On December 09, 2019 a
Exhibit,Appendix
was filed
involving a dispute between
A. H.
An Infant Under The Age Of 14 Years By His Mother And Natural Guardian, Elvira Rodriguez,
E. Q.
And,
Lilia Robles
Individually,
L. M. Q.
Both Infants Under The Age Of 14 Years By Their Father And Natural Guardian, Miguel Angel Espejo Quezada,
Miguel Angel Espejo Quezada
And,
and
Auto Driving Corona,
Jose D Garcia,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 01/14/2021 03:45 PM INDEX NO. 526694/2019
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 01/14/2021
"E"
EXHIBIT
FILED: KINGS COUNTY CLERK 01/14/2021 03:45 PM INDEX NO. 526694/2019
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 01/14/2021
P P
PEKNIC, PEKNIC
Cs SCHAEFER.
BRIAN M. PEKNIC 1005 West Beech Street LOREEN M. PEKNIC
CHARLES M. PEKNIC Long Beach, New York 7 756 7 CATHERINE PAPANDREW
SEAN W.5CHAEFER Phone 5 76.432.9400 THOMAS J. TYRRELL, JR.
- Fax 516.432.5396
MATTHEW R. BRUZZESE ElLEEN EVERS PATTON
OF COUNSEL
January 29, 2020
KHAVINSON & ASSOCIATES, P.C.
1601 Gravesend Neck Road, Suite #903
Brooklyn, New York 11229
Re: E.Q., and L.M.Q., infants, et. al. v. JOSE D. GARCIA, et. al.
D/A: 10/27/19
Our File No.: LNCR/014/19
Your File No.: E-06536
Dear Sir / Madam:
Please be advised that on DECEMBER 31, 2019, our office appeared on behalf of Defendants
regarding the above said case. Our office served a Verified Answer with Affirmative Defenses, along
with Demands for a Verified Bill of Particulars, Combhed Discovery and Inspection, Independent
Medical Examimtions, Pre-Surgical Independent Medical Examinations, Social Media Preservation,
Medicaid/Medicare Information and Depositions. To date, we have not received a response from
your office regarding any of these demands.
In a good faith effort to avoid annecessary motion practice, please forward the above said requested
plea to our office within ten (10) days hereof. Failure to provide these pleadings willresult in our
of ce filing a Motion to Compel and Preclude the Plaintiff
If you require any additional information, please contact the undersigned. Thank you for your
anticipated cooperation and courtesy in this matter.
Very . ours,
SEA SCHAEFER, ESQ.
SWS /jto
Document Filed Date
January 14, 2021
Case Filing Date
December 09, 2019
Category
Torts - Motor Vehicle
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FILED: KINGS COUNTY CLERK 01/14/2021 03:45 PM INDEX NO. 526694/2019 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 01/14/2021 "E" EXHIBIT FILED: KINGS COUNTY CLERK 01/14/2021 03:45 PM INDEX NO. 526694/2019 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 01/14/2021 P P PEKNIC, PEKNIC Cs SCHAEFER. BRIAN M. PEKNIC 1005 West Beech Street LOREEN M. PEKNIC CHARLES M. PEKNIC Long Beach, New York 7 756 7 CATHERINE PAPANDREW SEAN W.5CHAEFER Phone 5 76.432.9400 THOMAS J. TYRRELL, JR. - Fax 516.432.5396 MATTHEW R. BRUZZESE ElLEEN EVERS PATTON OF COUNSEL January 29, 2020 KHAVINSON & ASSOCIATES, P.C. 1601 Gravesend Neck Road, Suite #903 Brooklyn, New York 11229 Re: E.Q., and L.M.Q., infants, et. al. v. JOSE D. GARCIA, et. al. D/A: 10/27/19 Our File No.: LNCR/014/19 Your File No.: E-06536 Dear Sir / Madam: Please be advised that on DECEMBER 31, 2019, our office appeared on behalf of Defendants regarding the above said case. Our office served a Verified Answer with Affirmative Defenses, along with Demands for a Verified Bill of Particulars, Combhed Discovery and Inspection, Independent Medical Examimtions, Pre-Surgical Independent Medical Examinations, Social Media Preservation, Medicaid/Medicare Information and Depositions. To date, we have not received a response from your office regarding any of these demands. In a good faith effort to avoid annecessary motion practice, please forward the above said requested plea to our office within ten (10) days hereof. Failure to provide these pleadings willresult in our of ce filing a Motion to Compel and Preclude the Plaintiff If you require any additional information, please contact the undersigned. Thank you for your anticipated cooperation and courtesy in this matter. Very . ours, SEA SCHAEFER, ESQ. SWS /jto