed involving a dispute between Nicole Sutton, and 413 Throop Ave Llc, Core Scaffold Systems Inc., for Torts - Other (Personal Injury-Premises) in the District Court of Kings County.

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FILED: KINGS COUNTY CLERK 04/29/2021 12:01 PM INDEX NO. 522901/2020
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/29/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
__________-________________________________--___-----------------X

NICOLE Index No: 522901/2020
SUTTON,

COMBINED
DISCOVERY
DEMANDS
Plaintiff,

-against-

413 THROOP AVE LLC and

CORE SCAFFOLD SYSTEMS INC.,

Defendants.

PLEASE TAKE NOTICE, that the undersigned hereby makes the following

demands upon you.

Demand for the Names and Addresses of all Witnesses;

Demand for Expert Information;

Demand for Discovery and Inspection of any Statement of a Party Represented by the

Undersigned;

Demand for Insurance Policy;

Demand for Photographs;

Demand for Accident Reports;

Notice for Discovery and Inspection of the Accident Location;

Notice for Discovery and Inspection.

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DEMAND FOR THE NAMES AND ADDRESSES OF WITNESSES

PLEASE TAKE NOTICE, that the undersigned hereby demands, pursuant to

Article 31, that you set forth in writing and under oath, the following:

1. The names and addresses of allpersons known to have witnessed the

occurrence or to have first-hand knowledge of same, whether the identities

were obtained at the scene of the occurrence or thereafter obtained by the

party, by his attorneys or representatives.

2. The names and addresses of allpersons known to have knowledge, whether

obtained before or after the occurrence, of any condition which is claimed to

have caused or affected the occurrence (including any notice witnesses)

whether the identities were obtained at the scene of the occurrence or

thereafter obtained by the party, his attorneys or representatives. Zayas v.

(2nd
Morales, 360 N.Y.S.2d 279 Dept. 1974); Hoffman v. Ro-San Manor,

(131
425 N.Y.S.2d 619 Dept. 1980).

3. The names and addresses of every person Defendant(s) claims is a witness

to an admission made by Plaintiff and any other party.

4. The names and addresses of every person Defendant(s) claims is a witness

to any alleged culpable conduct of Plaintiff.

5. The names and addresses of any person with knowledge of the nature and

duration of the conditions that allegedly caused the occurrence alleged in the

complaint.

6. If no such persons are known, a response to that effect is demanded.

7. If any affirmative defense is alleged, state the names and addresses of any

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witnesses to the acts, notice or conditions substantiating the alleged affirmative defense.

DEMAND F_OR EXPERT INFORMATION

Pursuant to CPLR 3101(d):

1. (a) Please furnish the name, address and qualification of each expert

witness whom you expect to call at trial; state in reasonable detail the subject matter and

substance of the facts and opinions on which each expert is expected to testify; and set

forth a summary of the grounds for each such opinion.

(b) If no such witness is known to the Defendant(s), so state in the

sworn reply to this demand. The undersigned will object upon trial to the testimony of any

witnesses not so identified.

2. Disclose in reasonable detail the qualifications of each expert witness.

3. Disclose in reasonable detail the subject matter on which each expert is

expected to testify.

4. Disclose in reasonable detail the substance of the facts and opinions on

which each expert is expected to testify.

5. Disclose in reasonable detail a summary of the grounds for each expert's

opinion. Include:

(a) A description of every medical, dental and/or hospital record relied

upon.

(b) A listof alltextbooks, treatises and/or articles relied upon. Bryant v.

(40'
Bui, 265 A.D.2d 848 Dept. 1999).

6. All publications by Defendant(s)'s expert. Quinn v. St. Peter's, 2005 WL

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2094971 (Sup. 2005).

This is a continuing demand for information regarding experts retained by you for

trial. Failure to comply with this Notice in a timely manner shall be grounds for an Order

precluding you from offering the testimony at trialof any expert witness whose name and

expected testimony is not disclosed, striking the Answer and/or such other relief as the

Court deems just under the circumstances.

