On June 24, 2020 a
Motion-Secondary
was filed
involving a dispute between
Brian Ingerson,
and
Mary E. Coombs,
for Real Property - Other (Partition & Sale of Prop.)
in the District Court of Washington County.
Preview
FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
SUPREME COURT
STATE OF NEW YORK COUNTY OF WASHINGTON
BRIAN INGERSON,
Plaintiff,
-against-
MARY E. COOMBS, Index No. EC2020-
Defendant. 31750
RESPONSE TO COMBINED DISCOVERY DEMANDS
Defendant, MARY E. COOMBS, by her attorney, JOHN R. WINN, ESQ.,
in Response to the Combined Discovery Demands dated November 10, 2022 of
the Plaintiff, states as follows:
DEMAND FOR PHOTOGRAPHS
1. Attached hereto is a copy of six photographs showing the Carlton
Road property, and the garage/barn.
DEMAND FOR WITNESSES
2. Mary E. Coombs dealt with Elizabeth Reynolds of Keller William
Realty Capital District, 935 Loudon Road, Latham, New York 12110 in
connection with the purchase of the real from Mr. and Mrs. Putorti. Ms.
property
Reynolds could be able to testify that her contact was with E. Coombs
only Mary
and that she had no contact with Brian Ingerson.
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FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
In connection with the installation of the well, Mary E. Coombs met with a
representative of Rosick Well Drilling, 1175 Farley Road, Hudson Falls, New
York who, presumably, would be able to testify that Mary E. Coombs hired
Rosick Well Drilling to drill a well at 276 Carlton Road, Whitehall, New York,
that the well was drilled and that Mary E. Coombs paid for the well. Mary E.
Coombs also purchased materials from MacLeod's Lumber of Route 4, Whitehall,
New York, and presumes that Bart Bartholomew of MacLeod's will recall selling
materials to her for the construction of the barn/garage and that she paid for the
same.
DEMAND FOR EXPERT WITNESSES
The only expert witness that Mary E. Coombs might call would be Cynthia
Hollister, of New York/Vermont Real Estate Company. She is a licensed real
estate broker with an office at 4 Chapman Road, Whitehall, New York. She has
examined the premises at 276 Carlton Road and it isbelieved that she is of the
opinion that the real property has a current value of about $70,000.00.
DEMAND FOR STATEMENTS
There were various statements given by Brian Ingerson in connection with
proceedings in the Washington County Family Court, that resulted in dismissal of
his various petitions. Brian Ingerson appealed the dismissals to the Appellate
Division, Third Department. The Record on Appeal that he filed contained his
testimony and statements. The Third Department denied the appeal(s). While
Mary E. Coombs was provided with a copy of the Record on Appeal from Brian
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FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
Ingerson's attorney, a copy is not being provided as it is already in the possession
of Brian Ingerson. Further, therev have been hundreds, if no thousands, of text
messages sent by Brian Ingerson to Mary E. Coombs. While Brian Ingerson
presumably has a record of the text messages that he has sent, a copy was provided
to his attorney on September 3, 2020, such that Mary E. Coombs has already
provided such a copy to Brian Ingerson.
Dated: December 29, 2022 ours, etc.
O . WINN, ESQ.
Atto ey for Defendant
13 North Street
Granville, New York 12832
Tel: (518) 642-1365
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NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
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NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
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NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
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NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
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NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
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NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
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NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022
JOHN R. WINN
AT1 ORNEY AT LAW
13 NORTH STREET
GRANVILLE. NEW YORK 12832
TELEPHONE
516-642-1365 FAX
516-642 1436
September 3 2020
William L White. Esq.
Brennan & White, LLP
163 Haviland Road
Queensbury. New York 12804
Fax No. 793-3422
Re: Ingerson v Coombs
Dear Bill:
I am
enclosing my client's bank statements
showing the monies that were
for expenses paid out
relating to the Carlton Road property. I am also a of
messages sent your enclosing copy text
by client to mine.
Please forward your client s cancelled checks and receipts when you can.
Thank you.
Very truly yours.
