Preview
FILED: BRONX COUNTY CLERK 02/18/2023 11:19 AM INDEX NO. 807931/2021E
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/18/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
PLAINTIFF'S
MARIA DE BOBADILLA MASSIEL, VERIFIED
SUPPLEMENTAL
Plaintiff(s), BILL OF
-against-
PARTICULARS
DAVID FELlZVALENTINE, STEVEN E RODRIGUEZ and Index #
EDWARD R RODRIGUEZ, 807931/2021E
Defendant(s).
Plaintiff, by her attorneys, Law Offices of Paul Bryan Schneider, P.C., pursuant to the
demands of the Defendants, DAVID FELIZVALENTINE, STEVEN E RODRIGUEZ and
EDWARD R RODRIGUEZ as and for her Verified Bill of Particulars, respectfully sets forth,
upon information and belief, as follows:
1. The accident occurred on December 25, 2020, at approximately 1:45 p.m.
2. The accident occurred on Jerome Avenue approximately 25 feet south of
Shakespeare Avenue, Bronx, New York.
3. Defendants were careless, reckless and negligent in failing to properly own,
Defendants'
operate, manage, maintain, supervise and control vehicles; in failing
to maintain a proper lookout; in failing to give any signal or warning of approach:
in failing to avoid the collision herein although Defendants had a full opportunity to
Defendants'
avoid same; in permitting and allowing motor vehicles to be driven in
an inattentive and non-alert manner; in failing to take appropriate evasive action;
in failing to see that which was there to be seen; in failing to properly follow
established procedures; in failing to observe and heed road and traffic controls and
conditions; in failing to timely observe other motor vehicles; in failing to operate,
Defendants'
manage, maintain and control motor vehicles at a proper and
reasonable rate of speed and proper distance from the vehicle Plaintiff was
Defendants'
occupying and/or from other motor vehicles; in operating motor
vehicles at a fast and excessive rate of speed; in failing to make proper, prompt
and timely use of the brakes, horn, mirrors, warning device, steering apparatus
Defendants'
and other equipment, parts and accessories of motor vehicles; in
failing to properly inspect, service, repair and maintain the brakes, horn, warning
devices, mirrors, steering apparatus and other equipment, parts and accessories
Defendants'
of motor vehicles; in causing the vehicles to come into contact and
cause injury to Plaintiff; in failing to yield right of way; in failing to timely and
properly utilize directional signals; in failing to timely and properly utilize mirrors; in
failing to keep a proper lookout; in failing to exercise a degree of care and caution
which reasonable, prudent person would have exercised under similar
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circumstances; in being liable under the doctrines of res ipsa loquitar and
respondeat superior; in suddenly, and without any prior warning or sign,
Defendants'
automobiles struck each other (one of the vehicles was occupied by
Plaintiff) in a violent manner in the lane in which the vehicle occupied by Plaintiff
was traveling; in failing to properly change lanes; in general, operating the vehicles
Defendants'
of the in such a careless and negligent manner as to cause the
happening of the accident complained of, and failing to use adequate and sufficient
care, caution and precautions to prevent the happening of the accident complained
of; and in violating the applicable statutes, regulations, rules and ordinances of the
State of New York and its municipal subdivisions.
4. The vehicle operated/owned by Defendant David FELIZVALENTINE was struck in
the rear by the front end of the vehicle owned/operated by Defendants Steven and
Edward Rodriguez. Plaintiff was a passenger in Defendant David
FELIZVALENTINE's vehicle. Accordingly, there is no claim for property damage.