DEMAND FOR DISCOVERY AND INSPECTION OF ANY STATEMENT OF
OF A PARTY REPRESENTED BY THE UNDERSIGNED

PLEASE TAKE FURTHER NOTICE, that the undersigned demands upon behalf

of each party represented by him in this action, that pursuant to CPLR 3101(e), you

produce at the time and place herein specified, and permit the undersigned to discovery,

inspection and copying of each and every statement(s), abstracts, recordings and writings

made or taken by each such party and his, her, or its agents, servants and/or employees,

now in your possession, custody or control or in the possession, custody or control of any

party you represent in this action, if any such statement in any matter bears on the issues in

(1st
this action. Mingo v. MABSTOA, 756 N.Y.S.2d 13 Dept. 2003); Sigelakis v.

(2nd
Washington, 46 A.D.3d 800 Dept. 2007). If the statement was recorded, set forth a true

and complete copy of the statement. If the statement was orally made, provide the exact

substance of the statement, the name and address of the person to whom the statement was

made, the date and place the statement was made, and/or summaries and/or memoranda

referring to the statement.

If no such statement is in the possession, custody or control of any parties you

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represent in this action, so state in the sworn reply to this demand.

DEMAND FOR INSURANCE POLICY

PLEASE TAKE FURTHER NOTICE, that the undersigned demands, pursuant

(4th
to CPLR 3101(f) and Anderson v. House of Good Samaritan Hosp., 1 A.D.3d 970

Dept. 2003) that the Defendant(s) produce and permit Plaintiff to inspect and to copy the

following documents:

(a)The policies of insurance covering the basic liability,excess,

co-insurance and all other applicable liability, medical

payments, coverages as they apply to the underlying

accident and as specified in the Complaint.

DEMAND FOR PHOTOGRAPHS

PLEASE TAKE FURTHER NOTICE, that the undersigned demands pursuant to

CPLR 3120 and 3101:

(a) You are requested to produce, at the expense of the attorneys for the

Plaintiff, a duplicate of any and all pictures, movies, films, slides,

videotapes, visual reproductions, drawings, and/or descriptions of

the alleged scene of the accident, any conditions that allegedly

contributed to the occurrence of the accident and/or construction

and/or repair work prior to and including the date of the accident, in

the possession of the Defendant(s), their agents, servants, and/or

employees, or the attorneys representing said parties. Defendant(s)

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are also to produce any and allphotographs taken of the Plaintiff,

including any videotapes, photographs, movies, slides, and visual

reproductions of the Plaintiff, including out-takes, unused tapes,

notes and memoranda concerning the Plaintiff. Tai Tran v. New

Rochelle Hosp. Med. Ctr., 99 N.Y.2d 383 (2003)(Defendant must

produce surveillance tapes at the time of their creation, not after

Plaintiffs deposition). Beckford, 774 N.Y.S.2d 316 (Monroe

2004)(report of investigator). Also, provide the names and addresses

of the persons who obtained or created said materials, as well as the

date, time and place where said materials were allegedly obtained or

created. Dittmer v. Terzian, 787 N.Y.S.2d 617 (Rockland

2004)(videographer).

DEMAND FOR ACCIDENT REPORTS

PLEASE TAKE FURTHER NOTICE, that, pursuant to CPLR 3120 and 3101(g),

you are required to produce each and every accident/incident/investigation report prepared

in the usual course of business of the Defendant(s) referable to the incident complained of

(2nd
herein. Pataki v. Kiseda, 80 A.D.2d 100 Dept. 1981); MinRo v. MABSTOA, 756

(1st (13t
N.Y.S.2d 13 Dept. 2003); Recant v. Harwood, 222 A.D.2d 372 Dept. 1995);

(2nd
Agovino v. Taco Bell, 225 A.D.2d 569 Dept. 1996).

