Answer: Christeen Cooper Flash v. Janeine A. Richardson, Jose L. Escalante, Cecilia A. Escalante

On April 30, 2021 a Answer was filed involving a dispute between Christeen Cooper Flash, and Cecilia A. Escalante, Janeine A. Richardson, Jose L. Escalante, for Torts - Motor Vehicle in the District Court of Kings County.

Preview
FILED: KINGS COUNTY CLERK 06/09/2021 10:26 AM INDEX NO. 510164/2021
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 06/09/2021

510164/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
VERIFIED ANSWER
-against-
Index No. 510164/2021
JANEINE A. RICHARDSON, JOSE L.
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

Defendant, JANEINE A. RICHARDSON, by attorneys MARTYN, MARTYN, SMITH,

MURRAY AND YONG, ESQS., answering the Original Verified Complaint of the plaintiff herein

alleges:

1. Denies any knowledge or information sufficient to form a belief as to each and every

allegation contained in paragraphs designated “1”, “3”, “4”, “6”, “7”, “8”, “10”, “11”, “12”, “13”,

“14”, “15”, “16”, “17”, “18”, “19”, “20”, “21”, “22”, “23”, “24” and “25” of the Verified Complaint.

2. The allegations contained in paragraphs designated “2”, “5” and “9” are admitted.

3. Denies each and every allegation contained in paragraphs designated “26”, “27”, “28”,

“29”, “30” and “32” of the Verified Complaint and respectfully requests all questions of law be

referred to the Court.

4. Denies any knowledge or information sufficient to form a belief as to each and every

allegation contained in paragraph designated “31” of the Verified Complaint and respectfully requests

all questions of law be referred to the Court.

AS AND FOR A FIRST AFFIRMATIVE DEFENSE

5. That whatever injuries and damages the plaintiff may have sustained as alleged in the

Complaint herein were caused, in whole or in part by the culpable conduct of the plaintiff, including

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comparative negligence and assumption of risk of the plaintiff and failure to wear a seatbelt and/or

other restraints in accordance with Section 1229-C of the New York State Vehicle and Traffic Law

and plaintiff’s damages should be reduced by such culpable conduct.

AS AND FOR A SECOND AFFIRMATIVE DEFENSE

6. That if plaintiff’s economic losses were replaced or indemnified from collateral sources,

then this Defendant is entitled to have the Court consider these pursuant to CPLR 4545.

AS AND FOR A THIRD AFFIRMATIVE DEFENSE

7. That the injuries and damages allegedly sustained by plaintiff is barred pursuant to

Insurance Law 5104 unless plaintiff has sustained a serious injury and/or greater than basic economic

loss.

THE DEFENDANT, JANEINE A. RICHARDSON, SETS
FORTH THE FOLLOWING UPON INFORMATION
AND BELIEF AS AND FOR A CROSS-CLAIM
AGAINST THE CO-DEFENDANTS,
JOSE L. ESCALANTE AND CECILIA A. ESCALANTE

8. That if the damages and injuries alleged in the Original Verified Complaint filed herein

by the plaintiff were the result of any negligence other than plaintiff’s own negligence, then such

injuries and damages were caused wholly or in part by the negligence of the co-defendants, in the

ownership, operation, maintenance and control of co-defendants’ motor vehicle and in that said motor

vehicle was operated in a careless, reckless and negligent manner and without any negligence or active

participation on the part of JANEINE A. RICHARDSON contributing thereto and in that said co-

defendants actually, caused, created, maintained and were responsible for the conditions alleged in the

plaintiff’s Original Verified Complaint and at the situs of the occurrence and in that the aforesaid co-

defendants were the primary wrongdoers of any and all unusual or wrongful acts and were responsible

for the conditions alleged in plaintiff’s Original Verified Complaint and that for these reasons the co-

defendants are obligated to indemnify and hold harmless JANEINE A. RICHARDSON from and

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against any and all liability and damages which may be imposed upon it by reason of this lawsuit and

that if any negligence or liability is found to exist on the part of JANEINE A. RICHARDSON such

liability and negligence will be secondary and/or passive or the result solely of operation of law as

opposed to the liability of the co-defendants whose liability will be primary and active as aforesaid and

in such event JANEINE A. RICHARDSON demands judgment over and against co-defendants for

the amount of any verdict or judgment which shall or may be had against JANEINE A.

