Motion for Discovery in Elaine Choy Lee, Chuck W Lee v. Alexander Behrens| Trellis.Law

On May 24, 2021 a Party Notice was filed involving a dispute between Chuck W Lee, Elaine Choy Lee, and Alexander Behrens, for Commercial - Other (consumer credit) in the District Court of New York County.

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FILED: NEW YORK COUNTY CLERK 07/20/2021 10:48 PM INDEX NO. 653362/2021
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 07/20/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------------X Index Number:
ELAINE CHOY LEE and CHUCK W. LEE, 65336/2021

Plaintiffs, NOTICE FOR
DISCOVERY AND
-against- INSPECTION

ALEXENDER BEHRENS,

Defendant.
------------------------------------------------------------------------X

PLEASE TAKE NOTICE that pursuant to CPLR 3120 and 3101 Plaintiffs, by their

attorneys, LEE HEIT, ATTORNEY AT LAW, PC Plaintiffs demand Defendant produce for

discovery by him or his attorneys the following articles, documents and things for

inspection, copying, testing and photographing within twenty (20) days after receipt hereof

at the Law Offices of Lee Heit, Attorney at Law PC, 1166 Carll’s Straight Path, Dix Hills, NY

11746.

DEFINITIONS

1. The term “document” or “documents” have the broadest meanings accorded to them,
include all materials discoverable pursuant to the New York Civil Practice Law and Rules,
and shall include any original, reproduction, copy, or draft of any kind of written or
documented material, stored in any medium and include, by way of illustration, the
following items, including, but not limited to, communications, audio and video tapes, text
messages, emails, correspondence, memoranda, interoffice communications, electronic
mail, notes, diaries, calendars, personal digital assistant device entries, contract documents,
estimates, vouchers, minutes of meetings, invoices, checks, reports, telegraphs, notices of
telephone conversations, notes of oral communications, computer-stored information that
is retrievable in any form, writings, drawings, graphs, charts, photographs, stenographic or
handwritten notes, written forms of any kind, blueprints, sketches, graphs, plans, articles,
specifications, letters, photographs, contracts, agreements, surveys, computer printouts,
data compilations of any kind, teletypes, facsimiles, invoices, order forms, drafts,
statements, credit memos, reports, summaries, books, ledgers, notebooks, schedules
transparencies, recordings, audio/digital recordings, catalogs, advertisements, promotional

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materials, films, digital/audio recordings, voicemail recordings, brochures, pamphlets, or
any written or recorded materials of any kind. The term “document” also includes
electronically stored data from which information can be obtained either directly or by
translation through detection devices or readers; any such document is to be produced in a
reasonably legible and usable form. The term also includes information stored in, or
accessible through, computer or other information retrieval systems (including any
computer archives or back-up systems), together with instructions and all other materials
necessary to use or interpret such data compilations.

2. “Defendant”, “Defendants”, “you”, or “your” as used here refer to ALEXANDER BEHRENS
and all other persons or entities acting or purporting to act on their behalf, including, but
not limited to, any parent or predecessor entities, successors, subsidiaries, affiliates, and
each of their present or former officers, directors, partners, employees, agents, attorneys,
and controlling shareholders.

3. The words “and” and “or” shall mean and/or and shall be construed disjunctively or
conjunctively, as necessary, to bring within the scope of the Request all documents that
might otherwise be construed outside the scope.

4. “Pertaining to” means consisting of, constituting, concerning, evidencing, reflecting,
comprising, relating to or referring to, or otherwise establishing any related causal
connection, in any way relevant within the meaning of the CPLR.

5. “Building(s) or Premises” means 295 Broadway, Apt. 10D, New York, New York and all
land, structures or other areas contained within these apartment complex.

6. A document is deemed to be within your “control” if you have the right to secure the
document or a copy thereof from another person.

7. The terms “person” or “persons” refers to natural persons, proprietorships,
governmental agencies, corporations, partnerships, trusts, joint ventures, groups,
associations, organizations, and all other entities.

8. “Short term renter” means any occupant who resides in the apartment for a period of
less than three months.

9. “Transient occupant” means any occupant who resides in the buildings for less than 30
days.

10. “Online platform” means a marketplace on the World Wide Web, where potential
renters, and/or brokers can connect with individuals who rent out apartments.

