Preview
RECEIVED NYSCEF: 03/07/2023
EXHIBIT F(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
xX
JUANEDUARDO PEREZ PERALTA, —t—<“‘i‘“‘CSCS Index No.: 522746/2021
Plaintiff,
DEMAND FOR
-against- LITIGATION FUNDING
CO. INFORMATION
CROWN GATES LLC and MORELL BUILDERS INC., AND DOCUMENTS
Defendants.
wee e ee ee eee een eee ene eee eee een ne eee nneene eee nneenneeeeneeee x
CROWN GATES LLC,
Third-Party Plaintiff,
-against-
QUEENS RESTORATION & CONSTRUCTION, INC., and
GONZO CONSTRUCTION CORP..,
Third-Party Defendants.
PLEASE TAKE NOTICE, that the Defendants/Third-Party Plaintiffs, PUBLIC
STORAGE and BLUESTONE CONSTRUCTION INC., pursuant to CPLR 3101, et. seq. whether
plaintiff or plaintiffs attorney has entered into an agreement, contract, contingency or loan with a
lender, litigation funding company, litigation lending company, medical funding company or other
similar entity, company, corporation, partnership or person that is engaged in loaning money,
advancing money or financially assisting you in your attomey in any aspect of this case, whether
it be for payment of medical bills, litigation expenses, witness expenses, lost wages, or an
advancement against a portion or all of any potential recovery you may receive and if so, produce
within thirty days:
1. The complete name and address of the lender, litigation funding company, litigation
lending company, medical funding company, or similar entity as described above.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
2. The date of which agreement, advance or load was made.
3. The amount of such agreement, advance or loan.
4. Legible copies of all information, including documents of any kind provided to the
lender, litigation funding company, litigation lending company, or voluntary all
brochures, applications, contracts, agreements, liens, correspondence or other
similar documents received by plaintiff, completed by plaintiff, anyone on behalf
of plaintiff or plaintiffs attorneys as part of the process of entering into all
agreements negotiations and contracts with a lender, litigation lending company,
medical funding company or similar entity.
5. HIPAA compliant authorizations for the release of records from the lender,
litigation funding company, litigation lending company, medical funding company,
or similar entity as described above.
PLEASE TAKE FURTHER NOTICE, that the provisions of the CPLR §3122 govern
this demand and if the party to whom the notice is directed objects to the disclosure, inspection or
examination or withholds any documents which appear to be within the category of the documents
required by the notice, that in the event any of the requested documents and/or items do not exist,
a verified statement to that effect is to be served on the undersigned on or before the aforesaid
retum date.
PLEASE TAKE FURTHER NOTICE, that in the event or failure or refusal to comply
with any of these demands, the demanding defendants will apply to the Court for the appropriate
relief including, but not limited to, an Order compelling compliance pursuant to CPLR §3124
and/or appropriate relief pursuant to CPLR §3126 and 22 N.Y .C.R.R. Part 130.
PLEASE TAKE FURTHER NOTICE, that all demands herein shall be deemed to
continue during the pendency of this action through and including the trial thereof and must be
amended or supplemented properly in compliance with CPLR §3101(h). In the event any of the
requested documents and/or items are obtained after the aforesaid return date, same are to be
furnished to the undersigned within thirty (30) days after receipt.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
DATED: New Y ork, New Y ork
June 10, 2022
Y ours, etc.,
INDEX NO. 522746/2021
RECEIVED NYSCEF: 03/07/2023
HANNUM FERETIC PRENDERGAST
& MERLINO, LLC
Uaniva Carfeenti
Marisa Carpentiere
Attorneys for Third-Party Defendant
QUEENS RESTORATION &
CONSTRUCTION, INC.,
Office and Post Office Address
55 Broadway, Suite 202
New Y ork, New Y ork 10006
(212) 530-3900
TO:
William Schwitzer & Associates, P.C.
Attorneys for Plaintiff
JUAN EDUARDO PEREZ PERALTA
820 Second Avenue, 10th Floor
New Y ork, NY 10017
(212) 683-3800
Gold Benes, LLP
Attomeys for Defendant/Third-Party Plaintiff
CROWN GATES LLC
1666 Newbridge Road, 2nd Floor
Bellmore, NY 11710
(516) 512-6333
GONZO CONSTRUCTION CORP.
Third-Party Defendant Pro-Se
102-12 27th Avenue
East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
xX
JUAN EDUARDO PEREZ PERALTA, Index No.: 522746/2021
Plaintiff,
DEMAND FOR
-against- SOCIAL NETWORKING
INFORMATION
CROWN GATES LLC and MORELL BUILDERS INC.,
Defendants.
wen nee ene een een ee cee ene eee cenee ene eeeee xX
CROWN GATES LLC,
Third-Party Plaintiff,
-against-
QUEENS RESTORATION & CONSTRUCTION, INC., and
GONZO CONSTRUCTION CORP..,
Third-Party Defendants.
PLEASE TAKE NOTICE, that pursuant to the rules of this Court, Article 31 of the
CPLR, §2305 and §3120 of the CPLR, you are hereby required to serve upon and deliver within
twenty (20) days to the undersigned offices of Hannum Feretic Prendergast & Merlino, LLC, 55
Broadway, Suite 202, New Y ork, New Y ork 10006, the following documents and things:
1. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Facebook account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. If plaintiff has never had a Facebook account, then an affidavit to that effect
must be provided.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
C. f plaintiff does not currently have a Facebook account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
2. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiff's MySpace account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a MySpace account, then an affidavit to that effect
must be provided.
Cc. f plaintiff does not currently have a MySpace account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
3. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Twitter account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a Twitter account, then an affidavit to that effect
must be provided.
C. f plaintiff does not currently have a Twitter account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
4, Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs TikTok account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a TikTok account, then an affidavit to that effect
must be provided.
C. f plaintiff does not currently have a TikTok account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
5. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Foursquare account.
A.
The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
INDEX NO. 522746/2021
RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
B. f plaintiff has never had a Foursquare account, then an affidavit to that
effect must be provided.
C. f plaintiff does not currently have a Foursquare account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
6. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Google Buzz account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a Google Buzz account, then an affidavit to that
effect must be provided.
Cc. f plaintiff does not currently have a Google Buzz account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
7. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Shutterfly.com account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a Shutterfly.com account, then an affidavit to that
effect must be provided.
Cc. f plaintiff does not currently have a Shutterfly.com account, but had such
an account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
8. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Flikr.com account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a Flikr.com account, then an affidavit to that effect
must be provided.
C. f plaintiff does not currently have a Flikr.com account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
9. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Snapfish.com account.
INDEX NO. 522746/2021
RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
[he authorization must include the e-mail address linked to this account,
along with all other required identifying information.
f plaintiff has never had a Snapfish.com account, then an affidavit to that
effect must be provided.
f plaintiff does not currently have a Snapfish.com account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
10. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs LinkedIn account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a LinkedIn account, then an affidavit to that effect
must be provided.
C. f plaintiff does not currently have a LinkedIn account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
11. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiff's Evite.com account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had an Evite.com account, then an affidavit to that
effect must be provided.
Cc.
f plaintiff does not currently have a Evite.com account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
12. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Punchbowl.com account.
A.
[he authorization must include the e-mail address linked to this account,
along with all other required identifying information.
f plaintiff has never had a Punchbowl.com account, then an affidavit to that
effect must be provided.
f plaintiff does not currently have a Punchbowl.com account, but had such
an account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
INDEX NO. 522746/2021
RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
13. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Classmates.com account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a Classmates.com account, then an affidavit to that
effect must be provided.
