On May 30, 2023 a
No Value
was filed
involving a dispute between
Hussein Badr,
and
Adt Security Services Inc.,
Gelco Fleet Trust,
Jean Bouloute,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 06/20/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
HUSSEIN BADR,
Index No. 515722/2023
Plaintiff,
-against- DEFENDANTS JEAN
BOULOUTE, ADT LLC, AND
JEAN BOULOUTE, ADT SECURITY SERVICES INC., GELCO FLEET TRUST’S
and GELCO FLEET TRUST, DEMAND FOR TAXES AND W-2
DIRECTED TO PLAINTIFF
Defendants.
PLEASE TAKE NOTICE that pursuant to Article 31 of the New York Civil Practice Law
and Rules, the undersigned attorneys for Defendants JEAN BOULOUTE, ADT LLC (incorrectly
named as ADT SECURITY SERIVCES INC.), and GELCO FLEET TRUST hereby demand that
you furnish us within twenty (20) days of the service of this notice the following:
1. True copies of the federal and state income tax returns or W-2 statements of each
Plaintiff for the five (5) years preceding the accident giving rise to this action and from the accident
to date for each Plaintiff’s claims of lost income, past or future.
This is a continuing discovery demand that must be supplemented when and if additional
information on any of the above is obtained.
If you do not have one or more of the above, you are required to submit a letter or affidavit
so stating within ten (10) days of the service of this notice.
We shall rely on all sanctions provided by law if you fail to comply with these demands.
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FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 06/20/2023
Dated: New York, NY
June 20, 2023 Respectfully submitted,
Abraham D. Leybengrub, Esq.
GOLDBERG SEGALLA LLP
711 3rd Avenue, Suite 1900
New York, NY 10017-4013
Telephone: (646) 292-8785
aleybengrub@goldbergsegalla.com
Attorneys for Defendants,
JEAN BOULOUTE, ADT LLC (incorrectly named
as ADT SECURITY SERIVCES INC.), and
GELCO FLEET TRUST
TO: Nicholas Elefterakis, Esq.
ELEFTERAKIS, ELEFTERAKIS & PANEK
80 Pine Street, 38th Floor
New York, New York 10005
T: (212) 532-1116
Attorneys for Plaintiff,
HUSSEIN BADR
2
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FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 06/20/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
HUSSEIN BADR,
Index No. 515722/2023
Plaintiff,
-against-
JEAN BOULOUTE, ADT SECURITY SERVICES INC.,
and GELCO FLEET TRUST,
Defendants.
DEFENDANTS JEAN BOULOUTE, ADT LLC, AND GELCO FLEET TRUST’S DEMAND
FOR TAXES AND W-2 DIRECTED TO PLAINTIFF
GOLDBERG SEGALLA, LLP
Attorneys for Defendant
JEAN BOULOUTE, ADT LLC (incorrectly named as ADT SECURITY SERIVCES INC.), and
GELCO FLEET TRUST
711 Third Avenue, Suite 1900
New York, New York 10017
Tel: 646-292-8700
______________________________________________________________________________
TO:
Nicholas Elefterakis, Esq.
ELEFTERAKIS, ELEFTERAKIS &
Attorneys for Plaintiff
HUSSEIN BADR
80 Pine Street, 38th Floor
New York, New York 10005
T: (212) 532-1116
__________________________________________________________________________
3
3 of 3
Document Filed Date
June 20, 2023
Case Filing Date
May 30, 2023
Category
Torts - Motor Vehicle
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Preview
FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 06/20/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS HUSSEIN BADR, Index No. 515722/2023 Plaintiff, -against- DEFENDANTS JEAN BOULOUTE, ADT LLC, AND JEAN BOULOUTE, ADT SECURITY SERVICES INC., GELCO FLEET TRUST’S and GELCO FLEET TRUST, DEMAND FOR TAXES AND W-2 DIRECTED TO PLAINTIFF Defendants. PLEASE TAKE NOTICE that pursuant to Article 31 of the New York Civil Practice Law and Rules, the undersigned attorneys for Defendants JEAN BOULOUTE, ADT LLC (incorrectly named as ADT SECURITY SERIVCES INC.), and GELCO FLEET TRUST hereby demand that you furnish us within twenty (20) days of the service of this notice the following: 1. True copies of the federal and state income tax returns or W-2 statements of each Plaintiff for the five (5) years preceding the accident giving rise to this action and from the accident to date for each Plaintiff’s claims of lost income, past or future. This is a continuing discovery demand that must be supplemented when and if additional information on any of the above is obtained. If you do not have one or more of the above, you are required to submit a letter or affidavit so stating within ten (10) days of the service of this notice. We shall rely on all sanctions provided by law if you fail to comply with these demands. 1 of 3 FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 06/20/2023 Dated: New York, NY June 20, 2023 Respectfully submitted, Abraham D. Leybengrub, Esq. GOLDBERG SEGALLA LLP 711 3rd Avenue, Suite 1900 New York, NY 10017-4013 Telephone: (646) 292-8785 aleybengrub@goldbergsegalla.com Attorneys for Defendants, JEAN BOULOUTE, ADT LLC (incorrectly named as ADT SECURITY SERIVCES INC.), and GELCO FLEET TRUST TO: Nicholas Elefterakis, Esq. ELEFTERAKIS, ELEFTERAKIS & PANEK 80 Pine Street, 38th Floor New York, New York 10005 T: (212) 532-1116 Attorneys for Plaintiff, HUSSEIN BADR 2 2 of 3 FILED: KINGS COUNTY CLERK 06/20/2023 03:10 PM INDEX NO. 515722/2023 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 06/20/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS HUSSEIN BADR, Index No. 515722/2023 Plaintiff, -against- JEAN BOULOUTE, ADT SECURITY SERVICES INC., and GELCO FLEET TRUST, Defendants. DEFENDANTS JEAN BOULOUTE, ADT LLC, AND GELCO FLEET TRUST’S DEMAND FOR TAXES AND W-2 DIRECTED TO PLAINTIFF GOLDBERG SEGALLA, LLP Attorneys for Defendant JEAN BOULOUTE, ADT LLC (incorrectly named as ADT SECURITY SERIVCES INC.), and GELCO FLEET TRUST 711 Third Avenue, Suite 1900 New York, New York 10017 Tel: 646-292-8700 ______________________________________________________________________________ TO: Nicholas Elefterakis, Esq. ELEFTERAKIS, ELEFTERAKIS & Attorneys for Plaintiff HUSSEIN BADR 80 Pine Street, 38th Floor New York, New York 10005 T: (212) 532-1116 __________________________________________________________________________ 3 3 of 3