On January 08, 2021 a
Party Discovery
was filed
involving a dispute between
Catherine Stramba,
and
Michael Ayers,
for Torts - Motor Vehicle
in the District Court of Tompkins County.
Preview
FILED: TOMPKINS COUNTY CLERK 02/22/2021 02:02 PM INDEX NO. EF2021-0016
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/22/2021
CI2021-02990 Index # : EF2021-0016
STATE OF NEW YORK
SUPREME COURT COUNTY OF TOMPKINS
__________________________________________
CATHERINE STRAMBA, NOTICE TO TAKE
DEPOSITION UPON ORAL
Plaintiff, EXAMINATION
vs.
Index No.: EF2021-00.16
MICHAEL AYERS,
Defendant.
___________________________________________
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and
Rules the testimony, upon oral examination, of the Plaintiff and Co-Defendant as an adverse
party will be taken before a Notary Public who is not an attorney, or employee of an attorney, for
any party or prospective party herein and is not a person who would be disqualified to act as a
juror because of interest or because of consanguinity of affinity to any party herein, at a mutually
agreeable date, time, and location with respect to evidence and material necessary in the defense
of this action.
That the said persons to be examined is required to produce at such examination the
following: Any and all photographs of the sites of the occurrence, the parties, and the vehicles in
question (before and after date of occurrence); Titles and registrations of the involved vehicles;
statements of the Defendant; Any and all accident reports (including, but not limited to MV-
104's and Police Reports reviewed by the party); Copies of all lease agreements/contracts for the
subject vehicles; Copies of all prior transcripts of testimony, including DMV and 50-H Hearings,
of the parties; Repair Estimates and bills for repairs and towing charges for all of the vehicles in
Sensitivity: Confidential
1 of 2
FILED: TOMPKINS COUNTY CLERK 02/22/2021 02:02 PM INDEX NO. EF2021-0016
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/22/2021
CI2021-02990 Index #: EF2021-0016
question; Copies of all denial letters, bills or invoices for providers, and documents evidencing
submission of bills, invoices, expenses.
DATED: East Syracuse, New York
February 22, 2021
Yours, etc.,
________________________________
BY: J. William Savage, Esq.
Law Office of J. William Savage
Attorneys for Defendant
MICHAEL AYERS
6320 Fly Road, Suite 107
East Syracuse, NY 13057
315-446-4705
TO: Luciano L. Lama, Esq.
The Lama Law Firm, LLP
Attorneys for Plaintiff
CATHERINE STRAMBA
2343 North Triphammer Road
Ithaca, New York 14850
607-275-3425
Sensitivity: Confidential
2 of 2
Document Filed Date
February 22, 2021
Case Filing Date
January 08, 2021
Category
Torts - Motor Vehicle
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Preview
FILED: TOMPKINS COUNTY CLERK 02/22/2021 02:02 PM INDEX NO. EF2021-0016 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/22/2021 CI2021-02990 Index # : EF2021-0016 STATE OF NEW YORK SUPREME COURT COUNTY OF TOMPKINS __________________________________________ CATHERINE STRAMBA, NOTICE TO TAKE DEPOSITION UPON ORAL Plaintiff, EXAMINATION vs. Index No.: EF2021-00.16 MICHAEL AYERS, Defendant. ___________________________________________ PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules the testimony, upon oral examination, of the Plaintiff and Co-Defendant as an adverse party will be taken before a Notary Public who is not an attorney, or employee of an attorney, for any party or prospective party herein and is not a person who would be disqualified to act as a juror because of interest or because of consanguinity of affinity to any party herein, at a mutually agreeable date, time, and location with respect to evidence and material necessary in the defense of this action. That the said persons to be examined is required to produce at such examination the following: Any and all photographs of the sites of the occurrence, the parties, and the vehicles in question (before and after date of occurrence); Titles and registrations of the involved vehicles; statements of the Defendant; Any and all accident reports (including, but not limited to MV- 104's and Police Reports reviewed by the party); Copies of all lease agreements/contracts for the subject vehicles; Copies of all prior transcripts of testimony, including DMV and 50-H Hearings, of the parties; Repair Estimates and bills for repairs and towing charges for all of the vehicles in Sensitivity: Confidential 1 of 2 FILED: TOMPKINS COUNTY CLERK 02/22/2021 02:02 PM INDEX NO. EF2021-0016 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/22/2021 CI2021-02990 Index #: EF2021-0016 question; Copies of all denial letters, bills or invoices for providers, and documents evidencing submission of bills, invoices, expenses. DATED: East Syracuse, New York February 22, 2021 Yours, etc., ________________________________ BY: J. William Savage, Esq. Law Office of J. William Savage Attorneys for Defendant MICHAEL AYERS 6320 Fly Road, Suite 107 East Syracuse, NY 13057 315-446-4705 TO: Luciano L. Lama, Esq. The Lama Law Firm, LLP Attorneys for Plaintiff CATHERINE STRAMBA 2343 North Triphammer Road Ithaca, New York 14850 607-275-3425 Sensitivity: Confidential 2 of 2