Cc. f plaintiff does not currently have a Classmates.com account, but had such
an account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
14. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Active.com account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had an Active.com account, then an affidavit to that
effect must be provided.
Cc. f plaintiff does not currently have a Active.com account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
15. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Bebo.com account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a Bebo.com account, then an affidavit to that effect
must be provided.
C. f plaintiff does not currently have a Bebo.com account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
16. Duly executed, original authorizations for full access to, and copies of plaintiff's
current historical records/information for plaintiffs Friendster account.
A. The authorization must include the e-mail address linked to this account,
along with all other required identifying information.
B. f plaintiff has never had a Friendster account, then an affidavit to that effect
must be provided.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
C. f plaintiff does not currently have a Friendster account, but had such an
account at some prior time, then an affidavit to that effect, including the
time frame such an account existed, must be provided.
17. Identify any other social networking site(s) which plaintiff has been a member of
from two years prior to the alleged occurrence and date of loss to present.
A. Provide duly executed, original authorizations for full access to, and copies
of Plaintiff's current historical records/information for each site listed
herein.
B. The authorization must include the email address linked to this account,
along with all other required identifying information.
PLEASE TAKE NOTICE that the within demand is a continuing demand. In the event
that any of the above items are obtained after service of this demand, they are to be furnished to
the undersigned pursuant to this demand.
PLEASE TAKE FURTHER NOTICE, that plaintiff and plaintiff's counsel are put on
notice that the information in any and/or all of plaintiffs social networking sites has been duly
demanded for discovery related to this litigation pursuant to the rules of the Court and the CPLR.
The information in any and/or all of plaintiffs social networking sites, photo sites or other sites
listed above must not be destroyed, deleted, altered, tampered, spoiled expunged or manipulated
in any other way as to obstruct the information as demanded herein.
PLEASE TAKE FURTHER NOTICE, that your failure to comply with the foregoing,
within twenty (20) days, will serve as the basis of a motion for appropriate relief pursuant to the
CPLR.
PLEASE TAKE FURTHER NOTICE, that in lieu of producing the items demanded
herein, you may serve and submit to the undersigned true and conformed copies of the items
demanded herein at any time prior to the aforesaid date.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
DATED: New Y ork, New Y ork
June 10, 2022
Y ours, etc.,
INDEX NO. 522746/2021
RECEIVED NYSCEF: 03/07/2023
HANNUM FERETIC PRENDERGAST
& MERLINO, LLC
Uaniva Carfeenti
Marisa Carpentiere
Attorneys for Third-Party Defendant
QUEENS RESTORATION &
CONSTRUCTION, INC.,
Office and Post Office Address
55 Broadway, Suite 202
New Y ork, New Y ork 10006
(212) 530-3900
TO:
William Schwitzer & Associates, P.C.
Attorneys for Plaintiff
JUAN EDUARDO PEREZ PERALTA
820 Second Avenue, 10th Floor
New Y ork, NY 10017
(212) 683-3800
Gold Benes, LLP
Attomeys for Defendant/Third-Party Plaintiff
CROWN GATES LLC
1666 Newbridge Road, 2nd Floor
Bellmore, NY 11710
(516) 512-6333
GONZO CONSTRUCTION CORP.
Third-Party Defendant Pro-Se
102-12 27th Avenue
East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
xX
JUANEDUARDO PEREZ PERALTA, = Index No.: 522746/2021
Plaintiff,
DEMAND PURSUANT
-against- TO CPLR §4545
CROWN GATES LLC and MORELL BUILDERS INC.,
Defendants.
neceeeeeseceecceeeeeeencececceeeeeeeeseeeeceeeeeeeeseeeeceeeeeeeeenseees xX
CROWN GATES LLC,
Third-Party Plaintiff,
-against-
QUEENS RESTORATION & CONSTRUCTION, INC., and
GONZO CONSTRUCTION CORP..,
Third-Party Defendants.
PLEASE TAKE NOTICE, that demand is hereby made upon the plaintiff to serve upon
the undersigned a statement as to whether any part of the cost of medical care, custodial care,
rehabilitation services, loss of earnings, or other economic loss sought to be recovered herein was
replaced or indemnified, in whole or in part, from any collateral sources such as insurance, social
security (except those benefits provided under Title 18 the of Social Security Act), Workers’
Compensation or employee benefits programs and, if so, the full name and address of each
organization or program providing such replacement or indemnification, together with an itemized
statement of the amount in which each such claimed item of economic loss was replaced or
indemnified by each such organization or program.
Demand is additionally made for duly executed and properly addressed original(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
authorizations permitting the undersigned to inspect and copy all records reflecting any collateral
source or payment identified in response to the foregoing demand.
PLEASE TAKE FURTHER NOTICE, that your failure to comply with the foregoing,
within twenty (20) days, will serve as the basis of a motion for appropriate relief pursuant to the
CPLR.
DATED: New Y ork, New Y ork
June 10, 2022
Y ours, etc.,
HANNUM FERETIC PRENDERGAST
& MERLINO, LLC
Marisa Carpentiere
Attorneys for Third-Party Defendant
QUEENS RESTORATION &
CONSTRUCTION, INC.
Office and Post Office Address
55 Broadway, Suite 202
New Y ork, New Y ork 10006
(212) 530-3900
TO:
William Schwitzer & Associates, P.C.
Attorneys for Plaintiff
820 Second Avenue, 10th Floor
New Y ork, NY 10017
JUAN EDUARDO PEREZ PERALTA
(212) 683-3800
Gold Benes, LLP
Attomeys for Defendant/T hird-Party Plaintiff
CROWN GATES LLC
1666 Newbridge Road, 2nd Floor
Bellmore, NY 11710
(516)512-6333(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
GONZO CONSTRUCTION CORP.
Third-Party Defendant Pro-Se
102-12 27th Avenue
East Elmhurst, NY 11369(FILED: KINGS COUNTY
CLERK 0370772023 12:32 PM INDEX NO. 5
NYSCEF DOC. NO. 73
RECEIVED NYSCEF:
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
xX
JUANEDUARDO PEREZPERALTA, Index No.: 522746/2021
Plaintiff,
NOTICE FOR
-against- DISCOVERY AND
INSPECTION
CROWN GATES LLC and MORELL BUILDERS INC.,
Defendants.
wee e ee ee eee een eee ene eee eee een ne eee nneene eee nneenneeeeneeee xX
CROWN GATES LLC,
-against-
Third-Party Plaintiff,
QUEENS RESTORATION & CONSTRUCTION, INC., and
GONZO CONSTRUCTION CORP..,
Third-Party Defendants.
PLEASE TAKE NOTICE, that pursuant to Article 31 of the CPLR, you are required to
serve upon the undersigned attorneys for third-party defendant, QUEENS RESTORATION &
CONSTRUCTION, INC., within thirty (30) days of the receipt of this demand for the following:
1. CPLR
a.
b.
SECTION 304 and 306(a) DEMAND
Proof of filing of the Summons and Complaint.
Affidavits of service upon the Defendant.
2. DEMAND FOR MEDICAL REPORTS AND AUTHORIZATIONS
a.
The names and addresses of all physicians or other health care providers of
every description who have consulted, examined, or treated plaintiff for
each of the conditions allegedly caused or exacerbated by the occurrence(s)
described in the Verified Complaint, including the dates of such
consultation, treatment or examination.