RICHARDSON in this action together with all costs and expenses which may be incurred in the

defense of this action.

SECOND CROSS-CLAIM

9. That the defendant, JANEINE A. RICHARDSON repeats and reiterates each and

every allegation set forth in the First Cross-claim with the same force and effect as if set forth at length

herein.

10. That if JANEINE A. RICHARDSON is held liable in this action, such liability and

damages will have arisen out of and have been contributed to in all or in part by the negligence of the

co-defendants in the ownership, operation, maintenance and control of co-defendants’ motor vehicle

and in such event JANEINE A. RICHARDSON demands judgment over and against the aforesaid

co-defendants for all or part of any verdict or judgment which shall or may be had against JANEINE

A. RICHARDSON in this action and that such damages shall be apportioned accordingly as the

proportion of their respective liability shall be determined.

WHEREFORE, the defendant, JANEINE A. RICHARDSON demands judgment

dismissing the Original Verified Complaint of the plaintiff herein as to it together with the costs and

disbursements of this action and further demands that the ultimate rights of JANEINE A.

RICHARDSON and of the plaintiff, and of the co-defendants, be determined in this action and that

JANEINE A. RICHARDSON have judgment over and against the aforesaid parties for all or part of

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any verdict or judgment which shall or may be had against JANEINE A. RICHARDSON in this

action, together with all reasonable costs and expenses which may have been incurred in the defense

of this action.

Dated: Mineola, NY
June 08, 2021

Yours & etc.,

MARTYN, MARTYN, SMITH, MURRAY
AND YONG, ESQS.
Attorneys for Defendant
JANEINE A. RICHARDSON
330 Old Country Road, Suite 211
Mineola, NY, 11501
516-739-0000

TO: GREGORY SPEKTOR &
ASSOCIATES, P.C.
Attorneys for Plaintiff
One Cross Island Plaza, Suite 203C
Rosedale, New York, 11422
(718) 528-5272

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STATE OF NEW YORK)
ss:
COUNTY OF NASSAU)

Robert A. Drummond, duly admitted to practice law before the Courts of the State of New

York, affirms the following to be true under the penalties of perjury:

That (s)he is an attorney with the office of MARTYN, MARTYN, SMITH, MURRAY AND

YONG, ESQS. attorneys for the defendant, JANEINE A. RICHARDSON, with offices at 330 Old

Country Road, Suite 211, Mineola, NY 11501, County of Nassau, State of New York; that (s)he has

read the foregoing ANSWER and knows the contents thereof and that the same is true to her/his

own knowledge except as to matters therein stated to be alleged on information and belief and that as

to those matters (s)he believes it to be true.

That the reason why this affirmation is made by affirmant and not by the defendant is that the

defendant does not reside in the County where MARTYN, MARTYN, SMITH, MURRAY AND

YONG, ESQS. have their aforesaid offices. That the sources of affirmant’s information and grounds

of her/his belief as to all matters in the foregoing Answer therein stated upon her/his knowledge are

records, reports, and correspondence in connection with this matter reviewed by your affirmant.

Dated: Mineola, NY
June 08, 2021

___________________________________
ROBERT A. DRUMMOND

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510164/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
DEMAND FOR VERIFIED
-against- BILL OF PARTICULARS

JANEINE A. RICHARDSON, JOSE L. Index No. 510164/2021
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that the defendant hereby demands that plaintiff serves on the

undersigned, within twenty (20) from the date of service hereof a verified bill of particulars with

respect to the following matters:

1. State the exact date and approximate time of day of the occurrence.

2. Describe the location of the accident in sufficient detail to permit definite
identification.

3. State the acts or omissions constituting the negligence claimed.

4. Set forth the nature and extent of the injuries claimed to have been
sustained.

5. Describe the injuries claimed to be permanent in their nature and
consequences in sufficient detail to permit definite identification.

6. If this is an action for personal injuries arising out of negligence in the use
or operation of a motor vehicle in this state, set forth in what respect has
plaintiff sustained a serious injury as defined in Ins. Law 5102, or economic
loss greater than basic economic loss as defined in Ins. Law 5102.

7. Set forth the length of time it will be claimed plaintiff was confined (a) to
bed and (b) to house; (c) identify the hospital(s) to which confined.

8. State (a) the usual business or occupation of the plaintiff and (b) plaintiff's
salary or income, if any, per day, week or month.

