On March 09, 2022 a
Party Notice
was filed
involving a dispute between
Kalween Rodriguez,
and
Metropolitan Realty Management, Inc.,
Metropolitan Realty & Management Ny Inc,
Tov Management Corp.,
Tov Property Management Corp.,
for Torts - Other Negligence (Premises)
in the District Court of Kings County.
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FILED: KINGS COUNTY CLERK 07/28/2023 06:32 PM INDEX NO. 506931/2022
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 07/28/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-----------------------------------------------------X NOTICE TO PRODUCE
KALWEEN RODRIGUEZ,
Plaintiff, Index No.: 506931/2022
-against-
TOV MANAGEMENT CORP. and TOV PROPERTY
MANAGEMENT CORP,
Defendants.
_______________________________________Ç
PLEASE TAKE FURTHER NOTICE that the Plaintiff, KALWEEN
RODRIGUEZ, by his attorneys, The Flomenhaft Law Firm, PLLC, demands pursuant to
CPLR 3101(f) that you produce and permit plaintiff to inspect and to copy, on or before
September 14, 2023, at the offices of the undersigned, as follows:
DEMAND FOR INSURANCE COVERAGE
a. The contents of any insurance agreement by which any institutional insurer
may be liable to satisfy, indemnify, or reimburse payments made to satisfy, all or
part of the judgment that may be entered in this action, including any excess and
additional coverage.
b. A sworn statement disclosing the number of claims made against the
applicable insurance policies, the amount of each claim, and any amounts paid out
against those policies.
Plaintiff is entitled to discovery of these items under CPLR § 3101(f); Kimbell v.
Davis, 81 A.D.2d 855 (2d Dept. 1981); and Sullivan v. Brooklyn-Caledonian Hospital,
213 A.D.2d 474 (2d Dept. 1995). This demand is not satisfied by merely informing
Plaintiff of the existence of an insurance policy and the policy limits.
1 of 2
FILED: KINGS COUNTY CLERK 07/28/2023 06:32 PM INDEX NO. 506931/2022
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 07/28/2023
Instead of producing the items demanded, you may submit true and complete
photocopies thereof.
DATED: New York, NY
July 28, 2023
Yours, etc.,
Jos p tim, Esq.
T lomenhaft Law Firm, PLLC
Attorneys for Plaintiff
90 Broad Street, Suite 1901
New York, NY 10004
(646) 747-o300
To: McCauley Law Firm PLLC
Attorneys for Defendants
777 Westchester Avenue, Suite 101
White Plains, NY 10604
2 of 2
Document Filed Date
July 28, 2023
Case Filing Date
March 09, 2022
Category
Torts - Other Negligence (Premises)
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FILED: KINGS COUNTY CLERK 07/28/2023 06:32 PM INDEX NO. 506931/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 07/28/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -----------------------------------------------------X NOTICE TO PRODUCE KALWEEN RODRIGUEZ, Plaintiff, Index No.: 506931/2022 -against- TOV MANAGEMENT CORP. and TOV PROPERTY MANAGEMENT CORP, Defendants. _______________________________________Ç PLEASE TAKE FURTHER NOTICE that the Plaintiff, KALWEEN RODRIGUEZ, by his attorneys, The Flomenhaft Law Firm, PLLC, demands pursuant to CPLR 3101(f) that you produce and permit plaintiff to inspect and to copy, on or before September 14, 2023, at the offices of the undersigned, as follows: DEMAND FOR INSURANCE COVERAGE a. The contents of any insurance agreement by which any institutional insurer may be liable to satisfy, indemnify, or reimburse payments made to satisfy, all or part of the judgment that may be entered in this action, including any excess and additional coverage. b. A sworn statement disclosing the number of claims made against the applicable insurance policies, the amount of each claim, and any amounts paid out against those policies. Plaintiff is entitled to discovery of these items under CPLR § 3101(f); Kimbell v. Davis, 81 A.D.2d 855 (2d Dept. 1981); and Sullivan v. Brooklyn-Caledonian Hospital, 213 A.D.2d 474 (2d Dept. 1995). This demand is not satisfied by merely informing Plaintiff of the existence of an insurance policy and the policy limits. 1 of 2 FILED: KINGS COUNTY CLERK 07/28/2023 06:32 PM INDEX NO. 506931/2022 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 07/28/2023 Instead of producing the items demanded, you may submit true and complete photocopies thereof. DATED: New York, NY July 28, 2023 Yours, etc., Jos p tim, Esq. T lomenhaft Law Firm, PLLC Attorneys for Plaintiff 90 Broad Street, Suite 1901 New York, NY 10004 (646) 747-o300 To: McCauley Law Firm PLLC Attorneys for Defendants 777 Westchester Avenue, Suite 101 White Plains, NY 10604 2 of 2