5. Objection. The requested information is not applicable, irrelevant and/or unknown
by Plaintiff. Plaintiff was a passenger in a hired vehicle and has no knowledge as
to the market value of the vehicle she occupied. Based upon the police report, the
vehicle occupied by Plaintiff was a 2013 Toyota taxi bearing NY Plate T695071C.
a. Plaintiff MARIA DE BOBADILLA MASSIEL, sustained serious and severe
personal injuries which were caused, created, precipitated and/or accelerated
by the subject accident including, but not limited to, the following:
LIST OF INJURIES - WILL BE AMENDED/SUPPLEMENTED UPON RECEIPT
OF COMPLETE AND/OR UPDATED MEDICAL RECORDS FROM TREATING
PHYSICIANS. THE RECORDS HAVE BEEN REQUESTED.
" MRI of Cervical Spine 24, 2023 American Medical Initiatives
January
o C4-5 - broad-based central disc herniation is present in
resulting
compression of the ventral CSF space. Narrowing of right neural
foramen.
o Straightening of cervical lordosis
" MRI of Thoracic Spine January 31, 2023 American Medical Initiatives
o T4-5 broad-based central/left paracentral disc herniation is
present resulting in compression and impingement upon the
ventral CSF space. Narrowing of left neural foramen.
" Acute Concussion
" Head trauma/pain
" Reversal of cervical lordosis with apex at C4
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" Cervical sprain/strain
" Cervicalgia/neck pain
" Thoracic sprain/strain
" Thoracalgia/neck pain
" Lumbar sprain/strain
" Lumbaigia/back pain
" Bilateral internal derangement/sprain/strain of bilateral shoulders
" Bilateral shoulder pain
" Bilateral hand pain/loss of strength
" Bilateral pain/loss of strength
leg
" Bilateral foot and pain
cramping
" Headaches
" Nausea
"
Anxiety
" Stress
" insomnia
" Photophobia - eyes feel and sensitive to light
heavy
Plaintiff required extensive treatment including, but not limited to, Orthopaedic
care, pain management, neurologic care, chiropractic care, acupuncture care,
physical therapy and diagnostic testing as well as the use of medical supplies
including, but not limited to, the following: hot/cold packs, deep tissue massager,
egg crate mattress and/or orthopaedic pillow. Plaintiff also required medications
including, but not limited to, the following: Lidocaine 5% ointment, Naproxen and
Flexeril as well as over the counter pain relievers and anti-inflammatories including
NSAIDS.
Plaintiff was asymptomatic as to condition that have pre-
any underlying may
existed the accident; if such condition did exist, this incident aggravated and/or
exacerbated the same.
Additionally, in the event that the injuries to Plaintiff were superimposed upon any
pre-existing conditions which may have contributed to the extend and severity of
the Plaintiff's injuries and rendered Plaintiff more prone or susceptible to further
injury, then such pre-existing conditions or susceptibility, if any,·were aggravated,
activated, precipitated, accelerated and acted upon by the injuries sustained by
Plaintiff in the subject occurrence.
AII of the above conditions of the Plaintiff are accompanied by pain, swelling,
tenderness, deformity, inflammation, discoloration, stiffness, weakness, fatigue,
atrophy, scarring, numbness, spasms, sensitivity changes, limitation and
restriction of motion and use, with damage, traumatic derangement, injury and both
present and future degeneration to bones, muscles, ligaments, cartilage, tendons,
nerves, blood vessels, organs and soft tissues in and about the aforedescribed
areas as well as to the nervous system, muscle system, skeletal system and
digestive system.
AII of the aforesaid injuries and their sequela are of a chronic and protracted nature
which will have permanent residual effects and which manifested or will manifest
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permanent sequela and to that extent the Plaintiff expressly reserves the right to
prove upon trial thereof, any and all sequela and/or residuals which have
manifested themselves prior to the time of trial therein.
Plaintiff further reserves the right to prove upon the trial thereof any and all damage
or injury to the surrounding tissues, ligaments, blood vessels, muscles and nerves
and supportive structure and to prove the type and nature of all of the treatment
rendered because of the injuries as set forth above.
These injuries aggravated, activated and/or precipitated any underlying
hypertrophic degeneration, arthritic, circulatory, arterial, venous or systemic
conditions complained of.
