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FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
--------------------------------------------------------------X
LAURIE HAFNER, Index No.: EF005199-2021
Plaintiff,
DEMAND FOR LITIGATION
-against- FUNDING CO. INFORMATION
AND DOCUMENTS
HOMEPRO EXTERIORS INC. and OMAR RAMOS
MENDOZA,
Defendants.
--------------------------------------------------------------X
COUNSELOR:
PLEASE TAKE NOTICE, that the undersigned hereby demands, pursuant to CPLR §§3101,
et seq., whether plaintiff, or plaintiff’s attorney(s), or anyone on the behalf of plaintiff or plaintiff’s
attorney(s) has entered into an agreement, contract, contingency or loan with a lender, litigation
funding company, litigation lending company, medical funding company or other similar entity,
company, corporation, partnership or person that is engaged in loaning money, advancing money or
financially assisting you or your attorney in any aspect of this case, whether it be for payment of
medical bills, litigation expenses, witness expenses, lost wages or an advancement against a portion
or all of any potential recovery you may receive and if so, produce within thirty days:
1. The complete name and address of the lender, litigation funding company, litigation
lending company, medical funding company or similar entity as described above.
2. The date on which agreement, advance or loan was made.
3. The amount of such agreement, advance or loan.
4. Legible copies of all information, including documents of any kind provided to the
lender, litigation funding company, litigation lending company, either pursuant to the
request of the litigation funding company, litigation lending company, or voluntarily
all brochures, application, contracts, agreements, liens, correspondence or other
similar documents received by plaintiff, completed by plaintiff, anyone on behalf of
plaintiff or plaintiff’s attorney(s) as part of the process of entering into all agreements,
negotiations and contracts with a lender, litigation funding company, litigation lending
company, medical funding company or similar entity.
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FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021
PLEASE TAKE FURTHER NOTICE that, the provision of CPLR §3122 govern this demand
and if the party to whom the notice is directed objects to the disclosure, inspection or examination or
withholds any documents which appear to be within the category of the documents required by notice,
that in the event any of the requested documents and/or items do not exist, a verified statement to that
effect is to be served on the undersigned on or before the aforesaid return date.
PLEASE TAKE FURTHER NOTICE that, in the event of failure or refusal to comply with
any of these demands, the demanding defendants will apply to the Court for the appropriate relief
including, but not limited to, an Order compelling compliance pursuant to CPLR §3124 and/or
appropriate relief pursuant to CPLR §3126 and 22 N.Y.C.R.R. Part 130.
PLEASE TAKE FURTHER NOTICE that, all demands herein shall be deemed to continue
during the pendency of this action through and including the trial thereof and must be amended or
supplemented properly in compliance with CPLR §3101(h). In the event any of the requested
documents and/or items are obtained after the aforesaid return date, same are to be furnished to the
undersigned within thirty (30) days after receipt.
Dated: Purchase, New York
November 15, 2021
MILBER MAKRIS PLOUSADIS
& SEIDEN, LLP
By:___________________________
Debra Salvi
Attorneys for Defendants
Homepro Exteriors Inc. and
Omar Ramos Mendoza
100 Manhattanville Road, Suite 4E20
Purchase, New York 10577
(914) 231-8021
dsalvi@milbermakris.com
File No.: 388-21367
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FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021
TO: Maria Zambrano Steinhaus, Esq.
SURIS & ASSOCIATES, P.C.
Attorneys for Plaintiff
395 North Service Road, Suite 302
Melville, New York 11747
(631) 423-9700
File No.: 4027891NR
maria@surislaw.com
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Preview
FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE --------------------------------------------------------------X LAURIE HAFNER, Index No.: EF005199-2021 Plaintiff, DEMAND FOR LITIGATION -against- FUNDING CO. INFORMATION AND DOCUMENTS HOMEPRO EXTERIORS INC. and OMAR RAMOS MENDOZA, Defendants. --------------------------------------------------------------X COUNSELOR: PLEASE TAKE NOTICE, that the undersigned hereby demands, pursuant to CPLR §§3101, et seq., whether plaintiff, or plaintiff’s attorney(s), or anyone on the behalf of plaintiff or plaintiff’s attorney(s) has entered into an agreement, contract, contingency or loan with a lender, litigation funding company, litigation lending company, medical funding company or other similar entity, company, corporation, partnership or person that is engaged in loaning money, advancing money or financially assisting you or your attorney in any aspect of this case, whether it be for payment of medical bills, litigation expenses, witness expenses, lost wages or an advancement against a portion or all of any potential recovery you may receive and if so, produce within thirty days: 1. The complete name and address of the lender, litigation funding company, litigation lending company, medical funding company or similar entity as described above. 2. The date on which agreement, advance or loan was made. 3. The amount of such agreement, advance or loan. 4. Legible copies of all information, including documents of any kind provided to the lender, litigation funding company, litigation lending company, either pursuant to the request of the litigation funding company, litigation lending company, or voluntarily all brochures, application, contracts, agreements, liens, correspondence or other similar documents received by plaintiff, completed by plaintiff, anyone on behalf of plaintiff or plaintiff’s attorney(s) as part of the process of entering into all agreements, negotiations and contracts with a lender, litigation funding company, litigation lending company, medical funding company or similar entity. 1 of 3 FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021 PLEASE TAKE FURTHER NOTICE that, the provision of CPLR §3122 govern this demand and if the party to whom the notice is directed objects to the disclosure, inspection or examination or withholds any documents which appear to be within the category of the documents required by notice, that in the event any of the requested documents and/or items do not exist, a verified statement to that effect is to be served on the undersigned on or before the aforesaid return date. PLEASE TAKE FURTHER NOTICE that, in the event of failure or refusal to comply with any of these demands, the demanding defendants will apply to the Court for the appropriate relief including, but not limited to, an Order compelling compliance pursuant to CPLR §3124 and/or appropriate relief pursuant to CPLR §3126 and 22 N.Y.C.R.R. Part 130. PLEASE TAKE FURTHER NOTICE that, all demands herein shall be deemed to continue during the pendency of this action through and including the trial thereof and must be amended or supplemented properly in compliance with CPLR §3101(h). In the event any of the requested documents and/or items are obtained after the aforesaid return date, same are to be furnished to the undersigned within thirty (30) days after receipt. Dated: Purchase, New York November 15, 2021 MILBER MAKRIS PLOUSADIS & SEIDEN, LLP By:___________________________ Debra Salvi Attorneys for Defendants Homepro Exteriors Inc. and Omar Ramos Mendoza 100 Manhattanville Road, Suite 4E20 Purchase, New York 10577 (914) 231-8021 dsalvi@milbermakris.com File No.: 388-21367 2 of 3 FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021 TO: Maria Zambrano Steinhaus, Esq. SURIS & ASSOCIATES, P.C. Attorneys for Plaintiff 395 North Service Road, Suite 302 Melville, New York 11747 (631) 423-9700 File No.: 4027891NR maria@surislaw.com 3 of 3