On November 19, 2019 a
Order
was filed
involving a dispute between
Michelle Santos,
and
Michelle Y. Lawrence,
for Torts - Motor Vehicle
in the District Court of Dutchess County.
Preview
= INDEX NO. 2019-54690
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/13/2020
HON. EDWARD T. MCLOUGHLIN, ACTING JUSTICE SUPREME COURT
I aa ee oa TE RR OT PRELIMINARY CONFERENCE
STIPULATION & ORDER
MICHELLE SANTOS (§ 202.12 & 202.19 of the Uniform Rules)
Plaintiff,
~against- INDEX NO:: FEI 0-at
CONFERENCE DATE
Discovery Completion Date:
MICHELLE Yo | AW PENCE Expedited (8 mos.)
Defendant Standard (12 mos.) Hh BO
Complex (15 mos.)
eee i ea SSE PeacesbeuamouueeceNeee
ALL ITEMS ON THIS FORM MUST BE COMPLETED. WRITE “NOT APPLICABLE” (N/A/)) WHERE
APPROPRIATE. IF YOU ENCO! ER PROBLEMS WITH SCHEDUL. RCO. IG ITEMS ON
T ERE CE WILL BE
E. CONTAC! THE CO) SCHEDULED.
It is hereby STIPULATED and ORDERED that disclosure shall proceed as follows:
q) nsurance Coverage: If not already provided, shall be furnished by _Defendant on or before 4/30/2020
(2) Bill of Particulars
a. Demand for a Bill of Particulars shall be served by _ Plaintiff on or before Completed
b. Bill of Particulars shall be served by __Plaintiff on or before _ Completed
c. A Supplemental Bill of Particulars shall be served by _ Plaintiff as to items on or
before 30 days before trial
@) Medical Reports and Authorizations
Shall be served as follows:authorizations for: NF file and records of all treating providers in connection with 6/5/10
accident (demanded on 5/13/20); NF authorization for subject accident.
(4) Physical Examination
a, Examination of Plaintiff shall be held within 30 days of Plaintiffs EBT
b. A copy of the physician’s report shall be furnished to plaintiff within 45 days of the examination.
(5) Deposition: Depositions of
[ ] Plaintiffs) [ ] Defendant(s) [x] All Parties
shall be held on or before 09/30/2020
(6) Other Disclosure:
a. All parties, on or before _ 09/30/2020 , Shall exchange names and addresses of all witnesses,
statements of opposing parties and photographs, or, if none, provide an affirmation to that effect.
b. Authorization for plaintiff(s)’ employment records for the period , Shall be
furnished on or before _ 09/30/2020
Demand for discovery and inspection shall be served by Plaintiff on or before completed
The items sought shall be produced to the extent not objected to, and objections, if any, shall be stated on
or before 09/30/2020
Accident reports prepared in the regular course of business shall be exchanged pursuant to CPLR 3101 (g)
by 09/30/2020
Other [interrogatories (CPLR 3130), etc.]
Plaintiff shall provide authorizations for the following collateral source providers (CPLR 4545) within
30 days.
1 of 2
INDEX NO. 2019-54690
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/13/2020
(7) End Date for All Disclosure [must be within 12 months, or 15 months for a complex
case]:
(8) Impleader: Motion(s) to amend the pleadings; or to add parties: Shall be completed on or
before
(9) | Compliance Conference shall be held on On = a a SO
at
iaof MJP.M,
the progress of discovery, explore potential settlement, and set a deadline for the filing
to monitor
the Note of Issue.
(10) i
Plaintiff(s) shall mreviie expert disclosure by __in accordance with the CPLR
Defendant(s) shall provide expert disclosure by. in accordance with the CPLR
A response to any demand made pursuant to CPLR §3101(d)(1) shall be made within 30 days of retaining
such expert, but in no event later than 90 days prior to trial, Opposing party shall serve its disclosure within
45 days.
(1) Note of Issue: Plaintiff shall file a note of issue/certificate of readiness on or
before Per CPLR
(12) Motions: Any dispositive Summary Judgment Motion(s) shall be made within 60 days of the
filing of the Note Of Issue.
All motions and answering papers are ordered to be filed directly with the Dutchess County Clerk.
No papers will be accepted by chambers without proof of the filing fees having been
paid.
(13) The parties shall ensure that a stipulation of discontinuance shall be promptly filed if the case settles before
the next meeting with the Court.
(4) All parties shall comply with this part’s rules.
Failure to comply with any of these directives may result in the imposition of costs or sanctions or
other action authorized by law.