NOTICE OF DISCOVERY AND INSPECTION OF THE ACCIDENT LOCATION

Plaintiff demands access to the accident location by his liability expert and by his

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attorney. Please call Plaintiff's attorney to arrange a mutually convenient time and date for

the inspection of the Premises.

NOTICE OF DISCOVERY AND INSPECTION

"document"
As used throughout these Discovery Demands, the words or

"documents"
means any written, recorded, filmed or graphic matter whether produced

and/or reproduced on paper, cards, tapes, film, electronics, facsimile, computer storage

device, dise, hard drive, e-mail, or any other media that are or have been in the possession,

custody or control of the Defendant(s), or other documents that are known by Defendant(s)

"you"
to exist. References to means Defendant(s), his/her/its/their agents, servants,

"and" "or"
employees and attorneys. The words and are to be construed in both the

"any" "all," "all"
conjunctive and disjunctive. The word includes the word and the word

"any."
includes the word The use of the singular shall include the plural, and the use of the

plural shall include the singular. The use of the male pronoun shall include the female

"Defendant(s)"
pronoun. References to include, but are not limited to,Defendant(s) and

"Premises"
Defendant(s)'s agents, servants and employees. The term means the location of

the accident set forth in the Bill of Particulars. The foregoing definitions form an integral

part of each of the demands.

PLEASE TAKE FURTHER NOTICE, that you are required to produce the

following:

1. All leases or subleases (including riders and amendments) regarding the Premises in

effect on the date of the accident.

2. All agreements and/or contracts between the Defendant(s) regarding the Premises

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and/or the scaffolding at the Premises in effect on the date of the accident.

3. All contracts, subcontracts, leases, subleases, records, documents, memoranda, notes,

correspondence, reports, repair orders, logs, field reports, progress reports, purchase

orders, schedules, policies, procedures, rules, regulations, instructions, guidelines,

directives, invoices, bills, permits, curb cuts, cut-forms, diagrams, street openings,

work permits, blueprints, architect's designs, schematics, diagrams, job meeting

minutes, records referable to work done pursuant to permits and permit applications,

work proposals, or other documents regarding the service, inspection, repair and

maintenance of the sidewalk and/or the scaffolding at the Premises for the five years

(2nd
period prior to the accident. Dorsa v. National Amusements, Inc., 6 A.D.3d 652

Dept. 2004)(maintenance records regarding recurrent condition); Hardy v. Tops, 231

(4th
A.D.2d 879 Dept 1996)(Cleaning, maintenance and inspection schedules; prior

(4th
similar accidents; prior complaints); Taylor v. John Doe, 167 A.D.2d 984 Dept.

1990)(complaints and accident reports from the date of construction until the date of

(2nd
accident); Giacalone v. Hicksville Concrete Corp., 134 A.D.2d 482 Dept.

1987)(maintenance records for twelve years); Dattmore v. Eagan Real Estate, Inc., 112

(4th
A.D.2d 800 Dept. 1985)(security log book and maintenance log book pertaining to

prior accidents and repairs).

4. All contracts, subcontracts, leases, subleases, records, documents, memoranda, notes,

correspondence, reports, repair orders, logs, field reports, progress reports, purchase

orders, schedules, policies, procedures, rules, regulations, instructions, guidelines,

directives, invoices, bills, permits, curb cuts, cut-forms, diagrams, street openings,

work permits, blueprints, architect's designs, schematics, job meeting minutes, records

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referable to work done pursuant to permits and permit applications, work proposals, or

other documents regarding the sidewalk and/or the scaffolding at the Premises. Garcia

(2nd
v. City of New York, 5 A.D.3d 725, 774 N.Y.S.2d 173 Dept. 2004)(installation of

(13t
sidewalk records); Rivera v. City, 61 A.D.3d 521 Dept. 2009)(installation); Villa v.

