Preview
FILED: ORANGE COUNTY CLERK 02/11/2022 03:23 PM INDEX NO. EF008286-2021
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/11/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
--------------------------------------------------------------------------X
BARBARA LOPANE, Index No. EF008286-2021
Plaintiff, NOTICE TO PRODUCE
- against - TO ALL PARTIES
TERESA C. KOLK, ORANGE COUNTY MEDI-COACH, INC.,
a/k/a MEDI-COACH, INC., and TASHENA LATOYA DAVIS,
Defendant.
--------------------------------------------------------------------------X
S I R S:
PLEASE TAKE NOTICE, that pursuant to Section 3120 of the Civil Practice Law and
Rules, the defendant, TASHENA LATOYA DAVIS, demands that the plaintiff, BARBARA
LOPANE, and co-defendants, TERESA C. KOLK, ORANGE COUNTY MEDI-COACH, INC.,
a/lda MEDI-COACH, INC., produce and permit discovery by the said defendant, her attorneys, or
others acting on her behalf, within twenty (20) days after the receipt of this notice, of the following
articles, documents and things for inspection, copying, testing and photographing:
parties'
1. Set forth whether vehicle was equipped with an Event Data Recorder, a Sensing
parties'
and Diagnostic Module or Electronic Control Module. If vehicle was equipped with an
Event Data Recorder, a Sensing and Diagnostic Module or Electronic Control Module, parties are
required to provide defendant with a hard-copy print-out of all information contained in each such
Event Data Recorder, Sensing and Diagnostic Module or Electronic Control Module with which
parties'
vehicle was equipped at the time of the accident herein or in the alternative, allow
defendant or defendant's expert access to the vehicle to obtain such information.
2. A copy of the MV-104 filled out by the plaintiff and any of the defendants.
3. A copy of all collision damage reports, appraisals, repair bills, invoices, photographs,
claims, assessments or other such documents generated as a result of any damage to plaintiff's
1 of 2
FILED: ORANGE COUNTY CLERK 02/11/2022 03:23 PM INDEX NO. EF008286-2021
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/11/2022
property from this accident.
co-defendants'
4. Copy of any and all dashboard cam videotape in the plaintiff's car and cars
at the time of the accident.
PLEASE TAKE FURTHER NOTICE that a written communication the afore-
enclosing
requested information may be sent prior to the above-mentioned date and time in lieu of a personal
appearance on the above-mentioned date.
Dated: Rock Hill, New York
February 10, 2022
Yours, etc.,
By:
an R.. Kaplan
The Law Office of Bryan R. Kaplan
P.O. Box 1000
Rock Hill, New York 12775
(845) 733-8010
Attorney for Defendant,
TASHENA LATOYA DAVIS
TO:
Dupee & Monroe, P.C.
211 Main Street, Box 470
Goshen, New York 10924
(845) 294-8900
Attorneys for Plaintiff
Teresa C. Kolk
76 Uhlig Road, Apt. B117
Middletown, New York 10940
Defendant Pro Se
Orange County Medi-Coach, Inc.
86 Cottage Street
Middletown, New York 10940
Defendant Pro Se
2 of 2
Preview
FILED: ORANGE COUNTY CLERK 02/11/2022 03:23 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/11/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE --------------------------------------------------------------------------X BARBARA LOPANE, Index No. EF008286-2021 Plaintiff, NOTICE TO PRODUCE - against - TO ALL PARTIES TERESA C. KOLK, ORANGE COUNTY MEDI-COACH, INC., a/k/a MEDI-COACH, INC., and TASHENA LATOYA DAVIS, Defendant. --------------------------------------------------------------------------X S I R S: PLEASE TAKE NOTICE, that pursuant to Section 3120 of the Civil Practice Law and Rules, the defendant, TASHENA LATOYA DAVIS, demands that the plaintiff, BARBARA LOPANE, and co-defendants, TERESA C. KOLK, ORANGE COUNTY MEDI-COACH, INC., a/lda MEDI-COACH, INC., produce and permit discovery by the said defendant, her attorneys, or others acting on her behalf, within twenty (20) days after the receipt of this notice, of the following articles, documents and things for inspection, copying, testing and photographing: parties' 1. Set forth whether vehicle was equipped with an Event Data Recorder, a Sensing parties' and Diagnostic Module or Electronic Control Module. If vehicle was equipped with an Event Data Recorder, a Sensing and Diagnostic Module or Electronic Control Module, parties are required to provide defendant with a hard-copy print-out of all information contained in each such Event Data Recorder, Sensing and Diagnostic Module or Electronic Control Module with which parties' vehicle was equipped at the time of the accident herein or in the alternative, allow defendant or defendant's expert access to the vehicle to obtain such information. 2. A copy of the MV-104 filled out by the plaintiff and any of the defendants. 3. A copy of all collision damage reports, appraisals, repair bills, invoices, photographs, claims, assessments or other such documents generated as a result of any damage to plaintiff's 1 of 2 FILED: ORANGE COUNTY CLERK 02/11/2022 03:23 PM INDEX NO. EF008286-2021 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/11/2022 property from this accident. co-defendants' 4. Copy of any and all dashboard cam videotape in the plaintiff's car and cars at the time of the accident. PLEASE TAKE FURTHER NOTICE that a written communication the afore- enclosing requested information may be sent prior to the above-mentioned date and time in lieu of a personal appearance on the above-mentioned date. Dated: Rock Hill, New York February 10, 2022 Yours, etc., By: an R.. Kaplan The Law Office of Bryan R. Kaplan P.O. Box 1000 Rock Hill, New York 12775 (845) 733-8010 Attorney for Defendant, TASHENA LATOYA DAVIS TO: Dupee & Monroe, P.C. 211 Main Street, Box 470 Goshen, New York 10924 (845) 294-8900 Attorneys for Plaintiff Teresa C. Kolk 76 Uhlig Road, Apt. B117 Middletown, New York 10940 Defendant Pro Se Orange County Medi-Coach, Inc. 86 Cottage Street Middletown, New York 10940 Defendant Pro Se 2 of 2