22746/2021
03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
b. Duly
undersigned to obtain the complete office medical records, including bu
not limited to, reports, charts, diagnoses, test results, X-rays, CAT-scans,
MRI
plaint:
c. Co
d. Duly
hospit
inclu
e. The names anc
hospit
ies of all medical reports received from health care providers identifie
in “a” above.
treated or confined due to the occurrence(s) set forth in the Verifie
Complaint, so as to permit to securing of a copy of the entire hospital record,
treated, during the five years prior to the occurrence(s) set
Verified Complaint, for any condition(s) or injury(ies) to the plaintiff. Also
executed and acknowledged written authorizations to allow the
images, prescriptions, invoices and technicians’ reports relating to
iff from each health care provided identified in “a” above.
executed and acknowledged written authorizations directed to any
tal, clinic, or other health care facility in which plaintiff is or was
ing but not limited to reports, charts, diagnoses, test results, X -rays,
CAT-scans, MRI images, prescriptions, invoices and technicians’ reports.
addresses of every physician or other health care provider,
tal, clinic, or other health care facility which may have examined or
forth in the
state the dates of such treatment or examination.
f. Duly executed and acknowledged written authorizations to allow the
defendant to obtain the complete medical records including but not limited
to reports, charts, diagnoses, test results, X-rays, CAT-scans, MRI images,
prescriptions, invoices and technicians’ reports of any physician or other
health care provider, hospital, clinic or o
have
set forth in the Verified Complaint,
plaintiff.
g. Duly
er health care facility which may
e five years prior to the occurrence(s)
‘or any condition(s) or injury(ies) to the
examined or treated, during
executed and acknowledged written authorizations to allow the
undersigned to obtain complete pharmacy or drug store records with respect
to any drugs
occurrence(s)
rescribed for plaintiff from three (3) years prior to the
lescribed in the Verified Complaint to the present date.
DEMAND FOR WAGE AND COLLATERAL SOURCE INFORMATION
AND AUTHORIZATIONS
a. All documents that will
economic loss, including
e used at the trial to establish any claimed
but not limited to, bills, canceled checks,
insurance forms, etc. for each of the plaintiffs.
b. The
names and addresses of all institutions, firms, corporations,
partnerships, persons, or others by whom plaintiff was employed, and by or
from
whom plaintiff received a salary and/or income benefits from seven
INDEX NO. 522746/2021
RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
e present date.
Duly executed,
Complaint to the present date.
Duly executed,
authorizations permitting the release
7) years prior to the occurrence(s) described in the Verified Complaint to
acknowledged and properly addressed written
authorizations permitting the release of plaintiff's employment records from
seven (7) years prior to the occurrence(s) described in the Verified
[he names and addresses of all unions, clubs, health clubs, gyms, or
organizations of which plaintiff was a member from seven (7) years prior
to the occurrence(s) described in the V erified Complaint to the present date.
acknowledged and properly addressed written
of all records of the plaintiff with
respect to his/her membership in any unions, clubs, health clubs, gyms, or
organizations.
Serve upon and deliver to the undersigned duly executed and acknowledged
written authorizations permitting all parties to obtain and make copies of
any and all Worker’s Compensation (provide Worker’s Compensation
Board authorization for OC-110A) and No-Fault benefit records, reports, or
files relative to this incident.
Copies of the income tax returns filed by the plaintiff and the W2 forms
received by
e plaintiff and filed with
le United States Federal
Government, and any State or City Govemment from seven (7) years prior
to the occurrence(s) described in the V
Duly _ executed,
erified Complaint to the present date.
acknowledged and properly addressed written
authorizations directed to the Internal Revenue Service (IRS Form 4506 and
8821) for plaintiff's income tax retur
occurrence(s) described in the Veri
inclusive.
Provide the undersigned all document
canceled checks concerming
indemnification,
ns from seven (7) years prior to the
‘ied Complaint to the present date,
s, records, bills, invoices, receipts or
payment and/or
reimbursement, in whole or in part, which the plaintiff has received from
collateral sources, including but not
imited to insurance, social security,
workers compensation, no-fault or employee benefit programs for the cost
of medical care, custodial care, rehabil
other economic loss which the plaintifi
itation services, loss of earnings and
will claim as special damages in this
action or which plaintiff will claim were incurred as a result of the
occurrence(s) alleged in this action.
INDEX NO. 522746/2021
RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
4, DEMAND FOR PHOTOGRAPHS
a. All films, photographs, videotapes and the like of the scene of the alleged
occurrence(s) which is the subject of this litigation.
b. All films, photographs of any instrumentalities, equipment and other things
or objects allegedly involved in this litigation.
Cc. All films, photographs and the like of the plaintiffs which demonstrate the
injuries allegedly sustained.
5. DEMAND FOR DISCOVERY AND INSPECTION OF ANY STATEMENT
OF ANY PARTY REPRESENTED BY THE UNDERSIGNED
a. Written statements of any party represented by the undersigned.
b. Records, memoranda, notes, tape recordings, or other recorded
communications of or by any party represented by the undersigned.
6. DEMAND FOR WITNESS INFORMATION
Provide the names and addresses of each person claimed to be a witness of any of
the following:
a. The occurrence(s) alleged in the Verified Complaint.
b. Any acts, omission(s) or condition(s) which allegedly caused the
occurrence(s) alleged in the Verified Complaint.
c. Any notice of the alleged condition(s) complained of which caused the
occurrence(s) alleged in the Verified Complaint.
d. The nature and duration of the alleged condition(s) which caused the
occurrence(s) alleged in the Verified Complaint.
e. Any physical examination, test, consultation, treatment or conversation
performed or had by any party represented by the undersigned.
f. Any injury or damages sustained by the plaintiff.
7. DEMAND FOR WRITTEN REPORTS
Provide true copies of any written reports of the alleged occurrence(s) which have
been prepared in the regular course of business, operation or practice of any person,
firm, corporation, association, or other public or private entity.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
8. DEMAND FOR INSURANCE INFORMATION
Provide copies of the entire contents of any insurance agreement under which any
corporation or other entity carrying on an insurance business may be liable to satisfy
part or all of a judgment which may be entered in this action or to indemnify or
reimburse any party for payments made to satisfy the judgment.
9. DEMAND FOR EXPERT WITNESS DISCLOSURE
Provide the name and address of each person whom you expect to call as an expert
witness at trial and, with respect to each such witness, set forth the following:
a. State the qualifications of each expert witness.
b. State with specificity the subject matter upon which each expert is expected
to testify at the time of trial.
Cc. Provide the facts and opinion upon which each expert is expected to testify
at the time of trial.
d. Provide a summary of the grounds of each expert’s opinion, and attach any
data in support of each opinion and conclusion.
10. DEMAND FOR NAME AND ADDRESS OF ATTORNEYS
Provide the name, office address, telephone and facsimile numbers of all attorneys
who have appeared on behalf of any party in the above captioned action, and the
name of the party represented.
PLEASE TAKE NOTICE that, the foregoing demands are continuing demands. In the
event that any of the above items are obtained after service of this demand, or service of a response
hereto, they are to be furnished to the undersigned forthwith.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
DATED: New Y ork, New Y ork
June 10, 2022
Y ours, etc.,
INDEX NO. 522746/2021
RECEIVED NYSCEF: 03/07/2023
HANNUM FERETIC PRENDERGAST
& MERLINO, LLC
Uaniva Carfeenti
Marisa Carpentiere
Attorneys for Third-Party Defendant
QUEENS RESTORATION &
CONSTRUCTION, INC.
