Preview
FILED: NASSAU COUNTY CLERK 05/04/2023 11:49 AM INDEX NO. 601520/2019
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 05/04/2023
EXHIBIT L
08/31/2022 11:49
FILED: NASSAU COUNTY CLERK 05/04/2023 05:38 AM
PM INDEX NO. 601520/2019
30
NYSCEF DOC. NO. 52 08/31/2022
RECEIVED NYSCEF: 05/04/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
_____________,--------------------------------------------------------_Ç
JOSE L. PEREZ, Index No: 601520/2019
Plaintiff, RESPONSE TO
DEFENDANTS'
NOTICE
-against- OF DISCOVERY AND
INSPECTION
KORESH ALAN KAYPOUR, as Executor of the
Estate of NINA KAYPOUR and ALAN K. KAYPOUR,
Defendants.
----------------------------------------------------------------------x
COUNSELORS:
PLEASE TAKE NOTICE, that plaintiff by his attorneys, SILBERSTEIN AWAD &
MIKLOS, P.C., hereby responds to defendants, KORESH ALAN KAYPOUR, as Executor of the
Estate of NINA KAYPOUR and ALAN K. KAYPOUR's Notice of Discovery and Inspection,
dated June 8, 2020, upon information and belief as follows:
1. Objection. Plaintiff was not involved in a motor vehicle accident on 5/15/2016.
2. Objection. Plaintiff was not involved in a motor vehicle accident on 2/6/2015.
3. Objection. Plaintiff was not involved in a motor vehicle accident on 9/15/2013.
4. Objection. Plaintiff was not involved in a motor vehicle accident on 2/15/2010.
5. Refer to paragraph number 4 above.
PLEASE TAKE NOTICE, plaintiff reserves the right to supplement this response up to
and including the time of trial.
Dated: Garden City, New York
August 31, 2022
1 of 2
08/31/2022 11:49
FILED: NASSAU COUNTY CLERK 05/04/2023 05:38 AM
PM INDEX NO. 601520/2019
30
NYSCEF DOC. NO. 52 08/31/2022
RECEIVED NYSCEF: 05/04/2023
Yours, etc.,
SILBERSTEIN, AWAD & MIKLOS, PC
By:
ERIC S. VOGEL, E .
Attorneys for Plaintiff
JOSE L. PEREZ
600 Old Country Road, Suite 505
Garden City, New York 11530
(516) 832-7777
File No.: 9144
To: LAW OFICE OF ERIC D. FELDMAN
Attorneys for Defendants
KORESH ALAN KAYPOUR, as Executor of the Estate of
NINA KAYPOUR and ALAN K. KAYPOUR
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
(631) 501-3100
File No.: 2019058285PM
Lorraine H. Sparago, Esq.
2 of 2
08/31/2022 11:49
FILED: NASSAU COUNTY CLERK 05/04/2023 05:38 AM
PM INDEX NO. 601520/2019
31
NYSCEF DOC. NO. 52 08/31/2022
RECEIVED NYSCEF: 05/04/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
___..--..---_ ___- ________-..........--...._ __________-.........._ ____------______..__Ç
JOSE L. PEREZ, Index No: 601520/2019
Plaintiff, RESPONSE TO
DEFENDANTS$
-against- AMENDED NOTICE
OF DISCOVERY
AND INSPECTION
KORESH ALAN KAYP OUR, as Executor of the
Estate of NINA KAYPOUR and ALAN K. KAYPOUR,
Defendants.
..------------------............._ _------------....---- ________..............x
COUNSELORS:
PLEASE TAKE NOTICE, that plaintiff by his attorneys, SILBERSTEIN AWAD &
MIKLOS, P.C., hereby responds to defendants, KORESH ALAN KAYPOUR, as Executor of the
Estate of NINA KAYPOUR and ALAN K. KAYPOUR's Notice of Discovery and Inspection,
dated August 4, 2021, upon information and belief as follows:
1. Objection. Plaintiff has not been treated or examined by any provider with regards
to his spine prior to the subject accident.
2. Will be provided under separate cover.
PLEASE TAKE NOTICE, plaintiff reserves the right to supplement this response up to
and including the time of trial.
Dated: Garden City, New York
August 3 1, 2022
1 of 2
08/31/2022 11:49
FILED: NASSAU COUNTY CLERK 05/04/2023 05:38 AM
PM INDEX NO. 601520/2019
31
NYSCEF DOC. NO. 52 08/31/2022
RECEIVED NYSCEF: 05/04/2023
Yours, etc.,
SILBERSTEIN, AWAD & MIKLOS, PC
By:
ERIC S. VOGEL, Q.
Attorneys for Plaintiff
JOSE L. PEREZ
600 Old Country Road, Suite 505
Garden City, New York 11530
(516) 832-7777
File No.: 9144
To: LAW OFICE OF ERIC D. FELDMAN
Attorneys for Defendants
KORESH ALAN KAYPOUR, as Executor of the Estate of
NINA KAYPOUR and ALAN K. KAYPOUR
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
(631) 501-3100
File No.: 2019058285PM
Lorraine H. Sparago, Esq.