—
t ea +
i(s) Signature John A. DeGasperis, Esq
Basch & Keegan, LLP
Print Firm Name
On a
Aftorney for Defendant(s) Signature Print Firm Name
Attorney for Defendant(s) Signature Print Firm Name
0
SO ORDERED:
Dated:
JUL 13 2020
Poughkeepsie, New York HON. oe T. MCLOUGHLIN, AJSC
2 of 2
Document Filed Date
July 13, 2020
Case Filing Date
November 19, 2019
Category
Torts - Motor Vehicle
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Preview
= INDEX NO. 2019-54690 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/13/2020 HON. EDWARD T. MCLOUGHLIN, ACTING JUSTICE SUPREME COURT I aa ee oa TE RR OT PRELIMINARY CONFERENCE STIPULATION & ORDER MICHELLE SANTOS (§ 202.12 & 202.19 of the Uniform Rules) Plaintiff, ~against- INDEX NO:: FEI 0-at CONFERENCE DATE Discovery Completion Date: MICHELLE Yo | AW PENCE Expedited (8 mos.) Defendant Standard (12 mos.) Hh BO Complex (15 mos.) eee i ea SSE PeacesbeuamouueeceNeee ALL ITEMS ON THIS FORM MUST BE COMPLETED. WRITE “NOT APPLICABLE” (N/A/)) WHERE APPROPRIATE. IF YOU ENCO! ER PROBLEMS WITH SCHEDUL. RCO. IG ITEMS ON T ERE CE WILL BE E. CONTAC! THE CO) SCHEDULED. It is hereby STIPULATED and ORDERED that disclosure shall proceed as follows: q) nsurance Coverage: If not already provided, shall be furnished by _Defendant on or before 4/30/2020 (2) Bill of Particulars a. Demand for a Bill of Particulars shall be served by _ Plaintiff on or before Completed b. Bill of Particulars shall be served by __Plaintiff on or before _ Completed c. A Supplemental Bill of Particulars shall be served by _ Plaintiff as to items on or before 30 days before trial @) Medical Reports and Authorizations Shall be served as follows:authorizations for: NF file and records of all treating providers in connection with 6/5/10 accident (demanded on 5/13/20); NF authorization for subject accident. (4) Physical Examination a, Examination of Plaintiff shall be held within 30 days of Plaintiffs EBT b. A copy of the physician’s report shall be furnished to plaintiff within 45 days of the examination. (5) Deposition: Depositions of [ ] Plaintiffs) [ ] Defendant(s) [x] All Parties shall be held on or before 09/30/2020 (6) Other Disclosure: a. All parties, on or before _ 09/30/2020 , Shall exchange names and addresses of all witnesses, statements of opposing parties and photographs, or, if none, provide an affirmation to that effect. b. Authorization for plaintiff(s)’ employment records for the period , Shall be furnished on or before _ 09/30/2020 Demand for discovery and inspection shall be served by Plaintiff on or before completed The items sought shall be produced to the extent not objected to, and objections, if any, shall be stated on or before 09/30/2020 Accident reports prepared in the regular course of business shall be exchanged pursuant to CPLR 3101 (g) by 09/30/2020 Other [interrogatories (CPLR 3130), etc.] Plaintiff shall provide authorizations for the following collateral source providers (CPLR 4545) within 30 days. 1 of 2 INDEX NO. 2019-54690 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/13/2020 (7) End Date for All Disclosure [must be within 12 months, or 15 months for a complex case]: (8) Impleader: Motion(s) to amend the pleadings; or to add parties: Shall be completed on or before (9) | Compliance Conference shall be held on On = a a SO at iaof MJP.M, the progress of discovery, explore potential settlement, and set a deadline for the filing to monitor the Note of Issue. (10) i Plaintiff(s) shall mreviie expert disclosure by __in accordance with the CPLR Defendant(s) shall provide expert disclosure by. in accordance with the CPLR A response to any demand made pursuant to CPLR §3101(d)(1) shall be made within 30 days of retaining such expert, but in no event later than 90 days prior to trial, Opposing party shall serve its disclosure within 45 days. (1) Note of Issue: Plaintiff shall file a note of issue/certificate of readiness on or before Per CPLR (12) Motions: Any dispositive Summary Judgment Motion(s) shall be made within 60 days of the filing of the Note Of Issue. All motions and answering papers are ordered to be filed directly with the Dutchess County Clerk. No papers will be accepted by chambers without proof of the filing fees having been paid. (13) The parties shall ensure that a stipulation of discontinuance shall be promptly filed if the case settles before the next meeting with the Court. (4) All parties shall comply with this part’s rules. Failure to comply with any of these directives may result in the imposition of costs or sanctions or other action authorized by law. — t ea + i(s) Signature John A. DeGasperis, Esq Basch & Keegan, LLP Print Firm Name On a Aftorney for Defendant(s) Signature Print Firm Name Attorney for Defendant(s) Signature Print Firm Name 0 SO ORDERED: Dated: JUL 13 2020 Poughkeepsie, New York HON. oe T. MCLOUGHLIN, AJSC 2 of 2