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FILED: KINGS COUNTY CLERK 01/25/2022 02:10 PM INDEX NO. 522690/2021
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/25/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
JEAN ALMONTE-MORENO, SUPPLEMENTAL
NOTICE FOR
Plaintiff(s), DISCOVERY AND
INSPECTION TO
-against- PLAINTIFF
VIVIAN KEITA, JUDE E. KEITA AND JOSE TEVEZ, Index Number: 522690/21
Defendant(s),
Please take notice that pursuant to CPLR 3101 and 3120, plaintiff is hereby required to
produce for Discovery and Inspection at the offices of James F. Butler & Associates, P. O. Box
9040, 300 Jericho Quadrangle, Suite 260, Jericho, NY, attorneys for defendants, Vivian Keita
and Jude E. Keita, within thirty (30) days after the service of this demand, the following:
As to the prior accident of November 30, 2019:
ï‚· Duly executed and acknowledged original HIPAA compliant authorization permit-
ting the release of plaintiff's complete records from Progressive, claim #
0120193883309;
ï‚· Duly executed and acknowledged original HIPAA compliant authorization permit-
ting the release of plaintiff's complete records from Gallagher Bassett Services,
claim # 005857000601AB01.
As to the prior accident of August 25, 2020:
ï‚· Duly executed and acknowledged original HIPAA compliant authorization per-
mitting the release of plaintiff's complete records from Progressive, claim #
0120205992400.
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FILED: KINGS COUNTY CLERK 01/25/2022 02:10 PM INDEX NO. 522690/2021
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/25/2022
These documents and things are to be produced within thirty (30) days of the date of the
demand at the office of James F. Butler & Associates, at 10:00 o’clock in the forenoon. Compli-
ance may be effectuated by sending true, readable and legible copies of the requested matter to
the undersigned before the aforementioned return date.
Please take further notice, that the foregoing are continuing demands and that if any of
the above items are obtained after the date of this demand, they are to be furnished to the under-
signed pursuant to this demand. The undersigned will move to preclude said items not so provid-
ed and/or object upon the trial of this matter to the testimony and/or introduction of any items
sought herein.
Please take further notice that failure to timely respond to this demand will result in ap-
plication to the Court for appropriate sanctions.
Please take further notice that this office does not consent to service by telecopy or tele-
fax, unless otherwise stipulated.
Dated: Jericho, NY
January 20, 2022
Sincerely,
JAMES F. BUTLER & ASSOCIATES
Attorney(s) for Defendants
Vivian Keita and Jude E. Keita
P. O. Box 9040
300 Jericho Quadrangle, Suite 260
Jericho, NY 11753
(516) 229-6000
File Number: 21NEWY36855
Claim Number: 38-17Z2-04D
MALLILO & GROSSMAN, ESQS.
Attorney(s) for Plaintiff
Jean Almonte-Moreno
163-09 Northern Boulevard
Flushing, NY 11358
(718) 461-6633
2
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FILED: KINGS COUNTY CLERK 01/25/2022 02:10 PM INDEX NO. 522690/2021
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/25/2022
Index No: 522690/21 SUPREME COURT OF THE STATE OF NEW YORK, COUNTY OF KINGS
JEAN ALMONTE-MORENO,
Plaintiff(s),
-against-
VIVIAN KEITA, JUDE E. KEITA AND JOSE TEVEZ,
Defendant(s),
SUPPLEMENTAL NOTICE FOR DISCOVERY AND INSPECTION TO PLAINTIFF
JAMES F. BUTLER & ASSOCIATES
Attorneys for Defendants
Vivian Keita and Jude E. Keita
P. O. Box 9040
300 Jericho Quadrangle, Suite 260
Jericho, NY 11753
(516) 229-6000
Attorney Certification:
The undersigned, an attorney admitted to practice in the Courts of New York State, certifies that, upon infor-
mation, belief and reasonable inquiry, the contentions contained in the above referenced document(s) are not
frivolous.
Dated: Jericho, NY
January 20, 2022 _____________________________________________
Rocco Iervasi, Esq.
