Document for Joseph Itara, Tabetha Itara v. Masaryk Towers Corporation D/B/A Masaryk Towers Management, Metro Management & Development Inc., A/K/A Metro Management Devel., Inc.

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                                FILED: NEW YORK COUNTY CLERK 08/25/2021 02:48 PM         INDEX NO. 152948/2020
NYSCEF DOC. NO. 42                                 RECEIVED NYSCEF: 08/25/2021




                       Exhibit P
FILED: NEW YORK COUNTY CLERK 08/25/2021 02:48 PM                                                       INDEX NO. 152948/2020
NYSCEF DOC. NO. 42                                                                              RECEIVED NYSCEF: 08/25/2021




         SUPREME COURT OF THE STATE OF NEW YORK
         COUNTY OF NEW YORK
         ---------------------------------------------------------------------X          Index No.: 152948/2020
         JOSEPH ITARA and TABETHA ITARA,

                                                      Plaintiffs,
                                                                                         NOTICE FOR
                           -against-                                                     DISCOVERY
                                                                                         & INSPECTION

         MASARYK TOWERS CORPORATION d/b/a
         MASARYK TOWERS MANAGEMENT,

                                                       Defendants.
          ---------------------------------------------------------------------------X

          COUNSELLORS:


                  PLEASE TAKE NOTICE that, within twenty (20) days, the answering defendants are

         required to produce the following items for discovery and inspection, pursuant to Civil Practice

         Law & Rules § 3101 et seq., at the office of BRAND BRAND NOMBERG & ROSENBAUM,

         LLP, 622 Third Ave, 7th Floor, New York, New York 10017.


                  All headings are merely for the convenience of the plaintiff and in no way are meant to
                  limit or replace the substance of the demands made within the heading

                                                 DEMAND FOR RECORDS

                  Demand is made for:

                  (a) All contracts and agreements for the maintenance and/or management of 65

                       Columbia Street, New York New York in effect at the time of the accident, and five

                       years prior.

                  (b) All contracts and agreements for the maintenance and management of 65 Columbia

                       Street, New York, New York with METRO MANAGEMENT & DEVELOPMENT,

                       INC. in effect at the time of the accident, and five years prior.
FILED: NEW YORK COUNTY CLERK 08/25/2021 02:48 PM                                                  INDEX NO. 152948/2020
NYSCEF DOC. NO. 42                                                                        RECEIVED NYSCEF: 08/25/2021




                   (c) All contracts and agreements that addressed the maintenance and/or management of

                      the exterior stairway at issue at 65 Columbia Street, New York New York in effect at

                      the time of the accident, and five years prior.

                   (d) All documentation showing any business, person, or entity had any responsibility or

                      duties for maintaining the exterior stairway at issue at the time of the accident, and 5

                      years prior.

                   (e) All contracts with CENTENNIAL ELEVATOR INDUSTRIES, INC concerning 65

                      Columbia Street, New York, New York in effect at the time of the accident.

                   (f) All contracts for elevator maintenance and repair of 65 Columbia Street, New York,

                      New York in effect at the time of the accident.

                   (g) All documentation whether in writing or electronically, showing CENTENNIAL

                      ELEVATOR INDUSTRIES, INC., had any responsibility or duties for maintaining

                      the exterior stairway at issue at the time of the accident, and 5 years prior.

                   PLEASE TAKE FURTHER NOTICE that this demand shall be deemed to continue

          during the pendency of this action. In the extent of failure or refusal to comply, the plaintiffs

          shall see to preclude the introduction of certain evidence at trial where applicable.

          Dated:          Westchester, New York
                          July 21, 2021

                                                                         Yours, etc.,

                                                                         Brand Brand Nomberg &
                                                                         Rosenbaum, LLP
                                                                         Brett J. Nomberg, electronically signed
                                                                         By: Brett J. Nomberg
                                                                         Attorneys for Plaintiffs
                                                                         622 Third Ave, 7th Floor
                                                                         New York, New York 10017
                                                                         (212) 808-0448
FILED: NEW YORK COUNTY CLERK 08/25/2021 02:48 PM         INDEX NO. 152948/2020
NYSCEF DOC. NO. 42                                 RECEIVED NYSCEF: 08/25/2021




          TO:

          MILBER MAKRIS PLOUSADIS & SEIDEN, LLP
          Attorneys for the Defendant
          MASARYK TOWERS CORPORATION d/b/a
          1000 Woodbury Road, Suite 402
          Woodbury, NY 11797
          (516)712-4000