Office and Post Office Address
55 Broadway, Suite 202
New Y ork, New Y ork 10006
(212) 530-3900
TO:
William Schwitzer & Associates, P.C.
Attorneys for Plaintiff
JUAN EDUARDO PEREZ PERALTA
820 Second Avenue, 10th Floor
New Y ork, NY 10017
(212) 683-3800
Gold Benes, LLP
Attomeys for Defendant/T hird-Party Plaintiff
CROWN GATES LLC
1666 Newbridge Road, 2nd Floor
Bellmore, NY 11710
(516) 512-6333
GONZO CONSTRUCTION CORP.
Third-Party Defendant Pro-Se
102-12 27th Avenue
East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
x
JUANEDUARDO PEREZPERALTA, ————™ Index No.: 522746/2021
Plaintiff,
NOTICE FOR
-against- EXAMINATION
BEFORE TRIAL
CROWN GATES LLC and MORELL BUILDERS INC., a
Defendants.
ween e ene n nen ene n ene nen en enn nennnnnnenennnenennne xX
CROWN GATES LLC,
Third-Party Plaintiff,
-against-
QUEENS RESTORATION & CONSTRUCTION, INC., and
GONZO CONSTRUCTION CORP..,
Third-Party Defendants.
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and
Rules, the third-party defendant, QUEENS RESTORATION & CONSTRUCTION, INC., will
take the Examination Before Trial upon oral questions, of the plaintiff, JUAN EDUARDO PEREZ
PERALTA, at the time and place indicated below, conceming all of the evidence material and
necessary in connection with the prosecution and defense of this action.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §3113(b), the deposition
conducted may be audiotaped and videotaped simultaneously at the discretion of HANNUM
FERETIC PRENDERGAST & MERLINO, LLC.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
PLEASE TAKE FURTHER NOTICE, that pursuant to Rule 3111 of the CPLR, each
party is required to produce all books and papers in their possession, control or custody, relating
to the issues upon which said party is to be examined.
PERSONS TO BE EXAMINED. Plaintiff: JUAN EDUARDO PEREZ
PERALTA
DATE: September 9, 2022
TIME: 0:00 am
PLACE: Hannum Feretic Prendergast & Merlino, LLC
55 Broadway, Suite 202
New Y ork, New Y ork 10006
PLEASE TAKE FURTHER NOTICE, that this is a continuing demand and should any
of the information requested become available or known in the future, it is to be immediately
furnished to us. If you fail to comply, we shall rely on all sanctions provided by law.
DATED: New Y ork, New Y ork
June 10, 2022
Y ours, etc.,
HANNUM FERETIC PRENDERGAST
& MERLINO, LLC
Marisa Carpentiere
Attorneys for Third-Party Defendant
QUEENS RESTORATION &
CONSTRUCTION, INC.
Office and Post Office Address
55 Broadway, Suite 202
New Y ork, New Y ork 10006
(212) 530-3900
TO:
William Schwitzer & Associates, P.C.
Attorneys for Plaintiff
JUAN EDUARDO PEREZ PERALTA
820 Second Avenue, 10th Floor
New Y ork, NY 10017
(212) 683-3800(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
Gold Benes, LLP
Attomeys for Defendant/T hird-Party Plaintiff
CROWN GATES LLC
1666 Newbridge Road, 2nd Floor
Bellmore, NY 11710
(516) 512-6333
GONZO CONSTRUCTION CORP.
Third-Party Defendant Pro-Se
102-12 27th Avenue
East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
xX
JUANEDUARDO PEREZ PERALTA, = —t—<“Cisi‘CS
Plaintiff,
-against-
CROWN GATES LLC and MORELL BUILDERS INC.,
Defendants.
wee e ee ee eee een eee ene eee eee een ne eee nneene eee nneenneeeeneeee xX
CROWN GATES LLC,
Third-Party Plaintiff,
-against-
QUEENS RESTORATION & CONSTRUCTION, INC., and
GONZO CONSTRUCTION CORP..,
Third-Party Defendants.
PLEASE TAKE NOTICE, that pursuant to CPLR §3121, the plaintiff is directed to
present himself or herself for a physical examination as follows:
Index No.: 522746/2021
NOTICE FOR
PHYSICAL
EXAMINATION
DATE AND TIME: To Be Determined
NAME OF PHYSICIAN:
PLACE OF EXAMINATION:
INDEX NO. 522746/2021
RECEIVED NYSCEF:
03/07/2023
PLEASE TAKE FURTHER NOTICE, that at least twenty (20) days prior to such
scheduled examination, plaintiff shall serve on the undersigned, pursuant to such section, duly
executed and acknowledged authorizations to obtain all hospital records, and also all records and
reports pursuant to the rules relating to exchange of medical information.
PLEASE TAKE FURTHER NOTICE, that this is a continuing demand and should any(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
INDEX NO. 522746/2021
NYSCEF DOC. NO. 73
RECEIVED NYSCEF: 03/07/2023
of the information requested become available or known in the future, it is to be immediately
furnished to us. If you fail to comply, we shall rely on all sanctions provided by law.
DATED: New Y ork, New Y ork
June 10, 2022
TO:
William Schwitzer & Associates, P.C.
Attorneys for Plaintiff
JUAN EDUARDO PEREZ PERALTA
820 Second Avenue, 10th Floor
New Y ork, NY 10017
(212) 683-3800
Gold Benes, LLP
Y ours, etc.,
HANNUM FERETIC PRENDERGAST
& MERLINO, LLC
Marisa Carpentiere
Attorneys for Third-Party Defendant
QUEENS RESTORATION &
CONSTRUCTION, INC.
Office and Post Office Address
55 Broadway, Suite 202
New Y ork, New Y ork 10006
(212) 530-3900
Attomeys for Defendant/Third-Party Plaintiff
CROWN GATES LLC
1666 Newbridge Road, 2nd Floor
Bellmore, NY 11710
(516)512-6333
GONZO CONSTRUCTION CORP.
Third-Party Defendant Pro-Se
102-12 27th Avenue
East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ee Xx
JUAN EDUARDO PEREZ PERALTA, Index No.: 2746/2001
Plaintiff,
. NOTICE TO PRODUCE
-against- RETAINER AGREEMENT
CROWN GATES LLC and MORELL BUILDERS INC.,
Defendants.
wee eee cece eee eee eee nee ee ence eee een ee eee eeee eee eeeeeeeeeeeeeeeeee X
CROWN GATES LLC,
Third-Party Plaintiff,
-against-
QUEENS RESTORATION & CONSTRUCTION, INC., and
GONZO CONSTRUCTION CORP..,
Third-Party Defendants.
PLEASE TAKE NOTICE, that pursuant to CPLR § 3101(a), the plaintiff is hereby
required to produce a copy of the plaintiff's retainer agreement with his/her attorney for the subject
action within thirty days of the date of service hereof upon you. Priest v. Hennessy, 51 N.Y.2d 62,
409 N.E.2d 983, 431 N.Y.S.2d 511 (1980); Rumrill-Hoyt Inc. v. Perri, 97 A.D.2d 951, 468 N.Y.S.2d
754 (4" Dept. 1983). The retainer agreement may be redacted in any respect, except the date and
plaintiff's signature.