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9. Set forth the name and address of plaintiff's employer; or if self-employed,
so state, indicating the name and address under which the plaintiff is doing
business.

10. Set forth the length of time, if any, plaintiff was incapacitated from
employment or occupation, or if plaintiff was a student, give the name of
the school attended, and the grade in which he was a student.

11. Set forth the amount of lost earnings or any financial loss incurred and the
method by which the lost earnings and financial loss is computed.

12. State (a) the plaintiff's date and place of birth (b) social security number (c)
present address and (d) the address of the plaintiff at the time of the
occurrence.

13. Set forth the amounts incurred for:

(a) medical, surgical and dental services, stating separately the amount of
each service identifying by whom rendered.

(b) hospital services, stating separately the name and address of each
hospital and the amount of each bill.

(d) services for ambulance, x-rays, prescription drugs and prosthetics,
stating separately the amount of each bill and the service for which it
was rendered.

(e) any other item of expense, or damage.

14. Set forth the statutes or ordinances alleged to have been violated by the
defendant, designating by chapter, article, division, subdivision section,
paragraph and otherwise the particular portions and provisions of the
specific laws, ordinances, rules and regulations allegedly violated by
defendant.

15. State whether it is claimed that defendant had notice of the condition
complained of and if so, state whether actual or constructive notice is
claimed; if constructive notice is claimed, state for how long plaintiff claims
the alleged condition existed before the alleged accident; if actual notice is
claimed, state by whom and to whom such notice was allegedly given and
the place and time it was given, and whether oral or written and if written,
set forth a copy thereof.

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Dated: Mineola, NY
June 08, 2021

Yours & etc.,

MARTYN, MARTYN, SMITH, MURRAY
AND YONG, ESQS.
Attorneys for Defendant
JANEINE A. RICHARDSON
330 Old Country Road, Suite 211
Mineola, NY, 11501
516-739-0000

TO: GREGORY SPEKTOR &
ASSOCIATES, P.C.
Attorneys for Plaintiff
One Cross Island Plaza, Suite 203C
Rosedale, New York, 11422
(718) 528-5272

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
DEMAND FOR
MEDICAL
-against-
INFORMATION
JANEINE A. RICHARDSON, JOSE L.
Index No. 510164/2021
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that pursuant to C.P.L.R 3101 et seq. you are required to serve
and deliver to the undersigned within twenty (20) days the following:

Full, true, legible and complete copies of medical reports complying with the mandates of
22 NYCRR Section 202.17 of those physicians, dentists or other medical providers who have treated,
examined, consulted or saw the plaintiff for the condition(s) alleged in the Complaint or any prior
related condition(s). These shall include a detailed recital of the injuries and conditions as to which
testimony will be offered at the trial, referring to and identifying those x-ray and technician reports
which will be offered at the trial.

The names and addresses of all physicians who have examined or treated the plaintiff for
any of the injuries or conditions complained of or alleged herein, together with duly executed
authorizations permitting the defendant to examine such physician’s records.

Duly executed authorizations to examine all hospital records, including x-rays and
technician reports, involving the injuries or conditions complained of herein. All authorizations are to
expressly state the name, complete address and file number of each provider. All authorizations must
comply with the provisions of The Health Insurance Portability and Accountability Act (HIPAA)

Upon your failure to comply herewith, the plaintiff herein will be precluded at the time of trial
of this action from offering in evidence any part of the hospital records, medical records, x-ray reports
or report of other technicians not made available pursuant to the aforementioned rule, nor will the
Court hear the testimony of any physicians whose medical reports have not been served pursuant to
the aforementioned demand.

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Dated: Mineola, NY
June 08, 2021

Yours & etc.,

MARTYN, MARTYN, SMITH, MURRAY
AND YONG, ESQS.
Attorneys for Defendant
JANEINE A. RICHARDSON
330 Old Country Road, Suite 211
Mineola, NY, 11501
516-739-0000

TO: GREGORY SPEKTOR &
ASSOCIATES, P.C.
Attorneys for Plaintiff
One Cross Island Plaza, Suite 203C
Rosedale, New York, 11422
(718) 528-5272

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
NOTICE FOR DISCOVERY
-against- AND INSPECTION

JANEINE A. RICHARDSON, JOSE L. Index No. 510164/2021
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that pursuant to the Civil Practice Law & Rules, the defendant

by attorneys, MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS., demands that each

plaintiff and their attorneys produce and permit discovery by the defendant, their attorneys or another

acting on their behalf, the following documents and things for inspection, copying and photographing:

1. Each plaintiff seeking to recover for the costs of medical care, dental care, custodial care

or rehabilitation services, loss of earnings or other economic loss is to serve on the defendant’s

attorneys within thirty (30) days of the service of this demand, a statement of all past and future costs

and expense which has been or will, with reasonable certainty, be replaced or indemnified, in whole

or in part, from any collateral source such as insurance (except life insurance), social security, Worker’s

Compensation. Each statement is to set forth the name, address and insurance policy (or other account)

number of each collateral-source payor; and, separately stated for each payor, a list specifying the date

and amount of each payment and the name, address and social security number or other taxpayer

identification number of each payee. (C.P.L.R. 4545 (c)).

Said documents and things are to be produced at the offices of MARTYN, MARTYN,

SMITH, MURRAY AND YONG, ESQS., 330 Old Country Road, Suite 211, Mineola, NY 11501

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within thirty (30) days of receipt of this notice, at which time they will be physically inspected, copied

or mechanically reproduced and then returned.

PLEASE TAKE FURTHER NOTICE, that a written communication enclosing the

aforerequested information may be sent prior to the above mentioned time in lieu of a personal

appearance at the above time.

Dated: Mineola, NY
June 08, 2021

Yours & etc.,

MARTYN, MARTYN, SMITH, MURRAY
AND YONG, ESQS.
Attorneys for Defendant
JANEINE A. RICHARDSON
330 Old Country Road, Suite 211
Mineola, NY, 11501
516-739-0000

TO: GREGORY SPEKTOR &
ASSOCIATES, P.C.
Attorneys for Plaintiff
One Cross Island Plaza, Suite 203C
Rosedale, New York, 11422
(718) 528-5272

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-----------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
NOTICE FOR DISCOVERY
-against- AND INSPECTION

JANEINE A. RICHARDSON, JOSE L. Index No. 510164/2021
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that pursuant to Rule 3120 of the Civil Practice Law & Rules,

the defendant by attorneys, MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS.,

demands that the plaintiff, co-defendant(s) and/or third party defendant(s) produce and permit

discovery by MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS. or another acting on

their behalf, the following documents and things for inspection, copying and photographing:

1. The names and addresses of any witnesses at the scene of the occurrence, or people

who in any way witnessed the happening of the occurrence involving the plaintiff in this action, or

who appeared on the scene immediately following the occurrence, pursuant to the rule in ZELLMAN

vs. METROPOLITAN TRANSPORTATION AUTHORITY, 40 A.D. 2d 248, WOLKEN vs.

E.W.HOWELL COMPANY, 4l A.D. 2d 545.

2. The names and addresses of any witnesses or persons whom the plaintiff proposes to

call as notice witnesses as to the purported dangerous, defective and/or unsafe condition allegedly

causing this occurrence pursuant to the rule set forth in ZAYAS vs. MORALES, 45 A.D. 2d 6l0.

Said documents and things are to be produced at the offices of MARTYN, MARTYN,

SMITH, MURRAY AND YONG, ESQS. 330 Old Country Road, Suite 211, Mineola, NY 11501

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within twenty (20) days after receipt of this notice at l0:00 in the forenoon of that day at which time

they will be physically inspected, copied or mechanically reproduced and then returned.

PLEASE TAKE FURTHER NOTICE, that if the above parties or their attorneys

obtaining names and addresses of persons who witnessed the occurrence or who have firsthand

knowledge of same or are notice witnesses, subsequent to the service of this notice, such information

is to be furnished to MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS. whenever so

obtained. The defendant will object at the time of trial of this action to the testimony of any persons

not so identified.

PLEASE TAKE FURTHER NOTICE, that a written communication enclosing the afore-

requested information may be sent prior to the above mentioned time in lieu of personal appearance

on the above date.