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INSTRUCTIONS

1. Unless otherwise indicated in the specific request, the time period for the documents
requested is May 1, 2019 through the date of your response to Plaintiffs’ Request, including
documents created prior to May 1, 2019 that were effective for any period of time after
May 1, 2019 as well as documents submitted to Plaintiffs and/or the real estate agent to
request tenancy in 395 Broadway, Apartment 10D, New York, New York to be used for
procuring a lease for said premise.

2. In responding to these Requests, Defendant is required to furnish all responsive
documents in his possession, custody, or control, or in the possession, custody, or control of
his attorneys, agents, brokers, employees, independent contractors, and all other persons
acting on behalf of each or any of them.

3. All references to the singular shall be construed to include the plural and all references to
the plural shall be construed to include the singular.

4. Each Request shall be responded to separately and fully, unless it is in good faith
objected to, in which event the reasons for the objection shall be stated with specificity
pursuant to the CPLR and Uniform Civil Rules of the Supreme Court. If an objection pertains
to only a portion of the Request, or to a word, phrase, or clause contained within the
Request, Defendant shall state the objection to that portion only and respond to the
remainder of the Request.

5. If, in responding to these Requests, Defendant claims any ambiguity in any Request, or in
a definition or instruction applicable thereto, Defendant shall not rely upon the ambiguity
as a basis for refusing to respond but shall set forth as part of their response the language
deemed to be ambiguous, and the interpretation used in responding to the Request.

6. An original or one copy of each responsive document shall be produced. Any copy of a
document that varies in any way from the original or from any other copy of the document,
whether by reason of handwritten or other notation, highlighting, underlining, or other
marks, or a draft or successive iteration thereof and all modifications thereto, shall
constitute a separate document and must be produced, whether or not the original of such
document is within Defendant’s possession, custody, or control. If the same document
exists in both electronic and non-electronic format, the electronically maintained document
must be produced, provided that, if the non-electronically maintained document varies in
any way from the electronically maintained document as described above, both the
electronically maintained and non- electronically maintained document shall be produced.

7. All documents produced shall be labeled to indicate the request to which they are
responsive.

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8. Documents shall be produced as they are kept in the usual course of business, or any
document related and/or submitted to procure the lease for the premises at issue. Each
document requested is to be produced in its original file folder, file jacket, or cover (or
Defendant may, in the alternative, designate in writing the titles of such folder, jacket, or
cover with respect to each document). The Defendant, entity, or individual from whose files
the document is being produced shall be indicated.

9. A request for documents shall be deemed to include a request for all transmittal sheets,
cover letters, exhibits, enclosures, and attachments to the documents, in addition to the
documents themselves, without abbreviation or expurgations. Documents attached to
other documents or materials shall not be separated unless information is provided
sufficient to permit reconstruction of the grouping or context in which the document is
maintained in the usual course of business.

10. Each document requested shall be produced in its entirety and without redactions,
deletions, or excisions, regardless of whether Defendant considers the entire document to
be relevant or responsive to these Requests.

11. If Defendant refuses to produce any requested document, or part of any requested
document, under a claim of attorney-client privilege, work product, or any other privilege,
Defendant shall submit, for each document or part of document withheld, a written
statement that:

a. Specifies the privilege or other asserted basis for withholding the document; b. Describes
the nature and general topic of the document;

c. Identifies the person(s) who prepared the document and any person(s) to whom the
document was sent or disclosed;

d. Identifies any persons who have seen or had possession of the document; and

e. Specifies the dates on which the document was prepared, transmitted, and received.

12. If there are no documents responsive to any particular Request, Defendants shall so
state in writing.

13. These are continuing requests. Any document obtained, identified, or located after the
date of production that would have been produced had it been available or had its
existence been known at that time should be produced immediately, including updates to
the records described in these requests.

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14. You must answer each document request fully and completely, after making reasonable
inquiries to obtain the documents. If you cannot answer any document request fully and
completely after making reasonable inquiries, you should answer the document request to
the best of your ability and explain why you cannot give a full and complete answer.

15. If any document that Defendant would have produced in response to any Request was,
but no longer is, in Defendant’s possession, custody, or control or is no longer in existence,
Defendant shall identify with respect to each document:

a. the date of the document;

b. the title of the document;

c. the type of document;

d. a description of the subject matter of the document;

e. the name of each person who prepared, received, viewed, or had possession, custody, or
control of the document;

f. the date on which the document was destroyed, discarded, or lost;

g. the name of each person who directed that the document be destroyed, who directed that
the document be discarded, or who lost the document; and

h. a statement of the reasons for and circumstances under which the document was
destroyed, discarded, or lost.