PLEASE TAKE FURTHER NOTICE, that this is a continuing demand and failure to
comply will result in preclusion of any testimony regarding the items demanded.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM
NYSCEF DOC. NO. 73
DATED: New Y ork, New Y ork
June 10, 2022
Y ours, etc.,
INDEX NO. 522746/2021
RECEIVED NYSCEF: 03/07/2023
HANNUM FERETIC PRENDERGAST
& MERLINO, LLC
Uaniva Carfeenti
Marisa Carpentiere
Attorneys for Third-Party Defendant
QUEENS RESTORATION &
CONSTRUCTION, INC.
Office and Post Office Address
55 Broadway, Suite 202
New Y ork, New Y ork 10006
(212) 530-3900
TO:
William Schwitzer & Associates, P.C.
Attorneys for Plaintiff
JUAN EDUARDO PEREZ PERALTA
820 Second Avenue, 10th Floor
New Y ork, NY 10017
(212) 683-3800
Gold Benes, LLP
Attomeys for Defendant/T hird-Party Plaintiff
CROWN GATES LLC
1666 Newbridge Road, 2nd Floor
Bellmore, NY 11710
(516) 512-6333
GONZO CONSTRUCTION CORP.
Third-Party Defendant Pro-Se
102-12 27th Avenue
East Elmhurst, NY 11369
Preview
RECEIVED NYSCEF: 03/07/2023 EXHIBIT F(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS xX JUANEDUARDO PEREZ PERALTA, —t—<“‘i‘“‘CSCS Index No.: 522746/2021 Plaintiff, DEMAND FOR -against- LITIGATION FUNDING CO. INFORMATION CROWN GATES LLC and MORELL BUILDERS INC., AND DOCUMENTS Defendants. wee e ee ee eee een eee ene eee eee een ne eee nneene eee nneenneeeeneeee x CROWN GATES LLC, Third-Party Plaintiff, -against- QUEENS RESTORATION & CONSTRUCTION, INC., and GONZO CONSTRUCTION CORP.., Third-Party Defendants. PLEASE TAKE NOTICE, that the Defendants/Third-Party Plaintiffs, PUBLIC STORAGE and BLUESTONE CONSTRUCTION INC., pursuant to CPLR 3101, et. seq. whether plaintiff or plaintiffs attorney has entered into an agreement, contract, contingency or loan with a lender, litigation funding company, litigation lending company, medical funding company or other similar entity, company, corporation, partnership or person that is engaged in loaning money, advancing money or financially assisting you in your attomey in any aspect of this case, whether it be for payment of medical bills, litigation expenses, witness expenses, lost wages, or an advancement against a portion or all of any potential recovery you may receive and if so, produce within thirty days: 1. The complete name and address of the lender, litigation funding company, litigation lending company, medical funding company, or similar entity as described above.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 2. The date of which agreement, advance or load was made. 3. The amount of such agreement, advance or loan. 4. Legible copies of all information, including documents of any kind provided to the lender, litigation funding company, litigation lending company, or voluntary all brochures, applications, contracts, agreements, liens, correspondence or other similar documents received by plaintiff, completed by plaintiff, anyone on behalf of plaintiff or plaintiffs attorneys as part of the process of entering into all agreements negotiations and contracts with a lender, litigation lending company, medical funding company or similar entity. 5. HIPAA compliant authorizations for the release of records from the lender, litigation funding company, litigation lending company, medical funding company, or similar entity as described above. PLEASE TAKE FURTHER NOTICE, that the provisions of the CPLR §3122 govern this demand and if the party to whom the notice is directed objects to the disclosure, inspection or examination or withholds any documents which appear to be within the category of the documents required by the notice, that in the event any of the requested documents and/or items do not exist, a verified statement to that effect is to be served on the undersigned on or before the aforesaid retum date. PLEASE TAKE FURTHER NOTICE, that in the event or failure or refusal to comply with any of these demands, the demanding defendants will apply to the Court for the appropriate relief including, but not limited to, an Order compelling compliance pursuant to CPLR §3124 and/or appropriate relief pursuant to CPLR §3126 and 22 N.Y .C.R.R. Part 130. PLEASE TAKE FURTHER NOTICE, that all demands herein shall be deemed to continue during the pendency of this action through and including the trial thereof and must be amended or supplemented properly in compliance with CPLR §3101(h). In the event any of the requested documents and/or items are obtained after the aforesaid return date, same are to be furnished to the undersigned within thirty (30) days after receipt.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 DATED: New Y ork, New Y ork June 10, 2022 Y ours, etc., INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023 HANNUM FERETIC PRENDERGAST & MERLINO, LLC Uaniva Carfeenti Marisa Carpentiere Attorneys for Third-Party Defendant QUEENS RESTORATION & CONSTRUCTION, INC., Office and Post Office Address 55 Broadway, Suite 202 New Y ork, New Y ork 10006 (212) 530-3900 TO: William Schwitzer & Associates, P.C. Attorneys for Plaintiff JUAN EDUARDO PEREZ PERALTA 820 Second Avenue, 10th Floor New Y ork, NY 10017 (212) 683-3800 Gold Benes, LLP Attomeys for Defendant/Third-Party Plaintiff CROWN GATES LLC 1666 Newbridge Road, 2nd Floor Bellmore, NY 11710 (516) 512-6333 GONZO CONSTRUCTION CORP. Third-Party Defendant Pro-Se 102-12 27th Avenue East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS xX JUAN EDUARDO PEREZ PERALTA, Index No.: 522746/2021 Plaintiff, DEMAND FOR -against- SOCIAL NETWORKING INFORMATION CROWN GATES LLC and MORELL BUILDERS INC., Defendants. wen nee ene een een ee cee ene eee cenee ene eeeee xX CROWN GATES LLC, Third-Party Plaintiff, -against- QUEENS RESTORATION & CONSTRUCTION, INC., and GONZO CONSTRUCTION CORP.., Third-Party Defendants. PLEASE TAKE NOTICE, that pursuant to the rules of this Court, Article 31 of the CPLR, §2305 and §3120 of the CPLR, you are hereby required to serve upon and deliver within twenty (20) days to the undersigned offices of Hannum Feretic Prendergast & Merlino, LLC, 55 Broadway, Suite 202, New Y ork, New Y ork 10006, the following documents and things: 1. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Facebook account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. If plaintiff has never had a Facebook account, then an affidavit to that effect must be provided.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 C. f plaintiff does not currently have a Facebook account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 2. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiff's MySpace account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a MySpace account, then an affidavit to that effect must be provided. Cc. f plaintiff does not currently have a MySpace account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 3. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Twitter account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a Twitter account, then an affidavit to that effect must be provided. C. f plaintiff does not currently have a Twitter account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 4, Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs TikTok account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a TikTok account, then an affidavit to that effect must be provided. C. f plaintiff does not currently have a TikTok account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 5. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Foursquare account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 B. f plaintiff has never had a Foursquare account, then an affidavit to that effect must be provided. C. f plaintiff does not currently have a Foursquare account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 6. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Google Buzz account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a Google Buzz account, then an affidavit to that effect must be provided. Cc. f plaintiff does not currently have a Google Buzz account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 7. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Shutterfly.com account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a Shutterfly.com account, then an affidavit to that effect must be provided. Cc. f plaintiff does not currently have a Shutterfly.com account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 8. