On December 30, 2016 a
DEMAND FOR BILL OF PARTICULARS
was filed
involving a dispute between
Philip Lia Mr.,
and
Charlotte Savion Ms.,
Gabrielli Truck Leasing Llc,
Ricardo Andrade Mr.,
for Torts - Motor Vehicle
in the District Court of Richmond County.
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INDEX NO. 151827/2016
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 01/10/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
Sele eneasa saa crwee ee See arene neem enn|
PHILIP LIA, Index No.: 151827/16
Plaintiff, DEMAND FOR VERIFIED
BILL OF PARTICULARS
-against-
GABRIELLI TRUCK LEASING LLC., RICARDO ANDRADE
and CHARLOTTE SAVION,
Defendants.
a ee
PLEASE TAKE NOTICE that Zachary & Zachary, P.C. attorneys for the below named
defendant(s), demand that a Verified Bill of Particulars be served within ten (10) days, setting
forth in detail the following information:
Any name used by each plaintiff other than as specifically set forth.
Date of birth and address of each plaintiff.
Date, time and exact location of the occurrence.
Statement of acts or omissions constituting the negligence claimed.
Nature, location and extent of injuries claimed and description of those alleged
to be permanent and those alleged to be aggravated.
Length of time confined to hospital and name of hospital.
Length of time confined to (a) bed and (b) home.
Set forth: (a) occupation of plaintiff(s)
(b) name and address of employer
(c) number of working days incapacitated; and
(d) rate of pay.
If plaintiff is a student, name and address of school and absences.
10. Total amounts claimed as special damages for:
1 of 3
(a) physician services
(b) medical supplies
(c) hospital expenses
(d) nurses services
(e) loss of earnings
(f) other (specify)
(g) total damages claimed by plaintiff
11 Has plaintiff been reimbursed for any of the above special damages? If so, give
the name of the person or organization tendering such services.
12 Set forth by section and title, statutes, regulation, rules, ordinances and any
other laws, it will be claimed were violated by this defendant.
13 If an automobile accident, give the name of the thoroughfare on which and the
direction in which each motor vehicle or pedestrian involved in the accident was
proceeding, prior to and at the time of the occurrence.
14. If injury arises out of an automobile accident, state the facts constituting
serious injury or economic loss as defined in Secs. 5102(d) and 5102(a) of the
Insurance Law.
15 If the accident happened on defendant’s premises, then exactly where it is
alleged the accident occurred and describe the condition or defect which
allegedly caused the accident.
16 If actual notice is alleged, state:
a Person to whom give;
b. Place given; and
C. Person by whom given.
17 If constructive notice is claimed, state
a Nature of condition;
b. Location of condition; and
c. Duration of condition with dates
18 If it is alleged this defendant caused or created the condition, state name and
address of the person who created the condition and date thereof.
19 State whether or not any claim is being made of improper or defective
equipment and, if so, describe in detail such equipment and its defects.
20. If property damage Is claimed, set forth:
a Description of property damaged;
2 of 3
b. Year purchase and price paid;
Cc. Detailed list of repairs necessary and cost thereof; and
d. Length and cost of any loss of use
21 Set forth the year, make and model of plaintiffs motor vehicle and defendant’s
Motor vehicle together with the registration and plate number of said vehicles.
22. Set forth upon which roadway the plaintiffs motor vehicle was proceeding and
Defendant’s motor vehicle prior to impact.
Dated: Staten Island, New York
January 10, 2017
Yours etc.
ZACHARY & ZACHARY, P.C.
Attorneys for Defendant SAVION
75 Little Clove Road
Staten Island, New York 10301
(718) 442-2828
TO: KUHARSKI, LEVITZ & GIOVINAZZO, ESQ.
Attorneys for Plaintiff
176 Hart Boulevard
Staten Island, New York 10301
RICARDO ANDRADE
Pro Se
103 Windsor Street
Kearney, New Jersey 07032-2016
GABRIELLI TRUCK LEASING LLC.