AII of the above injuries and conditions described hereinabove for Plaintiff are
permanent in nature and effect, except those of a superficial nature.
6. Length time confined
a. Hospital - Plaintiff was confined to the room department located
emergency
168th
NY Presbyterian/Columbia Hospital, 622 West Street, New York, New
York 10032.
b. Bed - Plaintiff was confined to bed from the date of the accident for
one hundred days and non-
approximately twenty (120) intermittently
continuously and continues to date, intermittently.
c. Home - Plaintiff was confined to home from the date of the date of the accident
for one hundred days and non-
approximately twenty (120) intermittently
continuously and continues to date, intermittently.
7. The length of time Plaintiff was incapacitated from employment will be provided, if
applicable. Plaintiff was incapacitated from household duties from the date of the
accident for one hundred days and non-
approximately twenty (120) intermittently
continuously and continues to date, intermittently. Plaintiff is not a student.
8. Special damages - as all medical and records have not yet been
billing received,
please note that all amounts are approximate and subject to amendment pending
receipt of previously requested medical/billing records and/or future medical/billing
records
a. Physician's services $38,400.00
b. Medical supplies $ 1,249.00
c. Loss of earnings will be provided, if applicable.
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Nurses'
d. services included in 8e below
e. Hospital expenses $ 6,600.00
f. X-rays/MRIs expenses $ 10,000.00
g. Any other items special damage will be provided, if applicable.
h. Name address employer at time of accident - if applicable. Plaintiff is not self-
employed and Plaintiff is not a student.
9. Plaintiff sustained serious personal injuries as defined by Section 5102(d) which
means personal injuries that results in death; dismemberment; significant
disfigurement; a fracture; loss of a fetus; permanent loss of use of a body organ,
member, function or system; permanent consequential limitation of use of a body
organ or member; significant limitation of use of a body function or system; or a
medically determined injury or impairment of a non-permanent nature which
prevents the injured person from performing substantially all of the material acts
which constitute such person's usual and customary daily activities for not less
than ninety days during the one hundred eighty days immediately following the
occurrence of the injury or impairment. Information regarding economic loss
greater than basic economic loss as defined in subdivision (a) of 5102 of the
Insurance Law will be provided, if applicable.
10. Negligent entrustment is not being claimed at this time. Plaintiff reserves the right
to supplement her response to this demand upon completion of all discovery
but not limited the examinations before trial of all parties and/or non-
including, to,
party witnesses.
11. Presently not applicable. See response to item 10, above.
12. Information regarding any prior knowledge of some propensity to be alleged by
Defendants'
Plaintiff in regard to the operation of the vehicle will be provided, if
applicable; upon completion of all discovery including examinations before trial of
all parties and non-party witnesses.
13. The total amount of damages for which Plaintiff deems herself entitled is
$10,000,000.00.
14. Objection. Duplicative. See response to item 13, above.
15. Each category of damages and amounts demanded in each category will be
provided upon completion of Plaintiff's medical treatment and care. As Plaintiff
continues to treat and will require additional medical treatment and possible
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surgical intervention Plaintiff is unable to speculate on the amounts demanded for
each category. Plaintiff reserves his right to supplement his response to this
demand up to and including the time of trial.
16. The Court will take judicial notice, at the time of trial, of each and every section of
each and every statute, regulation, ordinance, rule, order and requirement of the
Federal State County Village Town or City government of any and all of their
departments divisions and bureaus it is alleged was violated by Defendants.
17. Information regarding each act and/or omission it will be claimed was committed
by the Defendants will be provided upon completion of all discovery, including, but
not limited to, examinations before trial of all parties. Additionally, see response
to item 16, above.
Please Take Notice, that the Plaintiff hereby reserve her rights to supplement
and/or amend her responses to this demand up to and including the time of trial.
Dated: Melville, New York
February 17, 2023
Paul B n chneider, Es
LAW O FI ES OF
PAUL Y N SCHNElDER, P.C.
