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FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021
NYSCEF DOC. NO. 11 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 PRODUCTION AS
-against- TO PRIOR AND SUBSEQUENT
RELATED INJURIES AND
HOMEPRO EXTERIORS INC. and OMAR RAMOS CONDITIONS
MENDOZA,
Defendants.
--------------------------------------------------------------X
PLEASE TAKE NOTICE, that pursuant to CPLR §3120, you are hereby required to
produce and permit discovery, inspection and copying within thirty (30) days after the receipt of
this demand, to the attorneys for the undersigned defendants, the following:
1. If plaintiff has sustained any prior or subsequent injury to any portions of her
body(ies) being claimed as injured in this action, then with respect to any such prior or subsequent
injury, state the portion(s) of the body involved and provide the following:
a. PRODUCE authorizations which will enable the undersigned to obtain all medical
records, hospital records, x-rays, MRI scans and technical and diagnostic reports and
films, directed to any hospital, clinic, diagnostic facility or other health care facility in
which the injured plaintiff is or was confined, treated and/or tested as a result of the
prior or subsequent injury described above.
b. PRODUCE copies of any accident and/or occurrence reports over any incident that
caused, gave rise to, precipitated or otherwise led to the development of the prior or
subsequent injury described above.
c. STATE the caption(s), venue(s) and index number(s) of any action(s) brought as a
result of sustaining the prior or subsequent injury described above and PRODUCE the
following documents from that/those litigation(s):
i. The Summons and Complaint and any Amended and/or Supplemental
Summons and Complaint;
ii. The Bill of Particulars and any Amended and/or Supplemental Bill of
Particulars;
iii. Copies of all medical reports exchanged in the action(s);
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FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 11/15/2021
iv. Copies of all depositions or otherwise recorded testimony of the plaintiff herein
from the action(s); and,
v. Copies of any General Releases and/or Judgments issued and/or filed in the
action(s).
2. If plaintiff has suffered from any pre-existing or subsequent condition(s) to any
portion of her body(ies) being claimed as injured in this action, state the portion(s) of the body(ies)
involved and provide the following:
a. PRODUCE authorizations which will enable the undersigned to obtain all medical
records, hospital records, x-rays, MRI scans and technical and diagnostic reports and
films, directed to any hospital, clinic, diagnostic facility or other health care facility in
which the injured plaintiff is or was confined, treated and/or tested as a result of the
prior or subsequent injury described above.
b. PRODUCE copies of any accident and/or occurrence reports over any incident that
caused, gave rise to, precipitated or otherwise led to the development of the prior or
subsequent injury described above.
c. STATE the caption(s), venue(s) and index number(s) of any action(s) brought as a
result of sustaining the prior or subsequent injury described above and PRODUCE the
following documents from that/those litigation(s):
i. The Summons and Complaint and any Amended and/or Supplemental
Summons and Complaint;
ii. The Bill of Particulars and any Amended and/or Supplemental Bill of
Particulars;
iii. Copies of all medical reports exchanged in the action(s);
iv. Copies of all depositions or otherwise recorded testimony of the plaintiff herein
from the action(s); and,
v. Copies of any General Releases and/or Judgments issued and/or filed in the
action(s).
3. Authorizations which will enable the undersigned to obtain the complete office
record, including but not limited to all X-Rays, MRIs, CT Scans and other diagnostic films of any
and all doctors who treated, examined and/or saw plaintiff herein for the condition, injury or
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FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 11/15/2021
infirmity for which damages are sought in this action, whether or not the physician will testify at
the time of trial.
PLEASE TAKE NOTICE, that upon your failure to comply with the above-mentioned
demands, said defendants will move this Court for those sanctions and remedies which are deemed
appropriate under the laws of New York State.
PLEASE TAKE FURTHER NOTICE, that these are continuing demands and that if you
obtain any of the information demanded herein subsequent to the service of this notice, then said
information is to be furnished to the defendants whenever obtained and said defendants will object
at the time of trial to the offering into evidence of any of the information which has been demanded
herein and not produced.
