On May 03, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Anis I. Muktar,
and
David P. Etling,
Integrated Computer Solutions Of Vestal Llc,
for Torts - Motor Vehicle
in the District Court of Onondaga County.
Preview
FILED: ONONDAGA COUNTY CLERK 07/06/2022 09:27 AM INDEX NO. 004181/2021
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 07/06/2022
William
Mattar IAWOTFICES
6 72 O M A I N STREET, SUITE 100, WIL L I AMSVIL LE, NEW YORK 14221 " (716) 633-3535
May 5, 2022
Lauren M. Miller, Esq.
Kenney, Shelton, Liptak, Nowak, LLP
4615 North Street
Jamesville, NY 13078
Re: Muktar v. Etling, et. al.
Index No: 004181/2021
Dear Ms. Miller:
Enclosed please find Plaintiffs Notice to Produce regarding the above-captioned action. Thank
you for your attention to this matter.
Very truly yours,
WILLIAM MATTAR, P.C.
/s/Arienne J. Irving, Esq.
AJI: en
Enclosure
SERVICING: BUFFALO " ROCHESTER " SYRACUSE " ALBANY " UTICA " BINGHAMTON " LONG ISLAND * NEW YORK CITY " PHILADELPHIA, PA
EMAIL: WILLIAM@WILLIAMMATTAR.COM
FILED: ONONDAGA COUNTY CLERK 07/06/2022 09:27 AM INDEX NO. 004181/2021
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 07/06/2022
STATE OF NEW YORK
SUPREME COURT: COUNTY OF ONONDAGA
ANIS I. MUKTAR,
Plaintiff
v.
NOTICE TO PRODUCE
Index No.: 004181/2021
INTEGRATED COMPUTER SOLUTIONS OF
VESTAL LLC
DAVID P. ETLING
Defendants
PLEASE TAKE NOTICE that the above-named Plaintiff hereby demands, pursuant to
CPLR 3101, the following materials be produced for discovery and inspection within twenty (20)
days of the service hereof at the office of the undersigned attorney:
In that Defendant, DAVID P. ETLING, is claiming a medical emergency at the time of
the subject motor vehicle collision, Plaintiff demands the following:
1. That Defendant furnish Plaintiff with the name and address of his primary care
physician;
2. An authorization for Defendant's primary care physician unlimited in scope and
time;
3. The names of any medical providers consulted by the Defendant following the
subject motor vehicle collision and authorizations for same;
4. Any and all medical documentation provided to Defendant INTEGRATED
COMPUTER SOLUTIONS OF VESTAL LLC regarding the alleged medical
condition that caused the alleged medical emergency; and,
5. Any and all internal reports regarding Defendant's medical condition
company
and/or the subject collision in the possession of Defendant, INTEGRATED
COPMUTER SOLUTIONS OF VESTAL, LLC.
FILED: ONONDAGA COUNTY CLERK 07/06/2022 09:27 AM INDEX NO. 004181/2021
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 07/06/2022
PLEASE TAKE FURTHER NOTICE that all demands contained herein are
continuing demands up to and including the time of Trial. Any items obtained after service of
this demand are to be furnished to this office within ten (10) days of your receipt thereof.
PLEASE TAKE FURTHER NOTICE that if you fail to comply with this Notice for
Discovery and Inspection, or any part thereof, we shall rely on all sanctions provided under law.
DATED: May 5, 2022 /s/Arienne J. Irving
Arienne J. Irving, Esq.
WILLIAM MATTAR, P.C.
Attorneys for Plaintiff
Office and Post Office Address
6720 Main Street, Suite 100
Williamsville, New York 14221-5986
(716) 633-3535
TO: Lauren M. Miller, Esq.