(1st
N.Y.C.H.A., 107 A.D.2d 619 Dept. 1985)(installation records).

5. The names and last known addresses (ifno longer employed) of any employees,

supervisory personnel, independent contractors, tenants, inspectors, or other entities

responsible for installation, service, inspection, repair and maintenance of the sidewalk

and/or the scaffolding at the Premises for the five year period prior to and including the

date of the accident.

6. All records, documents, logs, schedules, policies, procedures, invoices, bills, or other

written information regarding the construction and/or erection of the existing

scaffolding at the subject Premises.

7. All records, documents, logs, schedules, policies, procedures, invoices, bills, or other

written information regarding the lighting of the subject sidewalk and/or the scaffolding

at the Premises for the three-year period prior to the accident.

8. All documents, records, pleadings, notices of claim, correspondence, and log books

regarding any written or oral complaints, other accidents, or other litigation, regarding

the conditions complained of in the Complaint, or similar conditions, at the Premises

during the five years before the subject accident. See Mann v. Cooper, 816 N.Y.S.2d 45

(ISt (2nd
Dept. 2007); Dorsa v. National Amusements, Inc., 6 A.D.3d 652 Dept.

2004)(maintenance records regarding recurrent conditions); Daniels v. City of New

(1st
York, 291 A.D.2d 260 Dept. 2002)(prior similar accidents for three years prior to

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(2nd
the accident); Lancaster v. St. Luke's, 295 A.D.2d 321 Dept. 2002)(prior similar

(1st
accidents); Hall v. 130-10 Food Corp., 254 A.D.2d 22 Dept. 1998)(prior similar

(2nd
accidents); Coan v. LIRR, 246 A.D.2d 569 Dept. 1998)(records of prior similar

(4th
accidents); Hardy v. Tops, 231 A.D.2d 879 Dept 1996)(incident reports regarding

other falls and records of complaints; maintenance and inspection schedule); Boone v.

(2nd
Supermarket General Corp., 109 A.D.2d 771 Dept. 1985)(other slips and falls in

(2nd
five years prior); Lestingi v. City of New York, 209 A.D.2d 384 Dept. 1994)(prior

(lSt
similar accidents); Herbert v. Sivaco, 289 A.D.2d 71 Dept. 2001)(prior

(1st
complaints); Dukes v. 800 Grand Concourse Owners, Inc., 198 A.D.2d 13 Dept.

(4th
1993)(prior roof leaking in other units); Taylor v. John Doe,167 A.D.2d 984 Dept.

(3rd
1990)(prior similar accidents); Parry v. Pyramid Crossgattes Co., 158 A.D.2d 787

Dept. 1990)(other incidents in fifteen year period); Ielovich v. Taylor Mach. Works,

(2nd
Inc., 128 A.D.2d 676 Dept. 1987)(past accidents); Alexson Mechanical

(2nd
Contracting, Inc. v. Honeywell, 101 A.D.2d 796 Dept. 1984)(customer

(2nd
complaints); Klatz v. Armor Elevator Co., Inc., 93 A.D.2d 633 Dept. 1983)(other

(4th
accidents); Jonmaire v. West Seneca, 120 A.D.2d 928 Dept. 1986)(other

(3rd
accidents); Indilicato v. Pacific Pool Industries, Inc., 95 A.D.2d 886 Dept.

1983)(claims, correspondence and legal pleadings); Ragona; Petty v. Riverbay Corp.,

(13t
92 A.D.2d 525 Dept. 1983)(other actions, records of other assaults, bills,

correspondence, repair and maintenance records); Mott v. Chesbro-Whitman Co., 87

(2nd (2nd
A.D.2d 573 Dept. 1982)(other claims); Ross v. Northern, 43 A.D.3d 1135

Dept. 2007)("similar incidents that had occurred during the three-year period prior to

(2nd
the accident"); Marte v. Brooklyn Hospital Center, 9 A.D.3d 41 Dept.