Dated: Mineola, NY
June 08, 2021

Yours & etc.,

MARTYN, MARTYN, SMITH, MURRAY
AND YONG, ESQS.
Attorneys for Defendant
JANEINE A. RICHARDSON
330 Old Country Road, Suite 211
Mineola, NY, 11501
516-739-0000

TO: GREGORY SPEKTOR &
ASSOCIATES, P.C.
Attorneys for Plaintiff
One Cross Island Plaza, Suite 203C
Rosedale, New York, 11422
(718) 528-5272

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
NOTICE FOR DISCOVERY
-against- AND INSPECTION

JANEINE A. RICHARDSON, JOSE L. Index No. 510164/2021
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that pursuant to C.P.L.R §3101(d), defendant by attorneys,

MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS. demands that plaintiff, co-

defendant(s), and/or third party defendant(s) and their attorneys, produce and permit discovery by

MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS. or another acting on its behalf, the

following documents and things for inspection, copying, photographing and testing:

1. Set forth the names and addresses of each person you intend to call as an expert
witness at the time of trial of this action, and

2. Describe in reasonable detail the subject matter on which each expert is expected
to testify, and

3. Set forth the substance of the facts and opinions to which each expert is expected
to testify, and

4. Set forth the qualifications of each expert, witness, and

5. Set forth a summary of the grounds for each expert’s opinion, and

Said documents, things and information are to be produced at the offices of MARTYN,

MARTYN, SMITH, MURRAY AND YONG, ESQS., 330 Old Country Road, Suite 211, Mineola,

NY 11501 within twenty (20) days after receipt of this notice at 10:30 o’clock in the forenoon of that

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day at which time they will be physically inspected, copied or mechanically reproduced and then

returned.

PLEASE TAKE FURTHER NOTICE, that in the event that an expert is retained

subsequent to the service of this notice, such information is to be furnished to the office of MARTYN,

MARTYN, SMITH, MURRAY AND YONG, ESQS. whenever so obtained. The defendant will

object at the time of trial of this action to the testimony of any expert witness with regard to whom

you have failed to comply with this Notice for Discovery and Inspection.

PLEASE TAKE FURTHER NOTICE, that a written communication enclosing the afore-

requested information may be sent to the above named attorneys prior to the abovementioned time

in lieu of a personal appearance on the above date.

Dated: Mineola, NY
June 08, 2021

Yours & etc.,

MARTYN, MARTYN, SMITH, MURRAY
AND YONG, ESQS.
Attorneys for Defendant
JANEINE A. RICHARDSON
330 Old Country Road, Suite 211
Mineola, NY, 11501
516-739-0000

TO: GREGORY SPEKTOR &
ASSOCIATES, P.C.
Attorneys for Plaintiff
One Cross Island Plaza, Suite 203C
Rosedale, New York, 11422
(718) 528-5272

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
NOTICE FOR DISCOVERY
-against- AND INSPECTION

JANEINE A. RICHARDSON, JOSE L. Index No. 510164/2021
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that pursuant to the Civil Practice Law and Rules, the defendant

by attorneys, MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS. demands that plaintiff,

co-defendant(s) and/or third party defendant(s) produce and permit discovery by MARTYN,

MARTYN, SMITH, MURRAY AND YONG, ESQS. or another acting on their behalf, the following

documents and things for inspection, copying and photographing:

1. Copies of any and all answers, pleadings, notices for discovery and inspection,
discovery responses, medical-hospital records and reports served or exchanged to date.
2. Copies of any and all photographs, slides, videotapes or motion pictures depicting (a)
the scene of the accident, (b) the vehicle or vehicles involved (c) the defective condition involved (d)
the injuries to the plaintiff(s).
Said documents and things are to be produced at the offices of MARTYN, MARTYN,

SMITH, MURRAY AND YONG, ESQS. within twenty (20) days after receipt of this notice at l0:00

in the forenoon of that day, at which time they will be physically inspected, tested, copied or

mechanically reproduced and then returned.

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Dated: Mineola, NY
June 08, 2021

Yours & etc.,

MARTYN, MARTYN, SMITH, MURRAY
AND YONG, ESQS.
Attorneys for Defendant
JANEINE A. RICHARDSON
330 Old Country Road, Suite 211
Mineola, NY, 11501
516-739-0000

TO: GREGORY SPEKTOR &
ASSOCIATES, P.C.
Attorneys for Plaintiff
One Cross Island Plaza, Suite 203C
Rosedale, New York, 11422
(718) 528-5272

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
NOTICE FOR DISCOVERY
-against- AND INSPECTION

JANEINE A. RICHARDSON, JOSE L. Index No. 510164/2021
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that pursuant to Rule 3l20 of the Civil Practice Law and Rules,

defendant by attorneys, MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS. demands

that plaintiff and co-defendant(s) and/or third party defendant(s) and their attorneys produce and

permit discovery by MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS. or another

acting on their behalf, the following documents and things for inspection, copying, photographing

and testing:

1. Copies, recordings, reproductions and/or transcriptions or any statements, written or

recorded, taken of or from defendant represented by the undersigned attorneys or from any agent,

servant and/or any of their agents, servants, employees or representatives.