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Flikr.com account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a Flikr.com account, then an affidavit to that effect must be provided. C. f plaintiff does not currently have a Flikr.com account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 9. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Snapfish.com account. INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 [he authorization must include the e-mail address linked to this account, along with all other required identifying information. f plaintiff has never had a Snapfish.com account, then an affidavit to that effect must be provided. f plaintiff does not currently have a Snapfish.com account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 10. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs LinkedIn account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a LinkedIn account, then an affidavit to that effect must be provided. C. f plaintiff does not currently have a LinkedIn account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 11. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiff's Evite.com account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had an Evite.com account, then an affidavit to that effect must be provided. Cc. f plaintiff does not currently have a Evite.com account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 12. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Punchbowl.com account. A. [he authorization must include the e-mail address linked to this account, along with all other required identifying information. f plaintiff has never had a Punchbowl.com account, then an affidavit to that effect must be provided. f plaintiff does not currently have a Punchbowl.com account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 13. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Classmates.com account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a Classmates.com account, then an affidavit to that effect must be provided. Cc. f plaintiff does not currently have a Classmates.com account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 14. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Active.com account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had an Active.com account, then an affidavit to that effect must be provided. Cc. f plaintiff does not currently have a Active.com account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 15. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Bebo.com account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a Bebo.com account, then an affidavit to that effect must be provided. C. f plaintiff does not currently have a Bebo.com account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 16. Duly executed, original authorizations for full access to, and copies of plaintiff's current historical records/information for plaintiffs Friendster account. A. The authorization must include the e-mail address linked to this account, along with all other required identifying information. B. f plaintiff has never had a Friendster account, then an affidavit to that effect must be provided.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 C. f plaintiff does not currently have a Friendster account, but had such an account at some prior time, then an affidavit to that effect, including the time frame such an account existed, must be provided. 17. Identify any other social networking site(s) which plaintiff has been a member of from two years prior to the alleged occurrence and date of loss to present. A. Provide duly executed, original authorizations for full access to, and copies of Plaintiff's current historical records/information for each site listed herein. B. The authorization must include the email address linked to this account, along with all other required identifying information. PLEASE TAKE NOTICE that the within demand is a continuing demand. In the event that any of the above items are obtained after service of this demand, they are to be furnished to the undersigned pursuant to this demand. PLEASE TAKE FURTHER NOTICE, that plaintiff and plaintiff's counsel are put on notice that the information in any and/or all of plaintiffs social networking sites has been duly demanded for discovery related to this litigation pursuant to the rules of the Court and the CPLR. The information in any and/or all of plaintiffs social networking sites, photo sites or other sites listed above must not be destroyed, deleted, altered, tampered, spoiled expunged or manipulated in any other way as to obstruct the information as demanded herein. PLEASE TAKE FURTHER NOTICE, that your failure to comply with the foregoing, within twenty (20) days, will serve as the basis of a motion for appropriate relief pursuant to the CPLR. PLEASE TAKE FURTHER NOTICE, that in lieu of producing the items demanded herein, you may serve and submit to the undersigned true and conformed copies of the items demanded herein at any time prior to the aforesaid date.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 DATED: New Y ork, New Y ork June 10, 2022 Y ours, etc., INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023 HANNUM FERETIC PRENDERGAST & MERLINO, LLC Uaniva Carfeenti Marisa Carpentiere Attorneys for Third-Party Defendant QUEENS RESTORATION & CONSTRUCTION, INC., Office and Post Office Address 55 Broadway, Suite 202 New Y ork, New Y ork 10006 (212) 530-3900 TO: William Schwitzer & Associates, P.C. Attorneys for Plaintiff JUAN EDUARDO PEREZ PERALTA 820 Second Avenue, 10th Floor New Y ork, NY 10017 (212) 683-3800 Gold Benes, LLP Attomeys for Defendant/Third-Party Plaintiff CROWN GATES LLC 1666 Newbridge Road, 2nd Floor Bellmore, NY 11710 (516) 512-6333 GONZO CONSTRUCTION CORP. Third-Party Defendant Pro-Se 102-12 27th Avenue East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS xX JUANEDUARDO PEREZ PERALTA, = Index No.: 522746/2021 Plaintiff, DEMAND PURSUANT -against- TO CPLR §4545 CROWN GATES LLC and MORELL BUILDERS INC., Defendants. neceeeeeseceecceeeeeeencececceeeeeeeeseeeeceeeeeeeeseeeeceeeeeeeeenseees xX CROWN GATES LLC, Third-Party Plaintiff, -against- QUEENS RESTORATION & CONSTRUCTION, INC., and GONZO CONSTRUCTION CORP.., Third-Party Defendants. PLEASE TAKE NOTICE, that demand is hereby made upon the plaintiff to serve upon the undersigned a statement as to whether any part of the cost of medical care, custodial care, rehabilitation services, loss of earnings, or other economic loss sought to be recovered herein was replaced or indemnified, in whole or in part, from any collateral sources such as insurance, social security (except those benefits provided under Title 18 the of Social Security Act), Workers’ Compensation or employee benefits programs and, if so, the full name and address of each organization or program providing such replacement or indemnification, together with an itemized statement of the amount in which each such claimed item of economic loss was replaced or indemnified by each such organization or program. Demand is additionally made for duly executed and properly addressed original(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 authorizations permitting the undersigned to inspect and copy all records reflecting any collateral source or payment identified in response to the foregoing demand. PLEASE TAKE FURTHER NOTICE, that your failure to comply with the foregoing, within twenty (20) days, will serve as the basis of a motion for appropriate relief pursuant to the CPLR. DATED: New Y ork, New Y ork June 10, 2022 Y ours, etc., HANNUM FERETIC PRENDERGAST & MERLINO, LLC Marisa Carpentiere Attorneys for Third-Party Defendant QUEENS RESTORATION & CONSTRUCTION, INC. Office and Post Office Address 55 Broadway, Suite 202 New Y ork, New Y ork 10006 (212) 530-3900 TO: William Schwitzer & Associates, P.C. Attorneys for Plaintiff 820 Second Avenue, 10th Floor New Y ork, NY 10017 JUAN EDUARDO PEREZ PERALTA (212) 683-3800 Gold Benes, LLP Attomeys for Defendant/T hird-Party Plaintiff CROWN GATES LLC 1666 Newbridge Road, 2nd Floor Bellmore, NY 11710 (516)512-6333(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 GONZO CONSTRUCTION CORP. Third-Party Defendant Pro-Se 102-12 27th Avenue East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 5 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS xX JUANEDUARDO PEREZPERALTA, Index No.: 522746/2021 Plaintiff, NOTICE FOR -against- DISCOVERY AND INSPECTION CROWN GATES LLC and MORELL BUILDERS INC., Defendants. wee e ee ee eee een eee ene eee eee een ne eee nneene eee nneenneeeeneeee xX CROWN GATES LLC, -against- Third-Party Plaintiff, QUEENS RESTORATION & CONSTRUCTION, INC., and GONZO CONSTRUCTION CORP.., Third-Party Defendants. PLEASE TAKE NOTICE, that pursuant to Article 31 of the CPLR, you are required to serve upon the undersigned attorneys for third-party defendant, QUEENS RESTORATION & CONSTRUCTION, INC., within thirty (30) days of the receipt of this demand for the following: 1. CPLR a. b. SECTION 304 and 306(a) DEMAND Proof of filing of the Summons and Complaint. Affidavits of service upon the Defendant. 