Preview
FILED: JEFFERSON COUNTY CLERK 03/12/2024 04:20 PM INDEX NO. EF2021-00001543
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 03/12/2024
EXHIBIT “H”
FILED: JEFFERSON COUNTY CLERK 03/12/2024 04:20 PM INDEX NO. EF2021-00001543
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 03/12/2024
STATE OF NEW YORK
SUPREME COURT COUNTY OF OSWEGO
DAVID BARKER,
Index No. EFC-2021-0911
Plaintiff,
-vs-
ANTHONY V. GERVERA and AMANDA D,
GERVERA,
Defendants.
STATE OF NEW YORK
SUPREME COURT COUNTY OF JEFFERSON
DAVID BARKER,
Index No. EF2021-00001543
Plaintiff,
-vs- DEFENDANTS'
OMNIBUS
DISCOVERY DEMANDS
ANTHONY V. GERVERA and AMANDA D.
GERVERA,
Defendants.
PLEASE TAKE NOTICE, that Defendants, Anthony V. Gervera and Amanda D. Gervera
("Defendants"), by their attorneys, Costello, Cooney & Fearon, PLLC, demands responses to the
following discovery demands be served within twenty (20) days:
DEMAND FOR STATEMENTS
Pursuant to CPLR 3101(e), the undersigned demands that you produce, within twenty (20) days
of the service of the document containing the Demands herein, a copy of any statement or statements
given by or on behalf of Defendants, whether signed or unsigned, recorded, transcribed, or written. If
such a statement is alleged to be oral in nature, identify the speaker and the sum and substance of the
FILED: JEFFERSON COUNTY CLERK 03/12/2024 04:20 PM INDEX NO. EF2021-00001543
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 03/12/2024
communication alleged to constitute said statement.
DEMAND FOR EXPERT WITNESS INFORMATION
Pursuant to CPLR 3101 (d), the undersigned demands that you provide, within twenty (20) days
of the service of the document containing the Demands herein, the following:
a. The names and addresses of each person you expect to call as an expert
witness at trial;
b. The subject matter of the expected testimony of each such expert and
substance- on which such expert is
the of the facts and opinions each
expected to testify;
c. A summary ofthe grounds for each such expert's opinion; and
d. The qualifications for each such expert witness.
DEMAND FOR WITNESSES
Pursuant to CPLR 3101(a), the undersigned demands that you identify, within twenty (20) days of
the service of the document containing the Demands, the name and address of each person claimed by
Plaintiff to be a witness to any admission by any party, their agents, servants, and/or employees, and/or
any element reflecting on liability.
PLEASE TAKE FURTHER NOTICE, that in the event of failure or refusal to comply with any
of these demands, Plaintiff will apply to the Court for an order compelling compliance pursuant to CPLR
3124.
PLEASE TAKE FURTHER NOTICE, that said demands shall be deemed to continue
during the pendency of this action, including the trial thereof.
DATED: November 29, 2023
2
FILED: JEFFERSON COUNTY CLERK 03/12/2024 04:20 PM INDEX NO. EF2021-00001543
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 03/12/2024
COSTELLO, COONEY & F RON, PLLC
MATTHEW W. O'NEIL
Attorneys for Defendants,
Anthony V. Gervera and Amanda D. Gervera
Office and Post Office Address
211 West Jefferson Street
Syracuse, NY 13202
Telephone: (315) 422-1152
TO: MICHAEL LONGSTREET, ESQ.
LONGSTREET & BERRY, LLP
Attorneys for Plaintiff,
David Barker
Office and Post Office Address
415 Elm Street
Fayetteville, New York 13066
3
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FILED: JEFFERSON COUNTY CLERK 03/12/2024 04:20 PM INDEX NO. EF2021-00001543 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 03/12/2024 EXHIBIT “H” FILED: JEFFERSON COUNTY CLERK 03/12/2024 04:20 PM INDEX NO. EF2021-00001543 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 03/12/2024 STATE OF NEW YORK SUPREME COURT COUNTY OF OSWEGO DAVID BARKER, Index No. EFC-2021-0911 Plaintiff, -vs- ANTHONY V. GERVERA and AMANDA D, GERVERA, Defendants. STATE OF NEW YORK SUPREME COURT COUNTY OF JEFFERSON DAVID BARKER, Index No. EF2021-00001543 Plaintiff, -vs- DEFENDANTS' OMNIBUS DISCOVERY DEMANDS ANTHONY V. GERVERA and AMANDA D. GERVERA, Defendants. PLEASE TAKE NOTICE, that Defendants, Anthony V. Gervera and Amanda D. Gervera ("Defendants"), by their attorneys, Costello, Cooney & Fearon, PLLC, demands responses to the following discovery demands be served within twenty (20) days: DEMAND FOR STATEMENTS Pursuant to CPLR 3101(e), the undersigned demands that you produce, within twenty (20) days of the service of the document containing the Demands herein, a copy of any statement or statements given by or on behalf of Defendants, whether signed or unsigned, recorded, transcribed, or written. If such a statement is alleged to be oral in nature, identify the speaker and the sum and substance of the FILED: JEFFERSON COUNTY CLERK 03/12/2024 04:20 PM INDEX NO. EF2021-00001543 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 03/12/2024 communication alleged to constitute said statement. DEMAND FOR EXPERT WITNESS INFORMATION Pursuant to CPLR 3101 (d), the undersigned demands that you provide, within twenty (20) days of the service of the document containing the Demands herein, the following: a. The names and addresses of each person you expect to call as an expert witness at trial; b. The subject matter of the expected testimony of each such expert and substance- on which such expert is the of the facts and opinions each expected to testify; c. A summary ofthe grounds for each such expert's opinion; and d. The qualifications for each such expert witness. DEMAND FOR WITNESSES Pursuant to CPLR 3101(a), the undersigned demands that you identify, within twenty (20) days of the service of the document containing the Demands, the name and address of each person claimed by Plaintiff to be a witness to any admission by any party, their agents, servants, and/or employees, and/or any element reflecting on liability. PLEASE TAKE FURTHER NOTICE, that in the event of failure or refusal to comply with any of these demands, Plaintiff will apply to the Court for an order compelling compliance pursuant to CPLR 3124. PLEASE TAKE FURTHER NOTICE, that said demands shall be deemed to continue during the pendency of this action, including the trial thereof. DATED: November 29, 2023 2 FILED: JEFFERSON COUNTY CLERK 03/12/2024 04:20 PM INDEX NO. EF2021-00001543 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 03/12/2024 COSTELLO, COONEY & F RON, PLLC MATTHEW W. O'NEIL Attorneys for Defendants, Anthony V. Gervera and Amanda D. Gervera Office and Post Office Address 211 West Jefferson Street Syracuse, NY 13202 Telephone: (315) 422-1152 TO: MICHAEL LONGSTREET, ESQ. LONGSTREET & BERRY, LLP Attorneys for Plaintiff, David Barker Office and Post Office Address 415 Elm Street Fayetteville, New York 13066 3