Preview
FILED: NEW YORK COUNTY CLERK 06/01/2023 03:41 PM INDEX NO. 161241/2020
NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 06/01/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----------------------------------------------------------------------
SEAN YOUNG and KIMBERLY YOUNG,
POST DEPOSITION
Plaintiffs DEMANDS
-against- Index No: 161241/2020
JAMESTOWN 450 WEST 15TH STREET L.P., tp# 595299/2022
JAMESTOWN PROPERTIES CORP.,
AGB 15TH STREET L.L.C, MILK STUDIOS,
LLC, BRODERVILLE PICTURES and NORTHERN
VARIABLE, LLC D/B/A WINDMILL STUDIOS,
Defendants.
------------------------------------------------------------------------
MILK STUDIOS, LLC.,
Third-Party Plaintiff,
-against-
BRODERVILLE PICTURES and NORTHERN
VARIABLE, LLC D/B/A WINDMILL STUDIOS NYC.,
Third-party Defendant.
------------------------------------------------------------------------
MILK STUDIOS, LLC,
Second Third-Party Plaintiff,
-against-
MINUS L, INC., SHAWN ANNABEL and FIFTH PLANET
FILMS, LLC.
Second Third-Party Defendants.
----------------------------------------------------------------------------
C O U N S E L O R S:
PLEASE TAKE NOTICE, that the defendant MILK STUDIOS, LLC, by their attorneys
the Law Offices of Terrence F. Kuhn, pursuant to CPLR §3101, 3120 and the Rules of the
1 of 4
FILED: NEW YORK COUNTY CLERK 06/01/2023 03:41 PM INDEX NO. 161241/2020
NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 06/01/2023
Appellate Division, hereby demands that the Third-Party Defendant BRODERVILLE PICTURES
or their attorney serve upon and deliver to the undersigned attorney for the defendants within
twenty (20) days of receipt of this notice:
1) A copy of the full and complete executed contract/agreement between
Broderville Pictures and Milk Studios regarding the FW 2019 Addidas event in question;
2) A copy of the full and complete executed contract/agreement between
Broderville Pictures and Addidas regarding the production of the FW 2019 Addidas event in
question;
3) A copy of the full and complete executed contract/agreement between
Broderville and Craig DiBiase and/or Minus L regarding the FW 2019 Addidas event in question;
4) Copies of all invoices, billings and payments made as between Broderville
Pictures and Craig DiBiase and/or Minus L regarding the FW 2019 Addidas event in question;
5) Copies of all written and/or digital communications as between Broderville
Pictures and Craig DiBiase and/or Minus L regarding the FW 2019 Addidas event in question;
6) A copy of the full and complete executed contract/agreement between
Broderville and Shawn Annabel regarding the FW 2019 Addidas event in question;
7) Copies of all invoices, billings and payments made as between Broderville
Pictures and Shawn Annabel regarding the FW 2019 Addidas event in question;
8) Copies of all written and/or digital communications as between Broderville
Pictures and Shawn Annabel regarding the FW 2019 Addidas event in question;
9) A copy of the full and complete executed contract/agreement between
Broderville and Colin Foster and/or Fifth Planet Films regarding the FW 2019 Addidas event in
question;
2 of 4
FILED: NEW YORK COUNTY CLERK 06/01/2023 03:41 PM INDEX NO. 161241/2020
NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 06/01/2023
10) Copies of all invoices, billings and payments made as between Broderville
Pictures and Colin Foster and/or Fifth Planet Films regarding the FW 2019 Addidas event in
question;
11) Copies of all written and/or digital communications as between Broderville
Pictures and Colin Foster and/or Fifth Planet Films regarding the FW 2019 Addidas event in
question;
12) Copy of the full and complete project file(s) of Broderville Pictures for the
FW 2019 Addidas event in question, and;
13) Copies of all policies of insurance and certificates of insurance as procured
by Broderville Pictures, their independent contractors, their contractors and/or subcontractors as
retained for and relative to the FW 2019 Addidas event in question.