16. Documents not maintained electronically shall be scanned and electronically produced
in a user-friendly format. Each page of each document shall be individually numbered.

17. Documents maintained in electronic format, other than e-mails, shall be scanned and
electronically produced in an “imaged” file with the corresponding “image load/unitization
files” or user friendly unredacted format. Each page of each document should be
individually numbered.

18. Files shall be produced in their native file format where an image file does not
adequately represent the files as maintained in the ordinary course of business. Microsoft
Access files, Excel files, CSV files, other similar databases, and spreadsheet files, and media
files shall be produced in the format which the electronically stored information was
originally created.

Native Files shall be produced together with a placeholder image. Each placeholder shall
contain language indicating that the document is being produced in native format. A
relative file path to the native file shall be provided in the metadata database.

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19. Imaged file shall mean an image converted from the native file as it was originally
created. All imaged files shall meet the following requirements: All Imaged files shall be
exact copies. Color images are required to read or understand the file/document’s content;
all color images shall be produced as a JPEG file; numbers shall be branded to the images
so that the numbers print; imaged files shall be single page image files (one file for each
page of a document). Hidden content, tracked changes or edits, comments, notes, and other
similar information viewable within the native file shall also be imaged so that such content
is viewable on the image.

20. An image load/unitization file in a standard .opt or .log litigation support image load
format shall be included which provides:

a. the document number for each image;

b. the full path name(s) of each image file;

c. the document boundaries for each document; and

d. the load file shall be in the order that appropriately corresponds with each image file.

21.
electronic format, including e-mails, that do not render extractable text shall be provided as
follows:

a. Document level OCR text for redacted documents or Extracted text for ESI not containing
redaction shall be located in the same directory as its image file;
b. The text file name shall be the same name of the first image page for the OCR or
Extracted text file that corresponds to any documents maintained in document set,
followed by .txt.; and
c. An OCR or Extracted text file containing the produced document’s content shall be
provided for all documents whether it is produced as an image file or natively.

22. An associated delimited metadata database shall be provided in a “.dat” file format that
extracts metadata into fields in a delimited text load file. For the Concordance .dat, the
parties shall use Concordance standard delimiters (ASCII 020 corresponding to a comma,
ASCII 254 corresponding to a double quote, ASCII 174 corresponding to a new line, and a
semicolon used to separate values). The fielded data shall include all the below metadata
fields for a file/document in addition to the unitization (including the production number
of the first and last page of each document) and attachments (including the sort date
and/or any information sufficient to identify the parent and child relationships of all
documents that are or have attachments). The first line of the data load file shall contain
the field headers indicating the contents of each field, and each subsequent line should
contain the fielded data for each document.

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23. E-mails maintained in electronic format shall be electronically converted to TIFF
images and produced along with a Concordance.dat load file denoting: (i) the beginning
and
ending Bates number of each document; (ii) the sender’s name and e-mail address; (iii) the
names and e-mail addresses of individuals listed on the “To” line of the e-mail message; (iv)
the names and e-mail addresses of individuals listed on the “CC” line of the e-mail message;
(v) the names and e-mail addresses of individuals listed on the “BCC” line of the e-mail
message; (vi) the text contained on the “Subject” line of the e-mail message; (vii) the date
and time that the message was sent; and (viii) the beginning and ending Bates numbers of
associated attachments (collectively, “E-mail Metadata”), (ix) the native path; (x) the virtual
path; (xi) the hash value; (xii) confidentiality stamp, (xiii) custodian, and/or (xiv) duplicate
custodian. Each set of TIFF images constituting a single e-mail document shall be
accompanied by a plain-text (.txt) file containing any and all text that can be electronically
extracted from the native document. Each attachment to an e-mail shall be produced in
sequence immediately following the e-mail to which the document is attached and shall be
electronically converted to TIFF images and produced along with a Concordance.dat
compatible load file with the Electronic Document Metadata for the attachment and with a
plaintext (.txt) file containing any and all text that can be electronically extracted from the
attachment in its native format. If it is impractical or infeasible to convert any email
attachment document to TIFF format, Defendant shall produce (i) a “placeholder” image (in
sequence immediately following the e-mail to which the document is attached) containing
the file name of the attachment, (ii) the document in native format, and (iii) information
sufficient to link the native format document with its “placeholder” image.

