On August 23, 2016 a
Motion-Secondary
was filed
involving a dispute between
Phadia Jean,
Vladimir Jean,
and
Orangetown Police Department,
Orangetown Police Officer,
Orangetown Town Of,
for Torts - Other (Abuse of Process)
in the District Court of Rockland County.
Preview
FILED: ROCKLAND COUNTY CLERK 12/30/2021 09:23 PM INDEX NO. 033456/2016
NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/30/2021
1 of 2
FILED: ROCKLAND COUNTY CLERK 12/30/2021 09:23 PM INDEX NO. 033456/2016
NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/30/2021
Central Nyack, New York (Redacted)
"J"
EXHIBIT Indepêñdêñt Medical Evaluation of Phadia Jean by Barbara
Baer, Ph.D., ABPP-CN (Redacted)
4. All exhibits are true and accurate copies of what they purport to be.
WHEREFORE, based upon the submissions of the Defendants to include the
accompanying memoranda of law dated November 5, 2021 and December 20, 2021, it is
Defendants'
respectfully requested that the relief requested in the Orangetown Notice of Motion
Plaintiffs'
be granted in itsentirety, that the motion for leave to amend their pleadings be denied,
and for such other and further relief as this Court deems just and proper.
Dated: December 30, 2021
Orangeburg, New York
RICHARD S. PAKOLA, ESQ.
Counselfor the Grañgaowñ Defendants
- 2 -
2 of 2
Document Filed Date
December 30, 2021
Case Filing Date
August 23, 2016
Category
Torts - Other (Abuse of Process)
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FILED: ROCKLAND COUNTY CLERK 12/30/2021 09:23 PM INDEX NO. 033456/2016 NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/30/2021 1 of 2 FILED: ROCKLAND COUNTY CLERK 12/30/2021 09:23 PM INDEX NO. 033456/2016 NYSCEF DOC. NO. 140 RECEIVED NYSCEF: 12/30/2021 Central Nyack, New York (Redacted) "J" EXHIBIT Indepêñdêñt Medical Evaluation of Phadia Jean by Barbara Baer, Ph.D., ABPP-CN (Redacted) 4. All exhibits are true and accurate copies of what they purport to be. WHEREFORE, based upon the submissions of the Defendants to include the accompanying memoranda of law dated November 5, 2021 and December 20, 2021, it is Defendants' respectfully requested that the relief requested in the Orangetown Notice of Motion Plaintiffs' be granted in itsentirety, that the motion for leave to amend their pleadings be denied, and for such other and further relief as this Court deems just and proper. Dated: December 30, 2021 Orangeburg, New York RICHARD S. PAKOLA, ESQ. Counselfor the Grañgaowñ Defendants - 2 - 2 of 2