On October 01, 2018 a
Motion-Secondary
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 10/28/2021 07:35 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/28/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------------x
MARTHE MILIUS, Index No. 519726/2018
Plaintiff,
RESPONSE TO
-against- SUPPLEMENTAL
NOTICE OF
DISCOVERY AND
ISABELLE CHARLES, INSPECTION
Defendants.
-------------------------------------------------------------------------x
PLEASE TAKE NOTICE, that defendant ISABELLE CHARLES., by their attorneys,
Silverman Shin & Byrne PLLC as and for their response to plaintiff’s Supplemental Notice of
Discovery and Inspection dated October 26 upon information and belief, as follows:
GENERAL OBJECTIONS
1. The following general objections apply to and are incorporated by reference into
each response. In each instant in which defendants object specifically to a document request, such
subjection is in additional to these General Objections.
2. No admissions of any nature are implied or should be inferred from these responses.
3. Each response or objection to each document request is based on defendant’s
understanding of that request. To the extent that plaintiff asserts an interpretation that is
inconsistent with defendants understanding, defendant reserves the right to supplement or amend
their responses and objections.
4. Defendant object to the document requests to the extent that is duplicative, seeks
information or documents, which can be more readily obtained from other sources, and/or seeks
information or documents which are not in defendants’ custody, possession, or control.
5. Defendant object to the document requests to the extent that it is oppressive or
unduly burdensome.
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FILED: KINGS COUNTY CLERK 10/28/2021 07:35 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/28/2021
RESPONSE TO DEMANDS
1. Defendant object to this demand to the extent that the documented requested is
material prepared in anticipation of litigation and information that is protected from discovery by
the attorney-client privilege, work product doctrine, or any other privilege, doctrine, or immunity.
Defendant reserves the right to supplement this response and objection should additional
information be discovered.
Dated: New York, New York
October 28, 2021
SILVERMAN SHIN & BYRNE PLLC
By: Ari Reiser_________________
Ari Reiser
Attorneys for Defendant
Wall Street Plaza
88 Pine Street, 22nd Floor
New York, New York 10005
(212) 779-8600
File No.: 990.057
To:
Mark Linder
Attorney for Plaintiff
3 Park Avenue, 23rd Floor
New York, New York 10016
Tel: (212) 732-3665
2 of 3
FILED: KINGS COUNTY CLERK 10/28/2021 07:35 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/28/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------------x
MARTHE MILIUS, Index No. 519726/2018
Plaintiff,
-against-
ISABELLE CHARLES,
Defendants.
-------------------------------------------------------------------------x
______________________________________________________________________________
RESPONSE TO SUPPLEMENTAL NOTICE OF DISCOVERY AND INSPECTION
______________________________________________________________________________
SILVERMAN SHIN & BYRNE PLLC
Attorneys for Defendants
Wall Street Plaza
88 Pine Street, 22nd Floor
New York, New York 10005
(212) 779-8600
______________________________________________________________________________
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney duly admitted to practice law
in the State of New York, certifies that, upon information and belief based upon reasonable
inquiry, the contentions contained in the annexed document are not frivolous.
Dated: New York, New York
October 28, 2021
Ari Reiser
Ari Reiser
3 of 3
Preview
FILED: KINGS COUNTY CLERK 10/28/2021 07:35 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/28/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------------x MARTHE MILIUS, Index No. 519726/2018 Plaintiff, RESPONSE TO -against- SUPPLEMENTAL NOTICE OF DISCOVERY AND ISABELLE CHARLES, INSPECTION Defendants. -------------------------------------------------------------------------x PLEASE TAKE NOTICE, that defendant ISABELLE CHARLES., by their attorneys, Silverman Shin & Byrne PLLC as and for their response to plaintiff’s Supplemental Notice of Discovery and Inspection dated October 26 upon information and belief, as follows: GENERAL OBJECTIONS 1. The following general objections apply to and are incorporated by reference into each response. In each instant in which defendants object specifically to a document request, such subjection is in additional to these General Objections. 2. No admissions of any nature are implied or should be inferred from these responses. 3. Each response or objection to each document request is based on defendant’s understanding of that request. To the extent that plaintiff asserts an interpretation that is inconsistent with defendants understanding, defendant reserves the right to supplement or amend their responses and objections. 4. Defendant object to the document requests to the extent that is duplicative, seeks information or documents, which can be more readily obtained from other sources, and/or seeks information or documents which are not in defendants’ custody, possession, or control. 5. Defendant object to the document requests to the extent that it is oppressive or unduly burdensome. 1 of 3 FILED: KINGS COUNTY CLERK 10/28/2021 07:35 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/28/2021 RESPONSE TO DEMANDS 1. Defendant object to this demand to the extent that the documented requested is material prepared in anticipation of litigation and information that is protected from discovery by the attorney-client privilege, work product doctrine, or any other privilege, doctrine, or immunity. Defendant reserves the right to supplement this response and objection should additional information be discovered. Dated: New York, New York October 28, 2021 SILVERMAN SHIN & BYRNE PLLC By: Ari Reiser_________________ Ari Reiser Attorneys for Defendant Wall Street Plaza 88 Pine Street, 22nd Floor New York, New York 10005 (212) 779-8600 File No.: 990.057 To: Mark Linder Attorney for Plaintiff 3 Park Avenue, 23rd Floor New York, New York 10016 Tel: (212) 732-3665 2 of 3 FILED: KINGS COUNTY CLERK 10/28/2021 07:35 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/28/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------------x MARTHE MILIUS, Index No. 519726/2018 Plaintiff, -against- ISABELLE CHARLES, Defendants. -------------------------------------------------------------------------x ______________________________________________________________________________ RESPONSE TO SUPPLEMENTAL NOTICE OF DISCOVERY AND INSPECTION ______________________________________________________________________________ SILVERMAN SHIN & BYRNE PLLC Attorneys for Defendants Wall Street Plaza 88 Pine Street, 22nd Floor New York, New York 10005 (212) 779-8600 ______________________________________________________________________________ Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney duly admitted to practice law in the State of New York, certifies that, upon information and belief based upon reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated: New York, New York October 28, 2021 Ari Reiser Ari Reiser 3 of 3