On October 01, 2018 a
Party Notice
was filed
involving a dispute between
Marthe Milius,
and
Isabelle Charles,
for Torts - Other Negligence (PERSONAL INJURY)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 02/25/2021 05:31 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 02/25/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------------X Index Number: 519726/2018
MARTHE MILIUS,
Plaintiff, NOTICE OF DISCOVERY
AND INSPECTION
- against -
ISABELLE CHARLES,
Defendants.
---------------------------------------------------------------------X
COUNSELORS:
PLEASE TAKE NOTICE, that the undersigned hereby serves the following demands
upon you pursuant to CPLR 3120 and 3101, et. seq., returnable at the law offices of HARMON,
LINDER & ROGOWSKY 3 Park Avenue, 23rd Floor, New York, New York 10016 March
23, 2021, on at 10:00 A.M.
1) A fully executed copy of the Insurance Policy alleged to be effect on the date of June 19,
2016 for the property located at 1322 East 56th Street, in County of Kings, city and State
of New York, which includes original signatures;
2) A full and complete unredacted copy of the Recorded Statement given by Defendant
Isabelle Charles on November 2, 2018 relating to the accident of June 19, 2016;
PLEASE TAKE FURTHER NOTICE, that the foregoing are continuing demands and that
if any of the above items are obtained or come into the possession of the Defendant(s), their agents,
servants, employees and/or attorneys after the date of this demand, they are to be furnished pursuant
to this demand.
DATED: New York, New York
Thursday, February 25, 2021
Yours, etc.,
MARK LINDER, ESQ.
HARMON, LINDER & ROGOWSKY
1 of 2
FILED: KINGS COUNTY CLERK 02/25/2021 05:31 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 02/25/2021
Attorneys for Plaintiff(s)
3 Park Avenue, 23rd Floor
New York, NY 10016
(212) 732-3665
MJL/gka
VIA NYSCEF ONLY
TO: SILVERMAN, SHIN & BYRNE, PLLC
Attorney(s)for Defendant(s)
ISABELLE CHARLES
Wall Street Plaza
88 Pine Street, 22nd Floor
New York, New York 10005
(212) 779-8600
2 of 2
Preview
FILED: KINGS COUNTY CLERK 02/25/2021 05:31 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 02/25/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------X Index Number: 519726/2018 MARTHE MILIUS, Plaintiff, NOTICE OF DISCOVERY AND INSPECTION - against - ISABELLE CHARLES, Defendants. ---------------------------------------------------------------------X COUNSELORS: PLEASE TAKE NOTICE, that the undersigned hereby serves the following demands upon you pursuant to CPLR 3120 and 3101, et. seq., returnable at the law offices of HARMON, LINDER & ROGOWSKY 3 Park Avenue, 23rd Floor, New York, New York 10016 March 23, 2021, on at 10:00 A.M. 1) A fully executed copy of the Insurance Policy alleged to be effect on the date of June 19, 2016 for the property located at 1322 East 56th Street, in County of Kings, city and State of New York, which includes original signatures; 2) A full and complete unredacted copy of the Recorded Statement given by Defendant Isabelle Charles on November 2, 2018 relating to the accident of June 19, 2016; PLEASE TAKE FURTHER NOTICE, that the foregoing are continuing demands and that if any of the above items are obtained or come into the possession of the Defendant(s), their agents, servants, employees and/or attorneys after the date of this demand, they are to be furnished pursuant to this demand. DATED: New York, New York Thursday, February 25, 2021 Yours, etc., MARK LINDER, ESQ. HARMON, LINDER & ROGOWSKY 1 of 2 FILED: KINGS COUNTY CLERK 02/25/2021 05:31 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 02/25/2021 Attorneys for Plaintiff(s) 3 Park Avenue, 23rd Floor New York, NY 10016 (212) 732-3665 MJL/gka VIA NYSCEF ONLY TO: SILVERMAN, SHIN & BYRNE, PLLC Attorney(s)for Defendant(s) ISABELLE CHARLES Wall Street Plaza 88 Pine Street, 22nd Floor New York, New York 10005 (212) 779-8600 2 of 2