2. Copies, recordings, reproductions and/or transcriptions of any admissions made by

the defendant represented by the undersigned attorneys or of any admissions made by any of its agents,

servants and/or employees which will be used by any of the parties at the time of trial. If the alleged

admissions were not written or transcribed, set forth (a) the name and address of the person making

the admission (b) the name and address of the person to whom the admission was made (c) the date,

time and place where the admission was made, and (d) set forth a statement as to exact content of the

alleged admission.

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3. Copies of any and all liens asserted against the plaintiff and any and all agreements by

which the plaintiff has assigned, sold, demised and/or otherwise transferred to any third party any

interest in this action and/or the monies anticipated to be recovered in this action (other than the

attorney’s fees relative to this action).

Said documents and things are to be produced at the offices of MARTYN, MARTYN,

SMITH, MURRAY AND YONG, ESQS. within twenty (20) days after receipt of this notice at l0:00

in the forenoon of that day, at which time they will be physically inspected, tested, copied or

mechanically reproduced.

Dated: Mineola, NY
June 08, 2021

Yours & etc.,

MARTYN, MARTYN, SMITH, MURRAY
AND YONG, ESQS.
Attorneys for Defendant
JANEINE A. RICHARDSON
330 Old Country Road, Suite 211
Mineola, NY, 11501
516-739-0000

TO: GREGORY SPEKTOR &
ASSOCIATES, P.C.
Attorneys for Plaintiff
One Cross Island Plaza, Suite 203C
Rosedale, New York, 11422
(718) 528-5272

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
DEMAND FOR
STATEMENT OF
-against-
MONETARY DAMAGES
JANEINE A. RICHARDSON, JOSE L.
Index No. 510164/2021
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that pursuant to C.P.L.R. § 3017(a)(c), you are required to serve

and deliver to the undersigned within fifteen (15) days the following:

Set forth the monetary amount of damages claimed for each and every cause of action alleged

in the Original Verified Complaint.

PLEASE TAKE FURTHER NOTICE, that failure to comply with this demand will result

in a motion that will request motion costs.

Dated: Mineola, NY
June 08, 2021

Yours & etc.,

MARTYN, MARTYN, SMITH, MURRAY
AND YONG, ESQS.
Attorneys for Defendant
JANEINE A. RICHARDSON
330 Old Country Road, Suite 211
Mineola, NY, 11501
516-739-0000

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NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 06/09/2021

TO: GREGORY SPEKTOR &
ASSOCIATES, P.C.
Attorneys for Plaintiff
One Cross Island Plaza, Suite 203C
Rosedale, New York, 11422
(718) 528-5272

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NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 06/09/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------X
CHRISTEEN COOPER FLASH,

Plaintiff,
NOTICE TO TAKE DEPOSITION
-against- UPON ORAL EXAMINATION

JANEINE A. RICHARDSON, JOSE L. Index No. 510164/2021
ESCALANTE AND CECILIA A. ESCALANTE,

Defendants,.
--------------------------------------------------------------X

S I R S:

PLEASE TAKE NOTICE, that pursuant to Article 31 of the C.P.L.R., the parties

represented by MARTYN, MARTYN, SMITH, MURRAY AND YONG, ESQS. will take the

testimony of the plaintiff, co-defendant(s), third-party plaintiff(s) and/or third-party defendant(s) as

an adverse party as to all of the relevant facts and circumstances in connection with the accident,

including negligence, contributory negligence, liability or damages, before a duly authorized Notary

Public at a time and place to be determined and that for the purpose of refreshing plaintiff(s), co-

defendant(s), third-party plaintiff(s) and third-party defendant(s) recollection, plaintiff(s), co-

defendant(s), third-party plaintiff(s) and third-party defendant(s) are to have and produce upon the

aforesaid examination such records, books, papers, documents, correspondence and copies thereof

and other writings and papers kept by them or available to them as related to the matters in controversy

in said action or

Case Info

Judge

Peter P. Sweeney Track Judge’s New Case

Case No.

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Document Filed Date

June 09, 2021

Case Filing Date

April 30, 2021

County

Parties

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