Attome s r Plaintiff(s)
MARIA BOBADILLA MASSIEL
225 Bro Hollow Road, Suite 102
Melville, Y 11747
631-777-3519
Paul@LawSchneid.com
To:
Annmarie Webster, Esq. Ronit Z. Moskovits, Esq.
LAW OFFICE OF JOHN TROP BAKER, McEVOY & MOSKOVITS, PC
Attorney for Defendants Attorneys for Defendant(s)
STEVEN E RODRIGUEZ and EDWARD DAVID FELIZVALENTINE
R RODRIGUEZ 1 Metrotech Center, 8th Floor
120 White Plains Road, Suite 200 Brooklyn, NY 11201
Tarrytown NY 10591 212-857-8230
914-620-0029 File: 1081248
File: 0614156495.1- Case ID: 1177000
nyuefilinq@allstate.com eservice@bm3Iaw.com
rmoskovits@bm3law.com
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ATTORNEY VERIFICATION
PAUL B. SCHNEIDER, ESQ., an attorney duly admitted to practice before the
Courts of this State, affirms the following to be true under the penalties of perjury:
That I am a member of The Law Offices of Paul Bryan Schneider, P.C., attorney for
the plaintiff contents thereof, and that upon information and belief, believe the matters
alleged therein to be true.
The reason this verification is made by deponent and not by plaintiff is that plaintiff
lives in a County other than the one in which plaintiff's attorneys maintain their office.
The source of deponent's information and the grounds of my belief are
communications, papers, reports and investigations contained in this file; that I have read
the foregoing Plaintiff's Verified Bill of Particulars and know the contents herein.
Dated: Melville, New York
February 17, 2023
P u Bryan Schnei , Esq.
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Preview
FILED: BRONX COUNTY CLERK 02/18/2023 11:19 AM INDEX NO. 807931/2021E NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/18/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX PLAINTIFF'S MARIA DE BOBADILLA MASSIEL, VERIFIED SUPPLEMENTAL Plaintiff(s), BILL OF -against- PARTICULARS DAVID FELlZVALENTINE, STEVEN E RODRIGUEZ and Index # EDWARD R RODRIGUEZ, 807931/2021E Defendant(s). Plaintiff, by her attorneys, Law Offices of Paul Bryan Schneider, P.C., pursuant to the demands of the Defendants, DAVID FELIZVALENTINE, STEVEN E RODRIGUEZ and EDWARD R RODRIGUEZ as and for her Verified Bill of Particulars, respectfully sets forth, upon information and belief, as follows: 1. The accident occurred on December 25, 2020, at approximately 1:45 p.m. 2. The accident occurred on Jerome Avenue approximately 25 feet south of Shakespeare Avenue, Bronx, New York. 3. Defendants were careless, reckless and negligent in failing to properly own, Defendants' operate, manage, maintain, supervise and control vehicles; in failing to maintain a proper lookout; in failing to give any signal or warning of approach: in failing to avoid the collision herein although Defendants had a full opportunity to Defendants' avoid same; in permitting and allowing motor vehicles to be driven in an inattentive and non-alert manner; in failing to take appropriate evasive action; in failing to see that which was there to be seen; in failing to properly follow established procedures; in failing to observe and heed road and traffic controls and conditions; in failing to timely observe other motor vehicles; in failing to operate, Defendants' manage, maintain and control motor vehicles at a proper and reasonable rate of speed and proper distance from the vehicle Plaintiff was Defendants' occupying and/or from other motor vehicles; in operating motor vehicles at a fast and excessive rate of speed; in failing to make proper, prompt and timely use of the brakes, horn, mirrors, warning device, steering apparatus Defendants' and other equipment, parts and accessories of motor vehicles; in failing to properly inspect, service, repair and maintain the brakes, horn, warning devices, mirrors, steering apparatus and other equipment, parts and accessories Defendants' of motor vehicles; in causing the vehicles to come into contact and cause injury to Plaintiff; in failing to yield right of way; in failing to timely and properly utilize directional signals; in failing to timely and properly utilize mirrors; in failing to keep a proper lookout; in failing to exercise a degree of care and caution which reasonable, prudent person would have exercised under