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
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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FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021 NYSCEF DOC. NO. 11 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 PRODUCTION AS -against- TO PRIOR AND SUBSEQUENT RELATED INJURIES AND HOMEPRO EXTERIORS INC. and OMAR RAMOS CONDITIONS MENDOZA, Defendants. --------------------------------------------------------------X PLEASE TAKE NOTICE, that pursuant to CPLR §3120, you are hereby required to produce and permit discovery, inspection and copying within thirty (30) days after the receipt of this demand, to the attorneys for the undersigned defendants, the following: 1. If plaintiff has sustained any prior or subsequent injury to any portions of her body(ies) being claimed as injured in this action, then with respect to any such prior or subsequent injury, state the portion(s) of the body involved and provide the following: a. PRODUCE authorizations which will enable the undersigned to obtain all medical records, hospital records, x-rays, MRI scans and technical and diagnostic reports and films, directed to any hospital, clinic, diagnostic facility or other health care facility in which the injured plaintiff is or was confined, treated and/or tested as a result of the prior or subsequent injury described above. b. PRODUCE copies of any accident and/or occurrence reports over any incident that caused, gave rise to, precipitated or otherwise led to the development of the prior or subsequent injury described above. c. STATE the caption(s), venue(s) and index number(s) of any action(s) brought as a result of sustaining the prior or subsequent injury described above and PRODUCE the following documents from that/those litigation(s): i. The Summons and Complaint and any Amended and/or Supplemental Summons and Complaint; ii. The Bill of Particulars and any Amended and/or Supplemental Bill of Particulars; iii. Copies of all medical reports exchanged in the action(s); 1 of 3 FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 11/15/2021 iv. Copies of all depositions or otherwise recorded testimony of the plaintiff herein from the action(s); and, v. Copies of any General Releases and/or Judgments issued and/or filed in the action(s). 2. If plaintiff has suffered from any pre-existing or subsequent condition(s) to any portion of her body(ies) being claimed as injured in this action, state the portion(s) of the body(ies) involved and provide the following: a. PRODUCE authorizations which will enable the undersigned to obtain all medical records, hospital records, x-rays, MRI scans and technical and diagnostic reports and films, directed to any hospital, clinic, diagnostic facility or other health care facility in which the injured plaintiff is or was confined, treated and/or tested as a result of the prior or subsequent injury described above. b. PRODUCE copies of any accident and/or occurrence reports over any incident that caused, gave rise to, precipitated or otherwise led to the development of the prior or subsequent injury described above. c. STATE the caption(s), venue(s) and index number(s) of any action(s) brought as a result of sustaining the prior or subsequent injury described above and PRODUCE the following documents from that/those litigation(s): i. The Summons and Complaint and any Amended and/or Supplemental Summons and Complaint; ii. The Bill of Particulars and any Amended and/or Supplemental Bill of Particulars; iii. Copies of all medical reports exchanged in the action(s); iv. Copies of all depositions or otherwise recorded testimony of the plaintiff herein from the action(s); and, v. Copies of any General Releases and/or Judgments issued and/or filed in the action(s). 3. Authorizations which will enable the undersigned to obtain the complete office record, including but not limited to all X-Rays, MRIs, CT Scans and other diagnostic films of any and all doctors who treated, examined and/or saw plaintiff herein for the condition, injury or 2 of 3 FILED: ORANGE COUNTY CLERK 11/15/2021 12:27 PM INDEX NO. EF005199-2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 11/15/2021 infirmity for which damages are sought in this action, whether or not the physician will testify at the time of trial. PLEASE TAKE NOTICE, that upon your failure to comply with the above-mentioned demands, said defendants will move this Court for those sanctions and remedies which are deemed appropriate under the laws of New York State. PLEASE TAKE FURTHER NOTICE, that these are continuing demands and that if you obtain any of the information demanded herein subsequent to the service of this notice, then said information is to be furnished to the defendants whenever obtained and said defendants will object at the time of trial to the offering into evidence of any of the information which has been demanded herein and not produced. 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 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