On March 17, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Rebecca M. Flanders,
and
Michelle Goodfellow,
Stephen F. Goodfellow,
for Torts - Other (Dog Bite)
in the District Court of Onondaga County.
Preview
FILED: ONONDAGA COUNTY CLERK 04/01/2021 04:29 PM INDEX NO. 002769/2020
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 04/01/2021
EXHIBIT C
FILED: ONONDAGA COUNTY CLERK 04/01/2021 04:29 PM INDEX NO. 002769/2020
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 04/01/2021
STATE OF NEW YORK
SUPREME COURT: COUNTY OF MADISON
REBECCA M. FLANDERS,
Plaintiff, SECOND NOTICE FOR
DISCOVERY
v. AND INSPECTION
STEPHEN F. GOODFELLOW, Index No.: 002769/2020
MICHELLE GOODFELLOW,
Defendants
PLEASE TAKE NOTICE that the Defendants, STEPHEN F. GOODFELLOW and
MICHELLE GOODFELLOW, pursuant to CPLR 3101 et seq. and CPLR 3120, are required to
produce and allow discovery, inspection and copying to be made by the Plaintiff and attorney(s)
for the Plaintiff of the following items, writings, and objects maintained, controlled or supervised
by the Defendants or the agents, servants and/or employees of the Defendants, within twenty (20)
days of the service of this notice. In lieu of strict compliance with the terms and conditions of this
Notice, the undersigned will accept clearly legible photocopies of said items if received by the
undersigned at least (5) days prior to the return date hereof, together with a letter from the attorney
for the Defendants advising as to the completeness of the items provided.
PLACE OF DISCOVERY: Office of WILLIAM MATTAR, P.C., 6720 Main Street, Suite 100,
Williamsville, NY 14221-5986.
[TEMS TO BE PRODUCED:
(1) All correspandences, invoices, receipts, documents, memorañda, text messages, emails,
etc. exchanged with Gregory Gorman;
(2) Gregory Gorman's address and telephone number;
"Nest"
(3) All or other video footage documenting the behavior of the dog involved in the
incident which forms the basis of the Complaint on and before December 8, 2018;
"Nest" defendants'
(4) All or other video footage documenting or relating to in-person meeting
with Gregory Gorman;
FILED: ONONDAGA COUNTY CLERK 04/01/2021 04:29 PM INDEX NO. 002769/2020
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 04/01/2021
PLEASE TAKE FURTHER NOTICE that all demands contained herein are continuing
demands up to and including the time of Trial. Any items obtained aAer service of this demand
are to be furnished to this office within ten (10) days of your receipt thereof.
PLEASE TAKE FURTHER NOTICE that if you fail to comply with this Notice for
Discovery and Inspection, or any part thereof, we shall rely on all sanctions provided under law.
DATED: January 29, 2021
s/Duane D. Schoonmaker
Duane D. Schoonmaker, Esq.
WILLIAM MATTAR, P.C.
Attomeys for Plaintiff
Office and Post Office Address
6720 Main Street, Suite 100
Williamsville, NY 14221-5986
(716) 633-3535
TO: Donyelle Eller, Esq.
Martyn and Martyn
Attorneys for Defendants
Office and Post Office Address
330 Old Country Road, Suite 211
Mineola, NY 11501
(516) 739-0000
Document Filed Date
April 01, 2021
Case Filing Date
March 17, 2020
Category
Torts - Other (Dog Bite)
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FILED: ONONDAGA COUNTY CLERK 04/01/2021 04:29 PM INDEX NO. 002769/2020 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 04/01/2021 EXHIBIT C FILED: ONONDAGA COUNTY CLERK 04/01/2021 04:29 PM INDEX NO. 002769/2020 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 04/01/2021 STATE OF NEW YORK SUPREME COURT: COUNTY OF MADISON REBECCA M. FLANDERS, Plaintiff, SECOND NOTICE FOR DISCOVERY v. AND INSPECTION STEPHEN F. GOODFELLOW, Index No.: 002769/2020 MICHELLE GOODFELLOW, Defendants PLEASE TAKE NOTICE that the Defendants, STEPHEN F. GOODFELLOW and MICHELLE GOODFELLOW, pursuant to CPLR 3101 et seq. and CPLR 3120, are required to produce and allow discovery, inspection and copying to be made by the Plaintiff and attorney(s) for the Plaintiff of the following items, writings, and objects maintained, controlled or supervised by the Defendants or the agents, servants and/or employees of the Defendants, within twenty (20) days of the service of this notice. In lieu of strict compliance with the terms and conditions of this Notice, the undersigned will accept clearly legible photocopies of said items if received by the undersigned at least (5) days prior to the return date hereof, together with a letter from the attorney for the Defendants advising as to the completeness of the items provided. PLACE OF DISCOVERY: Office of WILLIAM MATTAR, P.C., 6720 Main Street, Suite 100, Williamsville, NY 14221-5986. [TEMS TO BE PRODUCED: (1) All correspandences, invoices, receipts, documents, memorañda, text messages, emails, etc. exchanged with Gregory Gorman; (2) Gregory Gorman's address and telephone number; "Nest" (3) All or other video footage documenting the behavior of the dog involved in the incident which forms the basis of the Complaint on and before December 8, 2018; "Nest" defendants' (4) All or other video footage documenting or relating to in-person meeting with Gregory Gorman; FILED: ONONDAGA COUNTY CLERK 04/01/2021 04:29 PM INDEX NO. 002769/2020 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 04/01/2021 PLEASE TAKE FURTHER NOTICE that all demands contained herein are continuing demands up to and including the time of Trial. Any items obtained aAer service of this demand are to be furnished to this office within ten (10) days of your receipt thereof. PLEASE TAKE FURTHER NOTICE that if you fail to comply with this Notice for Discovery and Inspection, or any part thereof, we shall rely on all sanctions provided under law. DATED: January 29, 2021 s/Duane D. Schoonmaker Duane D. Schoonmaker, Esq. WILLIAM MATTAR, P.C. Attomeys for Plaintiff Office and Post Office Address 6720 Main Street, Suite 100 Williamsville, NY 14221-5986 (716) 633-3535 TO: Donyelle Eller, Esq. Martyn and Martyn Attorneys for Defendants Office and Post Office Address 330 Old Country Road, Suite 211 Mineola, NY 11501 (516) 739-0000