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2004)(records of the investigation of the incident, prior similar incidents, complaints

regarding security breaches, and log books).

9. All writings reflecting notice to the Defendant(s) of the conditions complained of in the

Complaint prior to and including the date of Plaintiffs accident.

10. Names and lastknown addresses of allbuilding/property managers, porters, supers,

doormen, security and cleaning persons employed at the Premises on the date of the

accident.

I 1.All documents, consisting of, but not limited to, prior notification maps, complaints,

correspondence, Big Apple transmittal letters, computer data and printouts, index book

and log entries and inspection reports, of complaints received by any Defendant(s),

concerning the condition of the subject Premises prior to and including the date of the

accident. All copies of maps/diagrams are to be made and provided at full scale as the

original map/diagram so as to remain legible.

12. Printouts of computer data identifying alleged defects at the subject Premises within the

three years prior to the date of Plaintiffs accident.

13. Fifteen day notices issued by the City of New York, its departments and agencies,

relating to the scaffolding and/or the Premises prior to the date of Plaintiffs accident.

14. Reports prepared by Traffic Enforcement Agents, Police Officers, Department of

Transportation Inspection Team or Civil Servant Inspectors (e.g., P.D. 301-155, UF 18

and UF 61 reports) concerning the scaffolding and/or the Premises.

15. Memoranda, minutes and other documents of the Traffic and Construction

Coordinating Council, or any successor entity, pertaining to the scaffolding and/or the

Premises prior to the date of accident.

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16. All Central Index Bureau (CIB) reports that indicate or show any accident(s) or

pertaining to the Plaintiff in this action and set forth dates, times and places
claim(s)

that the prior accident(s) occurred.

17. The deed to the Premises in effect on the date of the accident.

18. Work orders, permits and complaint tickets of the Department of Transportation,

Department of Environmental Protection, and/or the Central Complaint Bureau of the

Department of Sewars, for the subject location for the two years prior to the accident.

(2nd
Bruni v. City, 2 N.Y.3d 319 (2004); Stein v. City, 12 A.D.3d 587 Dept. 2004).

19. Pursuant to HIPPA, if Defendant(s) at any time interviews Plaintiffs treating doctors

pursuant to the authorization requirements of HIPPA, Plaintiff demands all documents,

memoranda, notes reporting oral statements made by the doctor being interviewed, and

audio and video recordings of the interview.

20. Pursuant to CPLR Article 16, identify allparties and non-parties potentially liable for

Plaintiffs injuries. Ryan, 170 A.D.2d 1045. Plaintiff will object at trialto any Article

16 Defenses not disclosed before the Note of Issue is filed.

21. Records of subsequent accidents, and subsequent remedial action such as cleaning.

(4th
Hardy v. Topps, 231 A.D.2d 879 Dept. 1996); Niemann v. Luca, 214 A.D.2d 658

(2nd (4th
Dept. 1995); Mazurek v. Home Depot, 303 A.D.2d 960 Dept. 2003); Hughes

(4th (3rd
v. Cold, 26 A.D.3d 858 Dept. 2007); Petrilli v. Federated, 40 A.D.3d 1339

Dept. 2007).

PLEASE TAKE FURTHER NOTICE, that the foregoing are continuing

demands and that if any of the above items are obtained after the date of this demand, they

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are to be furnished to the undersigned, pursuant to these demands. To the extent

Defendant(s) claims that records cannot be located, produce a detailed statement, made

under oath, by a person with direct knowledge of the facts as to the past and present status

(13t
of the sought documents. Orner v. Mt. Sinai Hospital, 305 A.D.2d 307 Dept. 2003);

(1st
Longo v. Armor Elevator Co., Inc., 278 A.D.2d 127 Dept. 2000); Wilensky v. JRB

(2nd
Marketing, 161 A.D.2d 761 Dept. 1990). UnSubStantiated conclusory allegations of

hardship or an unwarranted fishing expedition are insufficient to bar disclosure.

