On December 31, 2013 a
DEMAND FOR: - Combined Demands
was filed
involving a dispute between
1015 70Th Street Llc,
and
International Underwriting Agency, Inc.,
Leading Insurance Group Insurance Co., Ltd,
Leading Insurance Services, Inc.,
M&S Insurance Agency Inc.,
for Tort
in the District Court of Kings County.
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FILED: KINGS COUNTY CLERK 10/12/2015 01:53 PM INDEX NO. 508378/2013
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 10/12/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
1015 70TH STREET LLC,
Index No.: 508378/13
Plaintiff,
-against- COMBINED DEMANDS
M&S INSURANCE AGENCY INC., LEADING
INSURANCE GROUP INSURANCE CO., LTD.,
LEADING INSURANCE SERVICES, INC., and
INTERNATIONAL UNDERWRITING AGENCY,
INC.,
Defendants.
DEMAND FOR INSURANCE INFORMATION
PLEASE TAKE NOTICE that pursuant to the provisions of Section 3101(f) of the
CPLR, demand is hereby made upon you to serve upon the undersigned within twenty (20) days
the following insurance information:
1. State whether your client has insurance agreements under which any insurance
company may be liable to satisfy part or all of a judgment, which may be entered in the action or
to indemnify or reimburse for payments made to satisfy a judgment.
2. State the name and address of each insurance company.
3. State the maximum amount of all liability coverage of each insurance company,
indicating the amount per person, the amount for all persons and the amount for each accident.
If there is excess or umbrella insurance liability coverage available, state the name and address of
each insurance carrier for such coverage available from each, indicating the amount per person,
the amount for all persons and the amount for each accident.
4. In the case of no coverage, disclaimer, reservation of rights or any of the conditions
relevant to any of the above coverage for the parties please so state.
5. Attach a copy of each insurance agreement (including coverage sheets) identified
above in your responses to this demand.
DEMAND FOR DISCLOSURE
PLEASE TAKE NOTICE that pursuant to CPLR Section 3101 and Rule 3120 you are
hereby called upon to produce at the office of the undersigned within twenty (20) days of the
date hereof the name and address of each person claimed by any party you represent to be a
witness to the occurrence alleged in the complaint and if no such witnesses are known, so state in
reply to this demand, and you are required to permit visual inspection, photocopying or
photographing of each and every statement by or taken from each party represented by the
undersigned or the agents, servants or employees of said party, now in your possession, custody
or control, or in the possession, custody or control of any party you represent in this action, if
such statement in any manner bears on the issues of this action.
PLEASE TAKE NOTICE that the undersigned will object upon trial to the testimony of
any witnesses not identified pursuant to this demand or to the use of any statement for any
purposes not disclosed pursuant to this demand.
DEMAND FOR STATEMENTS
PLEASE TAKE NOTICE that demand is hereby made that you serve upon the
undersigned within twenty (20) days from the date of this demand copies of all statements which
you have taken of the plaintiffs and/or any other party.
DEMAND FOR NAMES AND ADDRESSES OF WITNESSES
PLEASE TAKE NOTICE that pursuant to C.P.L.R. §§ 313(a) and 312(a) you are
requested to serve upon the undersigned within twenty (20) days the following:
1. Names and addresses of all persons claimed to have knowledge of the occurrence
and allegations contained in the Complaint and/or any defenses thereto.
2. If You know of no such persons, so state in response to this demand.
PLEASE TAKE FURTHER NOTICE that if You obtain the names and addresses of
any such witnesses, this information is to be furnished whenever obtained. The Plaintiff will
object at the time of trial to the testimony of any persons not so identified.
PLEASE TAKE FURTHER NOTICE that upon your failure to produce the aforesaid
documents within the time required in this notice, the defendant will move this Court for
appropriate relief.
DEMAND FOR NAMES AND ADDRESSES OF EXPERT WITNESSES
PLEASE TAKE NOTICE that pursuant to C.P.L.R. § 3101(d), Plaintiff hereby
demands that You provide the following information to the undersigned after an expert is, or
experts are retained, and prior to the filing of the Note of Issue:
1. The names of all expert witnesses each party will call to testify at trial.
2. The qualifications of each expert in the field he or she will be offered as an expert
witness.
