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 10/26/2021 10:59 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/26/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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MARTHE MILIUS, SUPPLEMENTAL
NOTICE OF DISCOVERY
Plaintiff, AND INSPECTION
-against-
Index No.: 519726/2018
ISABELLE CHARLES,
Defendant.
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C O U N S E L:
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 December 1, 2021, on at 10:00 A.M.
1. A complete, full, and unredacted version of the recorded statement of Defendant
ISABELLE CHARLES taken by William Ahern, a member of Mountain Valley’s Special
Investigations Unit, on November 2nd, 2018. A heavily redacted version of this statement
can be found on NYSCEF under Index #154734/2019, NYSCEF Document #24. Plaintiff
demands the complete, full, and unredacted version of this statement.
PLEASE TAKE FURTHER NOTICE that this demand can be responded to by emailing the
requested document(s) to DCrispell@HLRLawyers.com.
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.
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FILED: KINGS COUNTY CLERK 10/26/2021 10:59 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/26/2021
DATED: New York, New York
October 26, 2021
Yours, etc.,
MARK LINDER, ESQ.
HARMON, LINDER & ROGOWSKY
Attorneys for Plaintiff(s)
3 Park Avenue, 23rd Floor
New York, NY 10016
(212) 732-3665
MJL/kc
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
2 of 2
Preview
FILED: KINGS COUNTY CLERK 10/26/2021 10:59 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/26/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------X MARTHE MILIUS, SUPPLEMENTAL NOTICE OF DISCOVERY Plaintiff, AND INSPECTION -against- Index No.: 519726/2018 ISABELLE CHARLES, Defendant. --------------------------------------------------------------------X C O U N S E L: 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 December 1, 2021, on at 10:00 A.M. 1. A complete, full, and unredacted version of the recorded statement of Defendant ISABELLE CHARLES taken by William Ahern, a member of Mountain Valley’s Special Investigations Unit, on November 2nd, 2018. A heavily redacted version of this statement can be found on NYSCEF under Index #154734/2019, NYSCEF Document #24. Plaintiff demands the complete, full, and unredacted version of this statement. PLEASE TAKE FURTHER NOTICE that this demand can be responded to by emailing the requested document(s) to DCrispell@HLRLawyers.com. 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. 1 of 2 FILED: KINGS COUNTY CLERK 10/26/2021 10:59 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/26/2021 DATED: New York, New York October 26, 2021 Yours, etc., MARK LINDER, ESQ. HARMON, LINDER & ROGOWSKY Attorneys for Plaintiff(s) 3 Park Avenue, 23rd Floor New York, NY 10016 (212) 732-3665 MJL/kc 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 2 of 2