John R. Winn
10 of 10
Document Filed Date
December 29, 2022
Case Filing Date
June 24, 2020
Category
Real Property - Other (Partition & Sale of Prop.)
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FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 SUPREME COURT STATE OF NEW YORK COUNTY OF WASHINGTON BRIAN INGERSON, Plaintiff, -against- MARY E. COOMBS, Index No. EC2020- Defendant. 31750 RESPONSE TO COMBINED DISCOVERY DEMANDS Defendant, MARY E. COOMBS, by her attorney, JOHN R. WINN, ESQ., in Response to the Combined Discovery Demands dated November 10, 2022 of the Plaintiff, states as follows: DEMAND FOR PHOTOGRAPHS 1. Attached hereto is a copy of six photographs showing the Carlton Road property, and the garage/barn. DEMAND FOR WITNESSES 2. Mary E. Coombs dealt with Elizabeth Reynolds of Keller William Realty Capital District, 935 Loudon Road, Latham, New York 12110 in connection with the purchase of the real from Mr. and Mrs. Putorti. Ms. property Reynolds could be able to testify that her contact was with E. Coombs only Mary and that she had no contact with Brian Ingerson. 1 of 10 FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 In connection with the installation of the well, Mary E. Coombs met with a representative of Rosick Well Drilling, 1175 Farley Road, Hudson Falls, New York who, presumably, would be able to testify that Mary E. Coombs hired Rosick Well Drilling to drill a well at 276 Carlton Road, Whitehall, New York, that the well was drilled and that Mary E. Coombs paid for the well. Mary E. Coombs also purchased materials from MacLeod's Lumber of Route 4, Whitehall, New York, and presumes that Bart Bartholomew of MacLeod's will recall selling materials to her for the construction of the barn/garage and that she paid for the same. DEMAND FOR EXPERT WITNESSES The only expert witness that Mary E. Coombs might call would be Cynthia Hollister, of New York/Vermont Real Estate Company. She is a licensed real estate broker with an office at 4 Chapman Road, Whitehall, New York. She has examined the premises at 276 Carlton Road and it isbelieved that she is of the opinion that the real property has a current value of about $70,000.00. DEMAND FOR STATEMENTS There were various statements given by Brian Ingerson in connection with proceedings in the Washington County Family Court, that resulted in dismissal of his various petitions. Brian Ingerson appealed the dismissals to the Appellate Division, Third Department. The Record on Appeal that he filed contained his testimony and statements. The Third Department denied the appeal(s). While Mary E. Coombs was provided with a copy of the Record on Appeal from Brian 2 of 10 FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 Ingerson's attorney, a copy is not being provided as it is already in the possession of Brian Ingerson. Further, therev have been hundreds, if no thousands, of text messages sent by Brian Ingerson to Mary E. Coombs. While Brian Ingerson presumably has a record of the text messages that he has sent, a copy was provided to his attorney on September 3, 2020, such that Mary E. Coombs has already provided such a copy to Brian Ingerson. Dated: December 29, 2022 ours, etc. O . WINN, ESQ. Atto ey for Defendant 13 North Street Granville, New York 12832 Tel: (518) 642-1365 3 of 10 FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 if.a eU * MP 4 of 10 FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 a 5 of 10 FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 W j ½H O $ .d . 6 of 10 FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 q N L 7 of 10 FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 * . .t cc. c 8 of 10 FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 T O 9 of 10 FILED: WASHINGTON COUNTY CLERK 12/29/2022 05:23 PM INDEX NO. EC2020-31750 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 12/29/2022 JOHN R. WINN AT1 ORNEY AT LAW 13 NORTH STREET GRANVILLE. NEW YORK 12832 TELEPHONE 516-642-1365 FAX 516-642 1436 September 3 2020 William L White. Esq. Brennan & White, LLP 163 Haviland Road Queensbury. New York 12804 Fax No. 793-3422 Re: Ingerson v Coombs Dear Bill: I am enclosing my client's bank statements showing the monies that were for expenses paid out relating to the Carlton Road property. I am also a of messages sent your enclosing copy text by client to mine. Please forward your client s cancelled checks and receipts when you can. Thank you. Very truly yours. John R. Winn 10 of 10