24. The term “document” includes not only originals, but also any copies or reproductions
of all such written, printed, typed, recorded or graphic matter upon which any notations,
comments, or markings of any kind have been made that do not appear on the original
documents or that are otherwise not identical to the original documents. Any document
with marks such as initials, comments or notations of any kind is not identical to one
without such marks and is to be produced as a separate document.

25. Defendant shall produce electronically stored documents on flash drives or portable
hard drives.

DOCUMENTS

1. All documents, including but not limited to, text messages, emails, letters,
demands for rent and/or other payments made by Plaintiffs regarding 395 Broadway, Apt.
10D, New York, New York (“hereinafter referred to as the premises at issue”)

2. All documents including but not limited to, text messages, emails, letters,
responses to Plaintiffs’ demands for rent or other payments, rent breakdowns pertaining to
Document Request Number one.

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3. All documents including but not limited to, text messages, emails, letters,
demands for rent or other payments, rent breakdowns, pertaining to the premises at issue
written, recorded, or sent by Defendant to Plaintiffs or any of Plaintiffs’ agents, employees,
broker(s) or any person or entity associated with the premises at issue.

4. All documents including but not limited to text messages, emails, letters,
demands for rent or other payments, rent breakdowns, pertaining to the premises at issue
created or maintained by Defendant.

5. All documents or electronic data, including but not limited to, text messages,
emails, leases, letters, rental applications, credit applications, demands for rent or other
payments, rent breakdowns allegedly created or sent by Plaintiffs to Defendant,
Defendant’s agents, servants, broker(s) and/or employees/independent contractor(s).

6. All leases and/or rental agreements entered into between Plaintiffs and
Defendant.

7. All documents provided to Plaintiffs by Defendant, any broker(s) agents,
servant(s) or employees documenting Defendant’s credit, assets, banking and employment
status.

8. All documents and writings including but not limited to, text messages, emails,
and/or letters Defendant alleges were written to extend the original lease.

9. All documents including but not limited to, text messages, emails, letters, and/or
receipts documenting all money paid by Defendant to Plaintiffs for use and occupancy of
the premises at issue.

10. All documents, including but not limited to, text messages, emails, letters,
and/or receipts documenting any and all money paid by Defendant subsequent to the first-
year lease.

11. All documents, including but not limited to, text messages, emails, letters,
and/or receipts documenting rent or other payments paid by Defendant on or after March
1, 2020.

12. All documents, including but not limited to text messages, emails, letters and/or
receipts documenting an extension of the lease for another year.

13. All documents, including but not limited to text messages, emails, letters or
receipts documenting an extension of the lease subsequent to February, 2019.

14. Documentation that Defendant did not remain in possession of the apartment at
issue subsequent to the lease ending February, 2019.

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15. Documentation of Defendant’s new residence subsequent to allegedly vacating
the premises at issue at the end of the lease term.

16. All documents, including but not limited to text messages, emails, letters, leases
or receipts documenting Plaintiffs alleged agreement to reduced rent.

17. All documents, including but not limited to text messages, emails, letters, leases
or receipts documenting Plaintiffs alleged agreement to any rent and or payments to be
made following the original one-year lease.

18. All documents, including but not limited to text messages, emails, letters, leases
or receipts documenting Defendant’s request to any rent and or payment modifications
either reductions or increases to be made following the original one-year lease.

19. Any and all documentation, including but not limited to receipts, bank
statements, emails and/or correspondence documenting Defendant paid the full rent of
$5,700 subsequent to May, 2020.

20. Any and all documentation, including but not limited to receipts, emails, bank
statements and/or correspondence documenting the amount of money, if any, allegedly
paid by Defendant for June 2020 to September 2020.

21. Any and all documentation, including but not limited to receipts, emails, bank
statements, and/or correspondence documenting the amount of money, if any, allegedly
paid by Defendant from October 1, 2020 to present.

22. Any and all documents, including but not limited to correspondence, emails,
and/or texts documenting any and all alleged agreements to the change of the amount of
rent of $5,700.00 per month.

23. Documentation of employment status including name and location of employer,
salary and income earned, whether W-2, 1099, cash or other method of payment including
payments to Defendant individually or any corporation Defendant has any ownership
interest in. This demand is for three years prior to the original lease date to present.

24. Documentation of office(s) held by Defendant in any corporation located inside
or outside of the United States of America.

25. Documentation of any and all change of circumstance(s) of Defendant’s
employment and/or pay subsequent to signing the original lease.