similar 1 of 9 FILED: BRONX COUNTY CLERK 02/18/2023 11:19 AM INDEX NO. 807931/2021E NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/18/2023 circumstances; in being liable under the doctrines of res ipsa loquitar and respondeat superior; in suddenly, and without any prior warning or sign, Defendants' automobiles struck each other (one of the vehicles was occupied by Plaintiff) in a violent manner in the lane in which the vehicle occupied by Plaintiff was traveling; in failing to properly change lanes; in general, operating the vehicles Defendants' of the in such a careless and negligent manner as to cause the happening of the accident complained of, and failing to use adequate and sufficient care, caution and precautions to prevent the happening of the accident complained of; and in violating the applicable statutes, regulations, rules and ordinances of the State of New York and its municipal subdivisions. 4. The vehicle operated/owned by Defendant David FELIZVALENTINE was struck in the rear by the front end of the vehicle owned/operated by Defendants Steven and Edward Rodriguez. Plaintiff was a passenger in Defendant David FELIZVALENTINE's vehicle. Accordingly, there is no claim for property damage. 5. Objection. The requested information is not applicable, irrelevant and/or unknown by Plaintiff. Plaintiff was a passenger in a hired vehicle and has no knowledge as to the market value of the vehicle she occupied. Based upon the police report, the vehicle occupied by Plaintiff was a 2013 Toyota taxi bearing NY Plate T695071C. a. Plaintiff MARIA DE BOBADILLA MASSIEL, sustained serious and severe personal injuries which were caused, created, precipitated and/or accelerated by the subject accident including, but not limited to, the following: LIST OF INJURIES - WILL BE AMENDED/SUPPLEMENTED UPON RECEIPT OF COMPLETE AND/OR UPDATED MEDICAL RECORDS FROM TREATING PHYSICIANS. THE RECORDS HAVE BEEN REQUESTED. " MRI of Cervical Spine 24, 2023 American Medical Initiatives January o C4-5 - broad-based central disc herniation is present in resulting compression of the ventral CSF space. Narrowing of right neural foramen. o Straightening of cervical lordosis " MRI of Thoracic Spine January 31, 2023 American Medical Initiatives o T4-5 broad-based central/left paracentral disc herniation is present resulting in compression and impingement upon the ventral CSF space. Narrowing of left neural foramen. " Acute Concussion " Head trauma/pain " Reversal of cervical lordosis with apex at C4 2 of 9 FILED: BRONX COUNTY CLERK 02/18/2023 11:19 AM INDEX NO. 807931/2021E NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/18/2023 " Cervical sprain/strain " Cervicalgia/neck pain " Thoracic sprain/strain " Thoracalgia/neck pain " Lumbar sprain/strain " Lumbaigia/back pain " Bilateral internal derangement/sprain/strain of bilateral shoulders " Bilateral shoulder pain " Bilateral hand pain/loss of strength " Bilateral pain/loss of strength leg " Bilateral foot and pain cramping " Headaches " Nausea " Anxiety " Stress " insomnia " Photophobia - eyes feel and sensitive to light heavy Plaintiff required extensive treatment including, but not limited to, Orthopaedic care, pain management, neurologic care, chiropractic care, acupuncture care, physical therapy and diagnostic testing as well as the use of medical supplies including, but not limited to, the following: hot/cold packs, deep tissue massager, egg crate mattress and/or orthopaedic pillow. Plaintiff also required medications including, but not limited to, the following: Lidocaine 5% ointment, Naproxen and Flexeril as well as over the counter pain relievers and anti-inflammatories including NSAIDS. Plaintiff was asymptomatic as to condition that have pre- any underlying may existed the accident; if such condition did exist, this incident aggravated and/or exacerbated the same. Additionally, in the event that the injuries to Plaintiff were superimposed upon any pre-existing conditions which may have contributed to the extend and severity of the Plaintiff's injuries and rendered Plaintiff more prone or susceptible to further injury, then such pre-existing conditions or susceptibility, if any,·were aggravated, activated, precipitated, accelerated