PLEASE TAKE FURTHER NOTICE, that in the event you should fail to comply with
this notice for discovery and inspection, a motion will be made seeking to impose sanctions
pursuant to CPLR 3126.
Dated: New York, New York
June 1, 2023
Curtis B. Gilfillan
______________________________
Curtis B. Gilfillan, Esq.
Law Offices of Terrence F. Kuhn
Attorneys for Defendant
MILK STUDIOS, LLC
PENN 1
One Pennsylvania Plaza
50th Floor / Suite 5003
New York, NY 10119
Tel. No.: (212) 553-8700
File No.: Y2KL05308-001/CBG/lg
TO: Weitz & Luxenberg,
Gary Klein, Esq.
Attorneys for Plaintiff
3 of 4
FILED: NEW YORK COUNTY CLERK 06/01/2023 03:41 PM INDEX NO. 161241/2020
NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 06/01/2023
SEAN YOUNG AND KIMBERLY YOUNG
700 Broadway,
New York, NY 10003
Gklein@weitzlux.com
Correia, King, McGinnis & Liferiedge
Vincent Brescia, Esq.
Attorneys for Defendants
JAMESTOWN 450 WEST 15TH STREET, L.P.
and JAMESTOWN PROPERTIES CORP.
One Battery Park Plaza
29th Floor
New York, NY 10004
Vincent.Brescia@LibertyMutual.com
HAWORTH BARBER & GERTMAN, LLC,
Richard Barber Esq.,
Attorney for Third-Party Defendant
NORTHERN VARIABLE D/B/A
WINDMILL STUDIO NUC I/H/H/A “WINDMILL
STUDIOS NYC,”
777 Third Avenue, Suite 2104
New York, NY 10017
Phone: (212) 952-1100
Fax.: (212) 952-1110
richard.barber@hbandglaw.com
MORRIS, DUFFY, ALONSO, FALEY & PITCOFF
By: William J. Manning, Jr. Esq.,
Attorneys for Third-Party Defendant
BRODERVILLE PICTURES
101 Greenwich Street, 22nd Floor
New York, NY 10006
(212) 766-1888
File No.: (FIF) 74103
wmanning@mdafny.com
4 of 4
Preview
FILED: NEW YORK COUNTY CLERK 06/01/2023 03:41 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 06/01/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------------------------------------- SEAN YOUNG and KIMBERLY YOUNG, POST DEPOSITION Plaintiffs DEMANDS -against- Index No: 161241/2020 JAMESTOWN 450 WEST 15TH STREET L.P., tp# 595299/2022 JAMESTOWN PROPERTIES CORP., AGB 15TH STREET L.L.C, MILK STUDIOS, LLC, BRODERVILLE PICTURES and NORTHERN VARIABLE, LLC D/B/A WINDMILL STUDIOS, Defendants. ------------------------------------------------------------------------ MILK STUDIOS, LLC., Third-Party Plaintiff, -against- BRODERVILLE PICTURES and NORTHERN VARIABLE, LLC D/B/A WINDMILL STUDIOS NYC., Third-party Defendant. ------------------------------------------------------------------------ MILK STUDIOS, LLC, Second Third-Party Plaintiff, -against- MINUS L, INC., SHAWN ANNABEL and FIFTH PLANET FILMS, LLC. Second Third-Party Defendants. ---------------------------------------------------------------------------- C O U N S E L O R S: PLEASE TAKE NOTICE, that the defendant MILK STUDIOS, LLC, by their attorneys the Law Offices of Terrence F. Kuhn, pursuant to CPLR §3101, 3120 and the Rules of the 1 of 4 FILED: NEW YORK COUNTY CLERK 06/01/2023 03:41 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 06/01/2023 Appellate Division, hereby demands that the Third-Party Defendant BRODERVILLE PICTURES or their attorney serve upon and deliver to the undersigned attorney for the defendants within twenty (20) days of receipt of this notice: 1) A copy of the full and complete executed contract/agreement between Broderville Pictures and Milk Studios regarding the FW 2019 Addidas event in question; 2) A copy of the full and complete executed contract/agreement between Broderville Pictures and Addidas regarding the production of the FW 2019 Addidas event in question; 3) A copy of the full and complete