26. Documentation of any and all change of circumstance(s) of Defendants
employment and/or pay subsequent to agreeing to extend the lease to a monthly payment
of $5,700.

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27. Documentation of financial hardship that Defendant is unable to pay the rent
pursuant to the lease and/or other agreements.

28. Documentation that Defendant could not find suitable permanent housing
because of one or more of the following: significant loss of household income during the
Covid-19 pandemic; increase in necessary out-of-pocket expenses related to performing
essential work or related to health impacts during the Covid-19 pandemic; childcare
responsibilities or responsibilities to care for an elderly, disabled, or sick family member
during the Covid-19 pandemic that have negatively affected Defendant’s ability or the
ability of someone in the household to obtain meaningful employment or earn income or
increased Defendants necessary out of pocket expenses; moving expenses and difficulty in
securing alternative housing.

29. Documentation that Covid-19 negatively affected Defendant’s ability to obtain
meaningful employment or earn income or have significantly reduced Defendants
household income or significantly increased Defendant’s expenses.

30. Tax returns for three years prior to April 2020 to date.

31. Duly executed authorizations entitling Plaintiffs to procure Defendant’s tax
returns for three years prior to April 2020 to present.

32. Duly executed authorizations entitling Plaintiffs to procure Defendant’s
employment records from April 2017 to present. Include on authorizations the name and
address of employers.

33. Documents indicating if Defendant did lose household income due to Covid-19
that he has had increased expenses that public assistance, unemployment insurance,
pandemic unemployment assistance, disability insurance, or paid family leave did not fully
make up for the loss of income or increased expenses.

34. Paystubs or other documents indicating the amount of payment and/or monies
received from public assistance, unemployment insurance pandemic unemployment
assistance, disability insurance, or paid family leave received by Defendant from April 2020
to present.

35. Documentation that Defendant and/or his daughter (resident relative) had a
significant health risk that increased their risk for severe illness or death from Covid-19
should either leave the apartment that is the subject of this lawsuit.

36. Documentation that the lease was reduced to a monthly rent of $4,000 per
month from January 2021 forward.

37. Documentation including, but not limited to emails, correspondence, written
complaints to Plaintiffs, the condominium board, superintendent, or any New York City
agency of lack of heat and/or hot water, insect infestation, poor window maintenance,

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water damage to ceilings, brown filthy water supply, rusty pipes, excessive noise, smoke
detector violations.

38. Documentation by physician(s) that Defendant and/or his teenage daughter
experienced negligent infliction of emotional distress and/or other health issues as a result
of lack of heat and/or hot water, insect infestation, poor window maintenance, water
damage to ceilings, brown filthy water supply, rusty pipes, excessive noise, smoke detector
violations.

39. Documentation of deceptive practices with the intent to defraud the Defendant
by Plaintiffs their agents, servants and/or employees.

40. Documents either written or via electronic or other means showing Defendant
applied to the appropriate agencies for rental assistance.

41. Documentation of complaints filed with the Department of Housing, Department
of Buildings and/or other agencies regarding issues/complaints of defects and or problems
as claimed in Defendant’s counterclaim.

42. Documents of violations against the building related to the apartment that is the
issue of this lawsuit.

43. Documents of eviction proceedings commenced by Plaintiffs against Defendant
for the apartment that is the basis of this lawsuit.

44. Documentation that in September 2019 Defendant informed Plaintiffs of
warranty of habitability issues regarding the premises that are the subject of this lawsuit.

45. Photographs depicting lack of heat, brown hot water, insect infestation, poor
window maintenance and/or damage, water damage to ceilings, brown filthy water supply,
rusty pipes, defective smoke detectors, peeling paint, floods and/or other damage
Defendant claims constituted a breach of the warranty of habitability.

46. Documentation including but not limited to emails, correspondence and/or texts
that Plaintiffs entered into an agreement to a reduced rent of $3,900.00 per month.

47. Any and all tape-recorded statements, phone calls or other recordings between
Plaintiffs and Defendant.

48. The email allegedly sent on November 22, 2021as claimed in Defendant’s
counterclaim Paragraph number 10.

49. Documentation that on January 5, 2021 Plaintiffs offered Defendant six (6)
months free rent in the amount of $33,900.00 as well as Plaintiffs alleged comments to
make repairs and extend the lease from January 2021 to December 2021 at a monthly rate
of $4,500.

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50. Documentation that Defendant accepted the alleged offer Defendant claims
Plaintiffs extended as described more fully in this demand, item number 49, and
Paragraphs 14 & 15 of Defendants Counterclaim.