Pro Se
880 Oyster Bay Road
Upper Brookville, New York
3 of 3
Document Filed Date
January 10, 2017
Case Filing Date
December 30, 2016
Category
Torts - Motor Vehicle
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INDEX NO. 151827/2016 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 01/10/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND Sele eneasa saa crwee ee See arene neem enn| PHILIP LIA, Index No.: 151827/16 Plaintiff, DEMAND FOR VERIFIED BILL OF PARTICULARS -against- GABRIELLI TRUCK LEASING LLC., RICARDO ANDRADE and CHARLOTTE SAVION, Defendants. a ee PLEASE TAKE NOTICE that Zachary & Zachary, P.C. attorneys for the below named defendant(s), demand that a Verified Bill of Particulars be served within ten (10) days, setting forth in detail the following information: Any name used by each plaintiff other than as specifically set forth. Date of birth and address of each plaintiff. Date, time and exact location of the occurrence. Statement of acts or omissions constituting the negligence claimed. Nature, location and extent of injuries claimed and description of those alleged to be permanent and those alleged to be aggravated. Length of time confined to hospital and name of hospital. Length of time confined to (a) bed and (b) home. Set forth: (a) occupation of plaintiff(s) (b) name and address of employer (c) number of working days incapacitated; and (d) rate of pay. If plaintiff is a student, name and address of school and absences. 10. Total amounts claimed as special damages for: 1 of 3 (a) physician services (b) medical supplies (c) hospital expenses (d) nurses services (e) loss of earnings (f) other (specify) (g) total damages claimed by plaintiff 11 Has plaintiff been reimbursed for any of the above special damages? If so, give the name of the person or organization tendering such services. 12 Set forth by section and title, statutes, regulation, rules, ordinances and any other laws, it will be claimed were violated by this defendant. 13 If an automobile accident, give the name of the thoroughfare on which and the direction in which each motor vehicle or pedestrian involved in the accident was proceeding, prior to and at the time of the occurrence. 14. If injury arises out of an automobile accident, state the facts constituting serious injury or economic loss as defined in Secs. 5102(d) and 5102(a) of the Insurance Law. 15 If the accident happened on defendant’s premises, then exactly where it is alleged the accident occurred and describe the condition or defect which allegedly caused the accident. 16 If actual notice is alleged, state: a Person to whom give; b. Place given; and C. Person by whom given. 17 If constructive notice is claimed, state a Nature of condition; b. Location of condition; and c. Duration of condition with dates 18 If it is alleged this defendant caused or created the condition, state name and address of the person who created the condition and date thereof. 19 State whether or not any claim is being made of improper or defective equipment and, if so, describe in detail such equipment and its defects. 20. If property damage Is claimed, set forth: a Description of property damaged; 2 of 3 b. Year purchase and price paid; Cc. Detailed list of repairs necessary and cost thereof; and d. Length and cost of any loss of use 21 Set forth the year, make and model of plaintiffs motor vehicle and defendant’s Motor vehicle together with the registration and plate number of said vehicles. 22. Set forth upon which roadway the plaintiffs motor vehicle was proceeding and Defendant’s motor vehicle prior to impact. Dated: Staten Island, New York January 10, 2017 Yours etc. ZACHARY & ZACHARY, P.C. Attorneys for Defendant SAVION 75 Little Clove Road Staten Island, New York 10301 (718) 442-2828 TO: KUHARSKI, LEVITZ & GIOVINAZZO, ESQ. Attorneys for Plaintiff 176 Hart Boulevard Staten Island, New York 10301 RICARDO ANDRADE Pro Se 103 Windsor Street Kearney, New Jersey 07032-2016 GABRIELLI TRUCK LEASING LLC. Pro Se 880 Oyster Bay Road Upper Brookville, New York 3 of 3