Defendant(s) must show prejudice, disadvantage or embarrassment. Cynthia B. v. New

(2nd
Rochelle Hosp. Med. Center, 60 N.Y.2d 452 (1983); People v. Skylift, 72 A.D.2d 599

Dept. 1979). The fact that the Defendant(s) may have to produce or look for a number of

(13t
documents is irrelevant and not determinative. Shapiro v. Fine, 95 A.D.2d 714 Dept.

1983). Disclosure is not limited to the pleadings or the burden of proof. Allen v. Crowell-

Publishing Co., 21 N.Y.2d 403 (1968). An item of arguable relevance should be disclosed.

(2nd
Shanahan v. Bambino, 706 N.Y.S.2d 39 Dept. 2000). Discovery is not limited to

admissible evidence: any matter that could lead to the discovery of admissible proof is

(2"d
discoverable. Bigman v. Dime Sav. Bank, 153 A.D.2d 912 Dept. 1989). The burden of

demonstrating that particular subject matter is exempt from disclosure is on the party

(2nd
opposing discovery. Bigman. Vivitorian Corp. v. First, 203 A.D.2d 452 Dept. 1994);

(13t
Mavrikis v. Brooklyn Union, 196 A.D.2d 689 Dept. 1993). There is no privilege that

applies to the requested discovery. Responses that information will be provided "when it

known"
becomes are not responsive and could result in preclusion or striking of your

(2nd
answer. Garcia v. City of New York, 5 A.D.3d 725, 774 N.Y.S.2d 173 Dept. 2004).

Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice

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law in the Courts of New York State, certifies that, upon information and belief and

reasonable inquiry, the contentions contained in this document are not frivolous.

Dated: Rockville Centre, NY
April 28, 2021

Yours, etc.

GABRIEL LAW FIRM
By: Thomas Bernard, Esq.
Attorneys for Plaintiff
2 Lincoln Avenue, Suite 400,
Rockville Centre, NY, 11570

(516) 360-9101
File No: GLF20-2175

TO1

KOWALSKI & DEVITO
By: Bradley J. Corsair
Attorneys for Defendant
413 THROOP AVE LLC
80 Pine Street, Suite 300
New York, New York 10005

(718) 250-1100
File # NYNY-33832

FRENCH & CASEY, LLP
By: Joseph A. French
Attorneys for Defendant
CORE SCAFFOLD SYSTEMS INC.
29 Broadway, 27th Floor
New York, New York 10006
212-797-3544
File No.: 6230.1008

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------------X
NICOLE SUTTON, Index No: 522901/2020

Plaintiff, NON-CONSENT
TO SERVICE
-against- BY FACSIMILE

413 THROOP AVE LLC and
CORE SCAFFOLD SYSTEMS INC.,

Defendants.

---------------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that this office does not c

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Document Filed Date

April 29, 2021

Case Filing Date

November 18, 2020

County

Parties

413 THROOP AVE LLC Defendant
CORE SCAFFOLD SYSTEMS INC. Defendant
CORSAIR, BRADLEY J Attorney for the Defendant
FRANKEL, ROGER ANDREW Attorney for the Defendant
FRENCH, JOSEPH A Attorney for the Defendant
FUCHS, CHERYL DIANA Attorney for the Defendant
GABRIEL, SUREN Attorney for the Plaintiff
Nicole Sutton Plaintiff
WILSON, MARKUS ALDO Attorney for the Defendant
SUSAN ROMANO Attorney
JOHN GARVEY Attorney
JAMES GARVEY Attorney
PATRICK GARVEY Attorney
THOMAS BERNARD Attorneys for Plaintiffs
JOSEPH GARVEY Attorney
GEORGE BOYLE Attorney

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No Value: Nicole Sutton v. 413 Throop Ave Llc, Core Scaffold Systems Inc.

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