executed contract/agreement between Broderville and Craig DiBiase and/or Minus L regarding the FW 2019 Addidas event in question; 4) Copies of all invoices, billings and payments made as between Broderville Pictures and Craig DiBiase and/or Minus L regarding the FW 2019 Addidas event in question; 5) Copies of all written and/or digital communications as between Broderville Pictures and Craig DiBiase and/or Minus L regarding the FW 2019 Addidas event in question; 6) A copy of the full and complete executed contract/agreement between Broderville and Shawn Annabel regarding the FW 2019 Addidas event in question; 7) Copies of all invoices, billings and payments made as between Broderville Pictures and Shawn Annabel regarding the FW 2019 Addidas event in question; 8) Copies of all written and/or digital communications as between Broderville Pictures and Shawn Annabel regarding the FW 2019 Addidas event in question; 9) A copy of the full and complete executed contract/agreement between Broderville and Colin Foster and/or Fifth Planet Films regarding the FW 2019 Addidas event in question; 2 of 4 FILED: NEW YORK COUNTY CLERK 06/01/2023 03:41 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 06/01/2023 10) Copies of all invoices, billings and payments made as between Broderville Pictures and Colin Foster and/or Fifth Planet Films regarding the FW 2019 Addidas event in question; 11) Copies of all written and/or digital communications as between Broderville Pictures and Colin Foster and/or Fifth Planet Films regarding the FW 2019 Addidas event in question; 12) Copy of the full and complete project file(s) of Broderville Pictures for the FW 2019 Addidas event in question, and; 13) Copies of all policies of insurance and certificates of insurance as procured by Broderville Pictures, their independent contractors, their contractors and/or subcontractors as retained for and relative to the FW 2019 Addidas event in question. PLEASE TAKE FURTHER NOTICE, that in the event you should fail to comply with this notice for discovery and inspection, a motion will be made seeking to impose sanctions pursuant to CPLR 3126. Dated: New York, New York June 1, 2023 Curtis B. Gilfillan ______________________________ Curtis B. Gilfillan, Esq. Law Offices of Terrence F. Kuhn Attorneys for Defendant MILK STUDIOS, LLC PENN 1 One Pennsylvania Plaza 50th Floor / Suite 5003 New York, NY 10119 Tel. No.: (212) 553-8700 File No.: Y2KL05308-001/CBG/lg TO: Weitz & Luxenberg, Gary Klein, Esq. Attorneys for Plaintiff 3 of 4 FILED: NEW YORK COUNTY CLERK 06/01/2023 03:41 PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 06/01/2023 SEAN YOUNG AND KIMBERLY YOUNG 700 Broadway, New York, NY 10003 Gklein@weitzlux.com Correia, King, McGinnis & Liferiedge Vincent Brescia, Esq. Attorneys for Defendants JAMESTOWN 450 WEST 15TH STREET, L.P. and JAMESTOWN PROPERTIES CORP. One Battery Park Plaza 29th Floor New York, NY 10004 Vincent.Brescia@LibertyMutual.com HAWORTH BARBER & GERTMAN, LLC, Richard Barber Esq., Attorney for Third-Party Defendant NORTHERN VARIABLE D/B/A WINDMILL STUDIO NUC I/H/H/A “WINDMILL STUDIOS NYC,” 777 Third Avenue, Suite 2104 New York, NY 10017 Phone: (212) 952-1100 Fax.: (212) 952-1110 richard.barber@hbandglaw.com MORRIS, DUFFY, ALONSO, FALEY & PITCOFF By: William J. Manning, Jr. Esq., Attorneys for Third-Party Defendant BRODERVILLE PICTURES 101 Greenwich Street, 22nd Floor New York, NY 10006 (212) 766-1888 File No.: (FIF) 74103 wmanning@mdafny.com 4 of 4