51. Produce the writing as set forth in Defendant’s counterclaim Paragraph 23
whereby Defendant alleges Plaintiffs harassed Defendant in an email dated March 31, 2021.

52. Any and all documents and/or recordings pertaining to communication
between ELAINE CHOY LEE and defendant and/or his daughter.

53. Any and all documents and or recordings pertaining to communication between
CHUCK W. LEE and defendant and/or his daughter.

54. Any and all documents and or recordings pertaining to communication between
Defendant and any and all Superintendent (s).

55. Any and all documents and/or recordings pertaining to communication
between Defendant and any and all members of the Board/HOA.

56. All pleadings, affidavits, and motions served or filed in any proceeding brought
against Defendant regarding the apartment that is the subject of this lawsuit or brought in
New York State or New York City.

57. All transcripts of Defendant’s sworn testimony in any lawsuit since January 1,
2015 through present.

58. All correspondence between Defendant and any third party pertaining to the
Building/Apartment that is the subject of this lawsuit. In the event any such
correspondence is privileged, such correspondence must be identified and described as
provided in the Instructions set forth above.

59. Any and all documents pertaining to violations of New York City or New York
State housing code or other building, health or construction-related violations for the
applicable time period, including but not limited to:

1. New York City Department of Buildings violations;
2. New York City Environmental Control Board violations;
3. New York City Housing Preservation and Development violations;
4. New York State Division of Housing and Community Renewal violations;
5. New York City Housing Quality Standards violations.

60. Any and all documents Defendant filed regarding the Building/Apartment with:

1. New York City Department of Buildings;
2. New York City Environmental Control Board;
3. New York City Housing Preservation and Development;

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4. New York State Division of Housing and Community Renewal;
5. New York City Housing Authority;
6. Mayor’s Office of Criminal Justice – Office of Special Enforcement;
7. New York City Alternative Enforcement Program;
8. New York City Fire Department;
9. New York City Police Department.

61. Any and all documents pertaining to the Building/Apartment at issue including but
not limited to complaints made to city or state agencies listed above in item 60, pertaining
to:

a. noise level;

b. construction;

c. water damage;

d. smoke detectors;

e. debris;

f. leaks and floods;

g. paint;

h. floors;

i. inoperable appliance(s) including but not limited to heat and hot water;

j. ceiling damage;

k. bug infestation and extermination

l. complaints to the Superintendent or other agents, employees, or Plaintiffs

m. property damage;

62. Any and all documents relating to requests for access to the apartment by Plaintiffs,
their agents, servants and/or employees or any governmental agency, including but not
limited to, those agencies listed in item 60.

63. Any and all reports, assessments, and descriptions of conditions pertaining to the
Building/Apartment at issue.

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64. Any and all documents pertaining to apartment for improvements/repairs including
repairs to the ceiling and extermination services from the date of the original lease to
present.

65. Any and all documents pertaining to broker’s fees, or “legal fees” paid by Defendant.

By: Lee Heit, Esq.

LEE HEIT, ATTORNEY AT LAW PC
1166 Carll’s Straight Path
Dix Hills, NY 11746
(631) 586-2832

Dated: Dix Hills, NY
July 20, 2021

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------------X Index Number:
ELAINE CHOY LEE and CHUCK W. LEE, 65336/2021

Plaintiffs, INTERROGATORIES

-against-

ALEXENDER BEHRENS,

Defendant.
------------------------------------------------------------------------X

PLEASE TAKE NOTICE that pursuant to CPLR 3130, Plaintiffs, by their attorney, LEE HEIT,

ATTORNEY AT LAW PC serves Plaintiff’s First Set of Interrogatories (“Plaintiffs’ First Set”)

upon ALEXANDER BEHRENS, and request that Defendant answers Plaintiffs’ First Set

within twenty days, or as otherwise stipulated by the parties or ordered by the Court, in

accordance with the following definitions and instruction as set forth below, in accordance

with the following definitions and instruction as set forth below, to LEE HEIT, ATTORNEY

AT LAW, PC 1166 Carll’s Straight Path, Dix Hills, New York 11746.

DEFINITIONS

Case Info

Judge

Richard G. Latin Track Judge’s New Case

Case No.

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Document Filed Date

July 20, 2021

Case Filing Date

May 24, 2021

County

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Party Notice: Elaine Choy Lee, Chuck W Lee v. Alexander Behrens

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Case Info

Parties