and acted upon by the injuries sustained by Plaintiff in the subject occurrence. AII of the above conditions of the Plaintiff are accompanied by pain, swelling, tenderness, deformity, inflammation, discoloration, stiffness, weakness, fatigue, atrophy, scarring, numbness, spasms, sensitivity changes, limitation and restriction of motion and use, with damage, traumatic derangement, injury and both present and future degeneration to bones, muscles, ligaments, cartilage, tendons, nerves, blood vessels, organs and soft tissues in and about the aforedescribed areas as well as to the nervous system, muscle system, skeletal system and digestive system. AII of the aforesaid injuries and their sequela are of a chronic and protracted nature which will have permanent residual effects and which manifested or will manifest 3 of 9 FILED: BRONX COUNTY CLERK 02/18/2023 11:19 AM INDEX NO. 807931/2021E NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/18/2023 permanent sequela and to that extent the Plaintiff expressly reserves the right to prove upon trial thereof, any and all sequela and/or residuals which have manifested themselves prior to the time of trial therein. Plaintiff further reserves the right to prove upon the trial thereof any and all damage or injury to the surrounding tissues, ligaments, blood vessels, muscles and nerves and supportive structure and to prove the type and nature of all of the treatment rendered because of the injuries as set forth above. These injuries aggravated, activated and/or precipitated any underlying hypertrophic degeneration, arthritic, circulatory, arterial, venous or systemic conditions complained of. AII of the above injuries and conditions described hereinabove for Plaintiff are permanent in nature and effect, except those of a superficial nature. 6. Length time confined a. Hospital - Plaintiff was confined to the room department located emergency 168th NY Presbyterian/Columbia Hospital, 622 West Street, New York, New York 10032. b. Bed - Plaintiff was confined to bed from the date of the accident for one hundred days and non- approximately twenty (120) intermittently continuously and continues to date, intermittently. c. Home - Plaintiff was confined to home from the date of the date of the accident for one hundred days and non- approximately twenty (120) intermittently continuously and continues to date, intermittently. 7. The length of time Plaintiff was incapacitated from employment will be provided, if applicable. Plaintiff was incapacitated from household duties from the date of the accident for one hundred days and non- approximately twenty (120) intermittently continuously and continues to date, intermittently. Plaintiff is not a student. 8. Special damages - as all medical and records have not yet been billing received, please note that all amounts are approximate and subject to amendment pending receipt of previously requested medical/billing records and/or future medical/billing records a. Physician's services $38,400.00 b. Medical supplies $ 1,249.00 c. Loss of earnings will be provided, if applicable. 4 of 9 FILED: BRONX COUNTY CLERK 02/18/2023 11:19 AM INDEX NO. 807931/2021E NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/18/2023 Nurses' d. services included in 8e below e. Hospital expenses $ 6,600.00 f. X-rays/MRIs expenses $ 10,000.00 g. Any other items special damage will be provided, if applicable. h. Name address employer at time of accident - if applicable. Plaintiff is not self- employed and Plaintiff is not a student. 9. Plaintiff sustained serious personal injuries as defined by Section 5102(d) which means personal injuries that results in death; dismemberment; significant disfigurement; a fracture; loss of a fetus; permanent loss of use of a body organ, member, function or system; permanent consequential limitation of use of a body organ or member; significant limitation of use of a body function or system; or a medically determined injury or impairment of a non-permanent nature which prevents the injured person from performing substantially all of the material acts which constitute such person's usual and customary daily activities for not less than ninety days during the one hundred eighty days immediately following the occurrence of the injury or impairment. Information regarding economic loss greater than basic economic loss as defined in subdivision (a) of 5102 of the Insurance Law will be provided, if applicable. 