2 of 2
Preview
FILED: NASSAU COUNTY CLERK 05/04/2023 11:49 AM INDEX NO. 601520/2019 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 05/04/2023 EXHIBIT L 08/31/2022 11:49 FILED: NASSAU COUNTY CLERK 05/04/2023 05:38 AM PM INDEX NO. 601520/2019 30 NYSCEF DOC. NO. 52 08/31/2022 RECEIVED NYSCEF: 05/04/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU _____________,--------------------------------------------------------_Ç JOSE L. PEREZ, Index No: 601520/2019 Plaintiff, RESPONSE TO DEFENDANTS' NOTICE -against- OF DISCOVERY AND INSPECTION KORESH ALAN KAYPOUR, as Executor of the Estate of NINA KAYPOUR and ALAN K. KAYPOUR, Defendants. ----------------------------------------------------------------------x COUNSELORS: PLEASE TAKE NOTICE, that plaintiff by his attorneys, SILBERSTEIN AWAD & MIKLOS, P.C., hereby responds to defendants, KORESH ALAN KAYPOUR, as Executor of the Estate of NINA KAYPOUR and ALAN K. KAYPOUR's Notice of Discovery and Inspection, dated June 8, 2020, upon information and belief as follows: 1. Objection. Plaintiff was not involved in a motor vehicle accident on 5/15/2016. 2. Objection. Plaintiff was not involved in a motor vehicle accident on 2/6/2015. 3. Objection. Plaintiff was not involved in a motor vehicle accident on 9/15/2013. 4. Objection. Plaintiff was not involved in a motor vehicle accident on 2/15/2010. 5. Refer to paragraph number 4 above. PLEASE TAKE NOTICE, plaintiff reserves the right to supplement this response up to and including the time of trial. Dated: Garden City, New York August 31, 2022 1 of 2 08/31/2022 11:49 FILED: NASSAU COUNTY CLERK 05/04/2023 05:38 AM PM INDEX NO. 601520/2019 30 NYSCEF DOC. NO. 52 08/31/2022 RECEIVED NYSCEF: 05/04/2023 Yours, etc., SILBERSTEIN, AWAD & MIKLOS, PC By: ERIC S. VOGEL, E . Attorneys for Plaintiff JOSE L. PEREZ 600 Old Country Road, Suite 505 Garden City, New York 11530 (516) 832-7777 File No.: 9144 To: LAW OFICE OF ERIC D. FELDMAN Attorneys for Defendants KORESH ALAN KAYPOUR, as Executor of the Estate of NINA KAYPOUR and ALAN K. KAYPOUR Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 (631) 501-3100 File No.: 2019058285PM Lorraine H. Sparago, Esq. 2 of 2 08/31/2022 11:49 FILED: NASSAU COUNTY CLERK 05/04/2023 05:38 AM PM INDEX NO. 601520/2019 31 NYSCEF DOC. NO. 52 08/31/2022 RECEIVED NYSCEF: 05/04/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ___..--..---_ ___- ________-..........--...._ __________-.........._ ____------______..__Ç JOSE L. PEREZ, Index No: 601520/2019 Plaintiff, RESPONSE TO DEFENDANTS$ -against- AMENDED NOTICE OF DISCOVERY AND INSPECTION KORESH ALAN KAYP OUR, as Executor of the Estate of NINA KAYPOUR and ALAN K. KAYPOUR, Defendants. ..------------------............._ _------------....---- ________..............x COUNSELORS: PLEASE TAKE NOTICE, that plaintiff by his attorneys, SILBERSTEIN AWAD & MIKLOS, P.C., hereby responds to defendants, KORESH ALAN KAYPOUR, as Executor of the Estate of NINA KAYPOUR and ALAN K. KAYPOUR's Notice of Discovery and Inspection, dated August 4, 2021, upon information and belief as follows: 1. Objection. Plaintiff has not been treated or examined by any provider with regards to his spine prior to the subject accident. 2. Will be provided under separate cover. PLEASE TAKE NOTICE, plaintiff reserves the right to supplement this response up to and including the time of trial. Dated: Garden City, New York August 3 1, 2022 1 of 2 08/31/2022 11:49 FILED: NASSAU COUNTY CLERK 05/04/2023 05:38 AM PM INDEX NO. 601520/2019 31 NYSCEF DOC. NO. 52 08/31/2022 RECEIVED NYSCEF: 05/04/2023 Yours, etc., SILBERSTEIN, AWAD & MIKLOS, PC By: ERIC S. VOGEL, Q. Attorneys for Plaintiff JOSE L. PEREZ 600 Old Country Road, Suite 505 Garden City, New York 11530 (516) 832-7777 File No.: 9144 To: LAW OFICE OF ERIC D. FELDMAN Attorneys for Defendants KORESH ALAN KAYPOUR, as Executor of the Estate of NINA KAYPOUR and ALAN K. KAYPOUR Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 (631) 501-3100 File No.: 2019058285PM Lorraine H. Sparago, Esq. 2 of 2