2. DEMAND FOR MEDICAL REPORTS AND AUTHORIZATIONS a. The names and addresses of all physicians or other health care providers of every description who have consulted, examined, or treated plaintiff for each of the conditions allegedly caused or exacerbated by the occurrence(s) described in the Verified Complaint, including the dates of such consultation, treatment or examination. 22746/2021 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 b. Duly undersigned to obtain the complete office medical records, including bu not limited to, reports, charts, diagnoses, test results, X-rays, CAT-scans, MRI plaint: c. Co d. Duly hospit inclu e. The names anc hospit ies of all medical reports received from health care providers identifie in “a” above. treated or confined due to the occurrence(s) set forth in the Verifie Complaint, so as to permit to securing of a copy of the entire hospital record, treated, during the five years prior to the occurrence(s) set Verified Complaint, for any condition(s) or injury(ies) to the plaintiff. Also executed and acknowledged written authorizations to allow the images, prescriptions, invoices and technicians’ reports relating to iff from each health care provided identified in “a” above. executed and acknowledged written authorizations directed to any tal, clinic, or other health care facility in which plaintiff is or was ing but not limited to reports, charts, diagnoses, test results, X -rays, CAT-scans, MRI images, prescriptions, invoices and technicians’ reports. addresses of every physician or other health care provider, tal, clinic, or other health care facility which may have examined or forth in the state the dates of such treatment or examination. f. Duly executed and acknowledged written authorizations to allow the defendant to obtain the complete medical records including but not limited to reports, charts, diagnoses, test results, X-rays, CAT-scans, MRI images, prescriptions, invoices and technicians’ reports of any physician or other health care provider, hospital, clinic or o have set forth in the Verified Complaint, plaintiff. g. Duly er health care facility which may e five years prior to the occurrence(s) ‘or any condition(s) or injury(ies) to the examined or treated, during executed and acknowledged written authorizations to allow the undersigned to obtain complete pharmacy or drug store records with respect to any drugs occurrence(s) rescribed for plaintiff from three (3) years prior to the lescribed in the Verified Complaint to the present date. DEMAND FOR WAGE AND COLLATERAL SOURCE INFORMATION AND AUTHORIZATIONS a. All documents that will economic loss, including e used at the trial to establish any claimed but not limited to, bills, canceled checks, insurance forms, etc. for each of the plaintiffs. b. The names and addresses of all institutions, firms, corporations, partnerships, persons, or others by whom plaintiff was employed, and by or from whom plaintiff received a salary and/or income benefits from seven INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 e present date. Duly executed, Complaint to the present date. Duly executed, authorizations permitting the release 7) years prior to the occurrence(s) described in the Verified Complaint to acknowledged and properly addressed written authorizations permitting the release of plaintiff's employment records from seven (7) years prior to the occurrence(s) described in the Verified [he names and addresses of all unions, clubs, health clubs, gyms, or organizations of which plaintiff was a member from seven (7) years prior to the occurrence(s) described in the V erified Complaint to the present date. acknowledged and properly addressed written of all records of the plaintiff with respect to his/her membership in any unions, clubs, health clubs, gyms, or organizations. Serve upon and deliver to the undersigned duly executed and acknowledged written authorizations permitting all parties to obtain and make copies of any and all Worker’s Compensation (provide Worker’s Compensation Board authorization for OC-110A) and No-Fault benefit records, reports, or files relative to this incident. Copies of the income tax returns filed by the plaintiff and the W2 forms received by e plaintiff and filed with le United States Federal Government, and any State or City Govemment from seven (7) years prior to the occurrence(s) described in the V Duly _ executed, erified Complaint to the present date. acknowledged and properly addressed written authorizations directed to the Internal Revenue Service (IRS Form 4506 and 8821) for plaintiff's income tax retur occurrence(s) described in the Veri inclusive. Provide the undersigned all document canceled checks concerming indemnification, ns from seven (7) years prior to the ‘ied Complaint to the present date, s, records, bills, invoices, receipts or payment and/or reimbursement, in whole or in part, which the plaintiff has received from collateral sources, including but not imited to insurance, social security, workers compensation, no-fault or employee benefit programs for the cost of medical care, custodial care, rehabil other economic loss which the plaintifi itation services, loss of earnings and will claim as special damages in this action or which plaintiff will claim were incurred as a result of the occurrence(s) alleged in this action. INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 4, DEMAND FOR PHOTOGRAPHS a. All films, photographs, videotapes and the like of the scene of the alleged occurrence(s) which is the subject of this litigation. b. All films, photographs of any instrumentalities, equipment and other things or objects allegedly involved in this litigation. Cc. All films, photographs and the like of the plaintiffs which demonstrate the injuries allegedly sustained. 5. DEMAND FOR DISCOVERY AND INSPECTION OF ANY STATEMENT OF ANY PARTY REPRESENTED BY THE UNDERSIGNED a. Written statements of any party represented by the undersigned. b. Records, memoranda, notes, tape recordings, or other recorded communications of or by any party represented by the undersigned. 6. DEMAND FOR WITNESS INFORMATION Provide the names and addresses of each person claimed to be a witness of any of the following: a. The occurrence(s) alleged in the Verified Complaint. b. Any acts, omission(s) or condition(s) which allegedly caused the occurrence(s) alleged in the Verified Complaint. c. Any notice of the alleged condition(s) complained of which caused the occurrence(s) alleged in the Verified Complaint. d. The nature and duration of the alleged condition(s) which caused the occurrence(s) alleged in the Verified Complaint. e. Any physical examination, test, consultation, treatment or conversation performed or had by any party represented by the undersigned. f. Any injury or damages sustained by the plaintiff. 7. DEMAND FOR WRITTEN REPORTS Provide true copies of any written reports of the alleged occurrence(s) which have been prepared in the regular course of business, operation or practice of any person, firm, corporation, association, or other public or private entity.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 8. DEMAND FOR INSURANCE INFORMATION Provide copies of the entire contents of any insurance agreement under which any corporation or other entity carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse any party for payments made to satisfy the judgment. 