10. Negligent entrustment is not being claimed at this time. Plaintiff reserves the right to supplement her response to this demand upon completion of all discovery but not limited the examinations before trial of all parties and/or non- including, to, party witnesses. 11. Presently not applicable. See response to item 10, above. 12. Information regarding any prior knowledge of some propensity to be alleged by Defendants' Plaintiff in regard to the operation of the vehicle will be provided, if applicable; upon completion of all discovery including examinations before trial of all parties and non-party witnesses. 13. The total amount of damages for which Plaintiff deems herself entitled is $10,000,000.00. 14. Objection. Duplicative. See response to item 13, above. 15. Each category of damages and amounts demanded in each category will be provided upon completion of Plaintiff's medical treatment and care. As Plaintiff continues to treat and will require additional medical treatment and possible 5 of 9 FILED: BRONX COUNTY CLERK 02/18/2023 11:19 AM INDEX NO. 807931/2021E NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/18/2023 surgical intervention Plaintiff is unable to speculate on the amounts demanded for each category. Plaintiff reserves his right to supplement his response to this demand up to and including the time of trial. 16. The Court will take judicial notice, at the time of trial, of each and every section of each and every statute, regulation, ordinance, rule, order and requirement of the Federal State County Village Town or City government of any and all of their departments divisions and bureaus it is alleged was violated by Defendants. 17. Information regarding each act and/or omission it will be claimed was committed by the Defendants will be provided upon completion of all discovery, including, but not limited to, examinations before trial of all parties. Additionally, see response to item 16, above. Please Take Notice, that the Plaintiff hereby reserve her rights to supplement and/or amend her responses to this demand up to and including the time of trial. Dated: Melville, New York February 17, 2023 Paul B n chneider, Es LAW O FI ES OF PAUL Y N SCHNElDER, P.C. Attome s r Plaintiff(s) MARIA BOBADILLA MASSIEL 225 Bro Hollow Road, Suite 102 Melville, Y 11747 631-777-3519 Paul@LawSchneid.com To: Annmarie Webster, Esq. Ronit Z. Moskovits, Esq. LAW OFFICE OF JOHN TROP BAKER, McEVOY & MOSKOVITS, PC Attorney for Defendants Attorneys for Defendant(s) STEVEN E RODRIGUEZ and EDWARD DAVID FELIZVALENTINE R RODRIGUEZ 1 Metrotech Center, 8th Floor 120 White Plains Road, Suite 200 Brooklyn, NY 11201 Tarrytown NY 10591 212-857-8230 914-620-0029 File: 1081248 File: 0614156495.1- Case ID: 1177000 nyuefilinq@allstate.com eservice@bm3Iaw.com rmoskovits@bm3law.com 6 of 9 FILED: BRONX COUNTY CLERK 02/18/2023 11:19 AM INDEX NO. 807931/2021E NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/18/2023 ATTORNEY VERIFICATION PAUL B. SCHNEIDER, ESQ., an attorney duly admitted to practice before the Courts of this State, affirms the following to be true under the penalties of perjury: That I am a member of The Law Offices of Paul Bryan Schneider, P.C., attorney for the plaintiff contents thereof, and that upon information and belief, believe the matters alleged therein to be true. The reason this verification is made by deponent and not by plaintiff is that plaintiff lives in a County other than the one in which plaintiff's attorneys maintain their office. The source of deponent's information and the grounds of my belief are communications, papers, reports and investigations contained in this file; that I have read the foregoing Plaintiff's Verified Bill of Particulars and know the contents herein. Dated: Melville, New York February 17, 2023 P u Bryan Schnei , Esq. 7 of 9 FILED: BRONX COUNTY CLERK 02/18/2023 11:19 AM INDEX NO. 807931/2021E NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/18/2023