Preview
FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021
EXHIBIT B
FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
------------------------------------------·--------
x Index No.: EF005114-2021
SUTTON HILL II LLC
Plaintiff,
PLAINTIFF'S DEMAND FOR
-against-
DISCOVERY AND INSPECTION
CAROLINE DUNLOP-RIPEN
Defendant(s)
---------------------------------------------------x Our File No. 774746
PLEASE TAKE NOTICE that pursuant to the provisicñs of Article 31 of the CPLR, Plaintiff, by its
attorneys Smith Carroad Levy Wan & Parikh, P.C., hereby demeds you to produce at the offices of Smith
Carroad Levy Wan & Parikh, P.C., 5036 Jericho Turnpike, Commack, New York 11725, on or before 30
days for discovely and inspection the following documents, items, writings, and objects maiwained,
controlled, or supervised by Defendant or Defendant's agents, servant, and/or employees:
1. Any and all agreements, connects, and /or supplementary agreements made between
Plaintiff and Defendant, including but not limited to leases, lease renewals and lease
adjustments.
2. Any and all canceled checks, reeipts, and/or bank statements reflecting payments made
from Defendant to Plaintiff. invoices, statements, or bills received by Defendant from
PlaintitY.
3. Any and all correspondence, memorañdam, and/or communicaticñs made between Plaintiff
and Defendant, with regard to payments made or cutstañding debt.
4. Any documents, items, writings, and objects, indicating or evidencing any dispute of the
amount alleged to be owed to Plaintiff.
5. documents, items, writings, and objects, indicating or evidencing the date Defendant
Any
vacated the premises and/or surrendered the keys.
This demand is a continuing dersañd, and as such, you are required to supplement the
responses, in the event Defendant obtains further information any time before trial.
FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021
Dated: August 19, 2021
Commack, New York
Smith Carroad Levy Wan & Parikh, P.C.
BY:
PRAGNA PARIKH, ESQ.
Attorneys for Plaintiff
5036 .Iericho Turnpike, Suite 201
Commack, New York 11725
(631) 499-5400
To: Caroline Dunlop-Ripen
Defendant pro se
22 Fox Hill Dr
Middletown NY 10940
FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021
AFFIDAVIT OF SERVICE BY MAIL
STATE OF NEW YORK )
COUNTY OF SUFFOLK )ss:
Lindsey Ranning being sworn says: I am not a party to the action, am over 18 years
of age and reside at Smithtown, New York.
On August 19, 2021, I served a true copy of the annexed Plaintiff's Demand
for Discovery and Inspection by mailing the same in a sealed envelope, with postage prepaid
thereon, in a post-office or official depository of the U.S. Postal Service within the State of New
York, addressed to the last known address of the addressee(s) as indicated below:
TO: Caroline Dunlop-Ripen
Defendant pro se
22 Fox Hill Dr
Middletown NY 10940
Lin sey Ronmng
Sworn to befor
19*
d ugust, 2
otary Public
PRAGNA PARIKH
Notary Public, State of New York
No. 02PA6088205
QUALIFIED IN QUEENS COUNTY
Commission Expires March 3, 2023
FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021
.- ....___
Index No. EF005114-2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
..............._______..... ..... ...._____
SUTTON HILL H LLC
Plaintiff,
-against-
CAROLINE DUNLOP-RIPEN
Defendant.
PLAINTIFF'S DEMAND FOR DISCOVERY AND INSPECTION
To
Attorney(s) for
Service of a copy of the within is hereby admitted.
Dated,
Attorney(s) for .
Yours, etc.
Smith Carroad Levy Wan & Parikh, P.C.
Attorneys for Plaintiff
Office and Post OtTice Address
5036 JERICIIO TURNPlKE
COMMACK, NEW YORK 11725
(631) 499-5400
Attorney(s) for
Preview
FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021 EXHIBIT B FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE ------------------------------------------·-------- x Index No.: EF005114-2021 SUTTON HILL II LLC Plaintiff, PLAINTIFF'S DEMAND FOR -against- DISCOVERY AND INSPECTION CAROLINE DUNLOP-RIPEN Defendant(s) ---------------------------------------------------x Our File No. 774746 PLEASE TAKE NOTICE that pursuant to the provisicñs of Article 31 of the CPLR, Plaintiff, by its attorneys Smith Carroad Levy Wan & Parikh, P.C., hereby demeds you to produce at the offices of Smith Carroad Levy Wan & Parikh, P.C., 5036 Jericho Turnpike, Commack, New York 11725, on or before 30 days for discovely and inspection the following documents, items, writings, and objects maiwained, controlled, or supervised by Defendant or Defendant's agents, servant, and/or employees: 1. Any and all agreements, connects, and /or supplementary agreements made between Plaintiff and Defendant, including but not limited to leases, lease renewals and lease adjustments. 2. Any and all canceled checks, reeipts, and/or bank statements reflecting payments made from Defendant to Plaintiff. invoices, statements, or bills received by Defendant from PlaintitY. 3. Any and all correspondence, memorañdam, and/or communicaticñs made between Plaintiff and Defendant, with regard to payments made or cutstañding debt. 4. Any documents, items, writings, and objects, indicating or evidencing any dispute of the amount alleged to be owed to Plaintiff. 5. documents, items, writings, and objects, indicating or evidencing the date Defendant Any vacated the premises and/or surrendered the keys. This demand is a continuing dersañd, and as such, you are required to supplement the responses, in the event Defendant obtains further information any time before trial. FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021 Dated: August 19, 2021 Commack, New York Smith Carroad Levy Wan & Parikh, P.C. BY: PRAGNA PARIKH, ESQ. Attorneys for Plaintiff 5036 .Iericho Turnpike, Suite 201 Commack, New York 11725 (631) 499-5400 To: Caroline Dunlop-Ripen Defendant pro se 22 Fox Hill Dr Middletown NY 10940 FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021 AFFIDAVIT OF SERVICE BY MAIL STATE OF NEW YORK ) COUNTY OF SUFFOLK )ss: Lindsey Ranning being sworn says: I am not a party to the action, am over 18 years of age and reside at Smithtown, New York. On August 19, 2021, I served a true copy of the annexed Plaintiff's Demand for Discovery and Inspection by mailing the same in a sealed envelope, with postage prepaid thereon, in a post-office or official depository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressee(s) as indicated below: TO: Caroline Dunlop-Ripen Defendant pro se 22 Fox Hill Dr Middletown NY 10940 Lin sey Ronmng Sworn to befor 19* d ugust, 2 otary Public PRAGNA PARIKH Notary Public, State of New York No. 02PA6088205 QUALIFIED IN QUEENS COUNTY Commission Expires March 3, 2023 FILED: ORANGE COUNTY CLERK 11/30/2021 12:14 PM INDEX NO. EF005114-2021 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/30/2021 .- ....___ Index No. EF005114-2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE ..............._______..... ..... ...._____ SUTTON HILL H LLC Plaintiff, -against- CAROLINE DUNLOP-RIPEN Defendant. PLAINTIFF'S DEMAND FOR DISCOVERY AND INSPECTION To Attorney(s) for Service of a copy of the within is hereby admitted. Dated, Attorney(s) for . Yours, etc. Smith Carroad Levy Wan & Parikh, P.C. Attorneys for Plaintiff Office and Post OtTice Address 5036 JERICIIO TURNPlKE COMMACK, NEW YORK 11725 (631) 499-5400 Attorney(s) for