9. DEMAND FOR EXPERT WITNESS DISCLOSURE Provide the name and address of each person whom you expect to call as an expert witness at trial and, with respect to each such witness, set forth the following: a. State the qualifications of each expert witness. b. State with specificity the subject matter upon which each expert is expected to testify at the time of trial. Cc. Provide the facts and opinion upon which each expert is expected to testify at the time of trial. d. Provide a summary of the grounds of each expert’s opinion, and attach any data in support of each opinion and conclusion. 10. DEMAND FOR NAME AND ADDRESS OF ATTORNEYS Provide the name, office address, telephone and facsimile numbers of all attorneys who have appeared on behalf of any party in the above captioned action, and the name of the party represented. PLEASE TAKE NOTICE that, the foregoing demands are continuing demands. In the event that any of the above items are obtained after service of this demand, or service of a response hereto, they are to be furnished to the undersigned forthwith.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 DATED: New Y ork, New Y ork June 10, 2022 Y ours, etc., INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023 HANNUM FERETIC PRENDERGAST & MERLINO, LLC Uaniva Carfeenti Marisa Carpentiere Attorneys for Third-Party Defendant QUEENS RESTORATION & CONSTRUCTION, INC. Office and Post Office Address 55 Broadway, Suite 202 New Y ork, New Y ork 10006 (212) 530-3900 TO: William Schwitzer & Associates, P.C. Attorneys for Plaintiff JUAN EDUARDO PEREZ PERALTA 820 Second Avenue, 10th Floor New Y ork, NY 10017 (212) 683-3800 Gold Benes, LLP Attomeys for Defendant/T hird-Party Plaintiff CROWN GATES LLC 1666 Newbridge Road, 2nd Floor Bellmore, NY 11710 (516) 512-6333 GONZO CONSTRUCTION CORP. Third-Party Defendant Pro-Se 102-12 27th Avenue East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS x JUANEDUARDO PEREZPERALTA, ————™ Index No.: 522746/2021 Plaintiff, NOTICE FOR -against- EXAMINATION BEFORE TRIAL CROWN GATES LLC and MORELL BUILDERS INC., a Defendants. ween e ene n nen ene n ene nen en enn nennnnnnenennnenennne xX CROWN GATES LLC, Third-Party Plaintiff, -against- QUEENS RESTORATION & CONSTRUCTION, INC., and GONZO CONSTRUCTION CORP.., Third-Party Defendants. PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the third-party defendant, QUEENS RESTORATION & CONSTRUCTION, INC., will take the Examination Before Trial upon oral questions, of the plaintiff, JUAN EDUARDO PEREZ PERALTA, at the time and place indicated below, conceming all of the evidence material and necessary in connection with the prosecution and defense of this action. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §3113(b), the deposition conducted may be audiotaped and videotaped simultaneously at the discretion of HANNUM FERETIC PRENDERGAST & MERLINO, LLC.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 PLEASE TAKE FURTHER NOTICE, that pursuant to Rule 3111 of the CPLR, each party is required to produce all books and papers in their possession, control or custody, relating to the issues upon which said party is to be examined. PERSONS TO BE EXAMINED. Plaintiff: JUAN EDUARDO PEREZ PERALTA DATE: September 9, 2022 TIME: 0:00 am PLACE: Hannum Feretic Prendergast & Merlino, LLC 55 Broadway, Suite 202 New Y ork, New Y ork 10006 PLEASE TAKE FURTHER NOTICE, that this is a continuing demand and should any of the information requested become available or known in the future, it is to be immediately furnished to us. If you fail to comply, we shall rely on all sanctions provided by law. DATED: New Y ork, New Y ork June 10, 2022 Y ours, etc., HANNUM FERETIC PRENDERGAST & MERLINO, LLC Marisa Carpentiere Attorneys for Third-Party Defendant QUEENS RESTORATION & CONSTRUCTION, INC. Office and Post Office Address 55 Broadway, Suite 202 New Y ork, New Y ork 10006 (212) 530-3900 TO: William Schwitzer & Associates, P.C. Attorneys for Plaintiff JUAN EDUARDO PEREZ PERALTA 820 Second Avenue, 10th Floor New Y ork, NY 10017 (212) 683-3800(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 Gold Benes, LLP Attomeys for Defendant/T hird-Party Plaintiff CROWN GATES LLC 1666 Newbridge Road, 2nd Floor Bellmore, NY 11710 (516) 512-6333 GONZO CONSTRUCTION CORP. Third-Party Defendant Pro-Se 102-12 27th Avenue East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS xX JUANEDUARDO PEREZ PERALTA, = —t—<“Cisi‘CS Plaintiff, -against- CROWN GATES LLC and MORELL BUILDERS INC., Defendants. wee e ee ee eee een eee ene eee eee een ne eee nneene eee nneenneeeeneeee xX CROWN GATES LLC, Third-Party Plaintiff, -against- QUEENS RESTORATION & CONSTRUCTION, INC., and GONZO CONSTRUCTION CORP.., Third-Party Defendants. PLEASE TAKE NOTICE, that pursuant to CPLR §3121, the plaintiff is directed to present himself or herself for a physical examination as follows: Index No.: 522746/2021 NOTICE FOR PHYSICAL EXAMINATION DATE AND TIME: To Be Determined NAME OF PHYSICIAN: PLACE OF EXAMINATION: INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023 PLEASE TAKE FURTHER NOTICE, that at least twenty (20) days prior to such scheduled examination, plaintiff shall serve on the undersigned, pursuant to such section, duly executed and acknowledged authorizations to obtain all hospital records, and also all records and reports pursuant to the rules relating to exchange of medical information. PLEASE TAKE FURTHER NOTICE, that this is a continuing demand and should any(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 of the information requested become available or known in the future, it is to be immediately furnished to us. If you fail to comply, we shall rely on all sanctions provided by law. DATED: New Y ork, New Y ork June 10, 2022 TO: William Schwitzer & Associates, P.C. Attorneys for Plaintiff JUAN EDUARDO PEREZ PERALTA 820 Second Avenue, 10th Floor New Y ork, NY 10017 (212) 683-3800 Gold Benes, LLP Y ours, etc., HANNUM FERETIC PRENDERGAST & MERLINO, LLC Marisa Carpentiere Attorneys for Third-Party Defendant QUEENS RESTORATION & CONSTRUCTION, INC. Office and Post Office Address 55 Broadway, Suite 202 New Y ork, New Y ork 10006 (212) 530-3900 Attomeys for Defendant/Third-Party Plaintiff CROWN GATES LLC 1666 Newbridge Road, 2nd Floor Bellmore, NY 11710 (516)512-6333 GONZO CONSTRUCTION CORP. Third-Party Defendant Pro-Se 102-12 27th Avenue East Elmhurst, NY 11369(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM INDEX NO. 522746/2021 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 03/07/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ee Xx JUAN EDUARDO PEREZ PERALTA, Index No.: 2746/2001 Plaintiff, . NOTICE TO PRODUCE -against- RETAINER AGREEMENT CROWN GATES LLC and MORELL BUILDERS INC., Defendants. wee eee cece eee eee eee nee ee ence eee een ee eee eeee eee eeeeeeeeeeeeeeeeee X CROWN GATES LLC, Third-Party Plaintiff, -against- QUEENS RESTORATION & CONSTRUCTION, INC., and GONZO CONSTRUCTION CORP.., Third-Party Defendants. PLEASE TAKE NOTICE, that pursuant to CPLR § 3101(a), the plaintiff is hereby required to produce a copy of the plaintiff's retainer agreement with his/her attorney for the subject action within thirty days of the date of service hereof upon you. Priest v. Hennessy, 51 N.Y.2d 62, 409 N.E.2d 983, 431 N.Y.S.2d 511 (1980); Rumrill-Hoyt Inc. v. Perri, 97 A.D.2d 951, 468 N.Y.S.2d 754 (4" Dept. 1983). The retainer agreement may be redacted in any respect, except the date and plaintiff's signature. PLEASE TAKE FURTHER NOTICE, that this is a continuing demand and failure to comply will result in preclusion of any testimony regarding the items demanded.(FILED: KINGS COUNTY CLERK 0370772023 12:32 PM NYSCEF DOC. NO. 73 DATED: New Y ork, New Y ork June 10, 2022 Y ours, etc., INDEX NO. 522746/2021 RECEIVED NYSCEF: 03/07/2023 HANNUM FERETIC PRENDERGAST & MERLINO, LLC Uaniva Carfeenti Marisa Carpentiere Attorneys for Third-Party Defendant QUEENS RESTORATION & CONSTRUCTION, INC. Office and Post Office Address 55 Broadway, Suite 202 New Y ork, New Y ork 10006 (212) 530-3900 TO: William Schwitzer & Associates, P.C. Attorneys for Plaintiff JUAN EDUARDO PEREZ PERALTA 820 Second Avenue, 10th Floor New Y ork, NY 10017 (212) 683-3800 Gold Benes, LLP Attomeys for Defendant/T hird-Party Plaintiff CROWN GATES LLC 1666 Newbridge Road, 2nd Floor Bellmore, NY 11710 (516) 512-6333 GONZO CONSTRUCTION CORP. Third-Party Defendant Pro-Se 102-12 27th Avenue East Elmhurst, NY 11369