Kenney, Shelton, Liptak, Nowak, LLP
Attorneys for Defendants
INTEGRATED COMPUTER SOLUTIONS OF VESTAL, LLC
DAVID P. ETLING
Office and Post Office Address
4615 North Street
Jamesville, New York 13078
(315) 492-3000
Document Filed Date
July 06, 2022
Case Filing Date
May 03, 2021
Category
Torts - Motor Vehicle
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Preview
FILED: ONONDAGA COUNTY CLERK 07/06/2022 09:27 AM INDEX NO. 004181/2021 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 07/06/2022 William Mattar IAWOTFICES 6 72 O M A I N STREET, SUITE 100, WIL L I AMSVIL LE, NEW YORK 14221 " (716) 633-3535 May 5, 2022 Lauren M. Miller, Esq. Kenney, Shelton, Liptak, Nowak, LLP 4615 North Street Jamesville, NY 13078 Re: Muktar v. Etling, et. al. Index No: 004181/2021 Dear Ms. Miller: Enclosed please find Plaintiffs Notice to Produce regarding the above-captioned action. Thank you for your attention to this matter. Very truly yours, WILLIAM MATTAR, P.C. /s/Arienne J. Irving, Esq. AJI: en Enclosure SERVICING: BUFFALO " ROCHESTER " SYRACUSE " ALBANY " UTICA " BINGHAMTON " LONG ISLAND * NEW YORK CITY " PHILADELPHIA, PA EMAIL: WILLIAM@WILLIAMMATTAR.COM FILED: ONONDAGA COUNTY CLERK 07/06/2022 09:27 AM INDEX NO. 004181/2021 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 07/06/2022 STATE OF NEW YORK SUPREME COURT: COUNTY OF ONONDAGA ANIS I. MUKTAR, Plaintiff v. NOTICE TO PRODUCE Index No.: 004181/2021 INTEGRATED COMPUTER SOLUTIONS OF VESTAL LLC DAVID P. ETLING Defendants PLEASE TAKE NOTICE that the above-named Plaintiff hereby demands, pursuant to CPLR 3101, the following materials be produced for discovery and inspection within twenty (20) days of the service hereof at the office of the undersigned attorney: In that Defendant, DAVID P. ETLING, is claiming a medical emergency at the time of the subject motor vehicle collision, Plaintiff demands the following: 1. That Defendant furnish Plaintiff with the name and address of his primary care physician; 2. An authorization for Defendant's primary care physician unlimited in scope and time; 3. The names of any medical providers consulted by the Defendant following the subject motor vehicle collision and authorizations for same; 4. Any and all medical documentation provided to Defendant INTEGRATED COMPUTER SOLUTIONS OF VESTAL LLC regarding the alleged medical condition that caused the alleged medical emergency; and, 5. Any and all internal reports regarding Defendant's medical condition company and/or the subject collision in the possession of Defendant, INTEGRATED COPMUTER SOLUTIONS OF VESTAL, LLC. FILED: ONONDAGA COUNTY CLERK 07/06/2022 09:27 AM INDEX NO. 004181/2021 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 07/06/2022 PLEASE TAKE FURTHER NOTICE that all demands contained herein are continuing demands up to and including the time of Trial. Any items obtained after service of this demand are to be furnished to this office within ten (10) days of your receipt thereof. PLEASE TAKE FURTHER NOTICE that if you fail to comply with this Notice for Discovery and Inspection, or any part thereof, we shall rely on all sanctions provided under law. DATED: May 5, 2022 /s/Arienne J. Irving Arienne J. Irving, Esq. WILLIAM MATTAR, P.C. Attorneys for Plaintiff Office and Post Office Address 6720 Main Street, Suite 100 Williamsville, New York 14221-5986 (716) 633-3535 TO: Lauren M. Miller, Esq. Kenney, Shelton, Liptak, Nowak, LLP Attorneys for Defendants INTEGRATED COMPUTER SOLUTIONS OF VESTAL, LLC DAVID P. ETLING Office and Post Office Address 4615 North Street Jamesville, New York 13078 (315) 492-3000