Sincerely,
MALLILO & GROSSMAN, ESQS. JAMES F. BUTLER & ASSOCIATES
Attorney(s) for Plaintiff Attorney(s) for Defendants
Jean Almonte-Moreno Vivian Keita and Jude E. Keita
163-09 Northern Boulevard P. O. Box 9040
Flushing, NY 11358 300 Jericho Quadrangle, Suite 260
(718) 461-6633 Jericho, New York 11753
(516) 229-6000
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FILED: KINGS COUNTY CLERK 01/25/2022 02:10 PM INDEX NO. 522690/2021 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/25/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS JEAN ALMONTE-MORENO, SUPPLEMENTAL NOTICE FOR Plaintiff(s), DISCOVERY AND INSPECTION TO -against- PLAINTIFF VIVIAN KEITA, JUDE E. KEITA AND JOSE TEVEZ, Index Number: 522690/21 Defendant(s), Please take notice that pursuant to CPLR 3101 and 3120, plaintiff is hereby required to produce for Discovery and Inspection at the offices of James F. Butler & Associates, P. O. Box 9040, 300 Jericho Quadrangle, Suite 260, Jericho, NY, attorneys for defendants, Vivian Keita and Jude E. Keita, within thirty (30) days after the service of this demand, the following: As to the prior accident of November 30, 2019:  Duly executed and acknowledged original HIPAA compliant authorization permit- ting the release of plaintiff's complete records from Progressive, claim # 0120193883309;  Duly executed and acknowledged original HIPAA compliant authorization permit- ting the release of plaintiff's complete records from Gallagher Bassett Services, claim # 005857000601AB01. As to the prior accident of August 25, 2020:  Duly executed and acknowledged original HIPAA compliant authorization per- mitting the release of plaintiff's complete records from Progressive, claim # 0120205992400. 1 of 3 FILED: KINGS COUNTY CLERK 01/25/2022 02:10 PM INDEX NO. 522690/2021 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/25/2022 These documents and things are to be produced within thirty (30) days of the date of the demand at the office of James F. Butler & Associates, at 10:00 o’clock in the forenoon. Compli- ance may be effectuated by sending true, readable and legible copies of the requested matter to the undersigned before the aforementioned return date. Please take further notice, that the foregoing are continuing demands and that if any of the above items are obtained after the date of this demand, they are to be furnished to the under- signed pursuant to this demand. The undersigned will move to preclude said items not so provid- ed and/or object upon the trial of this matter to the testimony and/or introduction of any items sought herein. Please take further notice that failure to timely respond to this demand will result in ap- plication to the Court for appropriate sanctions. Please take further notice that this office does not consent to service by telecopy or tele- fax, unless otherwise stipulated. Dated: Jericho, NY January 20, 2022 Sincerely, JAMES F. BUTLER & ASSOCIATES Attorney(s) for Defendants Vivian Keita and Jude E. Keita P. O. Box 9040 300 Jericho Quadrangle, Suite 260 Jericho, NY 11753 (516) 229-6000 File Number: 21NEWY36855 Claim Number: 38-17Z2-04D MALLILO & GROSSMAN, ESQS. Attorney(s) for Plaintiff Jean Almonte-Moreno 163-09 Northern Boulevard Flushing, NY 11358 (718) 461-6633 2 2 of 3 FILED: KINGS COUNTY CLERK 01/25/2022 02:10 PM INDEX NO. 522690/2021 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/25/2022 Index No: 522690/21 SUPREME COURT OF THE STATE OF NEW YORK, COUNTY OF KINGS JEAN ALMONTE-MORENO, Plaintiff(s), -against- VIVIAN KEITA, JUDE E. KEITA AND JOSE TEVEZ, Defendant(s), SUPPLEMENTAL NOTICE FOR DISCOVERY AND INSPECTION TO PLAINTIFF JAMES F. BUTLER & ASSOCIATES Attorneys for Defendants Vivian Keita and Jude E. Keita P. O. Box 9040 300 Jericho Quadrangle, Suite 260 Jericho, NY 11753 (516) 229-6000 Attorney Certification: The undersigned, an attorney admitted to practice in the Courts of New York State, certifies that, upon infor- mation, belief and reasonable inquiry, the contentions contained in the above referenced document(s) are not frivolous. Dated: Jericho, NY January 20, 2022 _____________________________________________ Rocco Iervasi, Esq. Sincerely, MALLILO & GROSSMAN, ESQS. JAMES F. BUTLER & ASSOCIATES Attorney(s) for Plaintiff Attorney(s) for Defendants Jean Almonte-Moreno Vivian Keita and Jude E. Keita 163-09 Northern Boulevard P. O. Box 9040 Flushing, NY 11358 300 Jericho Quadrangle, Suite 260 (718) 461-6633 Jericho, New York 11753 (516) 229-6000 3 of 3