3. The substance of the facts and opinions on which the expert is expected to testify.
4. The grounds forming the basis for the experts’ opinion.
5. The dates of all reports provided by the expert to attorney.
If the defendant does not respond to this request in a timely fashion, the undersigned will
object at trial to the testimony of any such expert or experts whose information is not provided.
Dated: New York, New York
October 12, 2015
/S/ Steven A. Weg
Steven A. Weg
GOLDBERG & RIMBERG, PLLC
Attorneys for Plaintiff
115 Broadway, 3rd Floor
New York, New York 10006
(212) 697-3250
Document Filed Date
October 12, 2015
Case Filing Date
December 31, 2013
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FILED: KINGS COUNTY CLERK 10/12/2015 01:53 PM INDEX NO. 508378/2013 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 10/12/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS 1015 70TH STREET LLC, Index No.: 508378/13 Plaintiff, -against- COMBINED DEMANDS M&S INSURANCE AGENCY INC., LEADING INSURANCE GROUP INSURANCE CO., LTD., LEADING INSURANCE SERVICES, INC., and INTERNATIONAL UNDERWRITING AGENCY, INC., Defendants. DEMAND FOR INSURANCE INFORMATION PLEASE TAKE NOTICE that pursuant to the provisions of Section 3101(f) of the CPLR, demand is hereby made upon you to serve upon the undersigned within twenty (20) days the following insurance information: 1. State whether your client has insurance agreements under which any insurance company may be liable to satisfy part or all of a judgment, which may be entered in the action or to indemnify or reimburse for payments made to satisfy a judgment. 2. State the name and address of each insurance company. 3. State the maximum amount of all liability coverage of each insurance company, indicating the amount per person, the amount for all persons and the amount for each accident. If there is excess or umbrella insurance liability coverage available, state the name and address of each insurance carrier for such coverage available from each, indicating the amount per person, the amount for all persons and the amount for each accident. 4. In the case of no coverage, disclaimer, reservation of rights or any of the conditions relevant to any of the above coverage for the parties please so state. 5. Attach a copy of each insurance agreement (including coverage sheets) identified above in your responses to this demand. DEMAND FOR DISCLOSURE PLEASE TAKE NOTICE that pursuant to CPLR Section 3101 and Rule 3120 you are hereby called upon to produce at the office of the undersigned within twenty (20) days of the date hereof the name and address of each person claimed by any party you represent to be a witness to the occurrence alleged in the complaint and if no such witnesses are known, so state in reply to this demand, and you are required to permit visual inspection, photocopying or photographing of each and every statement by or taken from each party represented by the undersigned or the agents, servants or employees of said party, now in your possession, custody or control, or in the possession, custody or control of any party you represent in this action, if such statement in any manner bears on the issues of this action. PLEASE TAKE NOTICE that the undersigned will object upon trial to the testimony of any witnesses not identified pursuant to this demand or to the use of any statement for any purposes not disclosed pursuant to this demand. DEMAND FOR STATEMENTS PLEASE TAKE NOTICE that demand is hereby made that you serve upon the undersigned within twenty (20) days from the date of this demand copies of all statements which you have taken of the plaintiffs and/or any other party. DEMAND FOR NAMES AND ADDRESSES OF WITNESSES PLEASE TAKE NOTICE that pursuant to C.P.L.R. §§ 313(a) and 312(a) you are requested to serve upon the undersigned within twenty (20) days the following: 1. Names and addresses of all persons claimed to have knowledge of the occurrence and allegations contained in the Complaint and/or any defenses thereto. 2. If You know of no such persons, so state in response to this demand. PLEASE TAKE FURTHER NOTICE that if You obtain the names and addresses of any such witnesses, this information is to be furnished whenever obtained. The Plaintiff will object at the time of trial to the testimony of any persons not so identified. PLEASE TAKE FURTHER NOTICE that upon your failure to produce the aforesaid documents within the time required in this notice, the defendant will move this Court for appropriate relief. DEMAND FOR NAMES AND ADDRESSES OF EXPERT WITNESSES PLEASE TAKE NOTICE that pursuant to C.P.L.R. § 3101(d), Plaintiff hereby demands that You provide the following information to the undersigned after an expert is, or experts are retained, and prior to the filing of the Note of Issue: 1. The names of all expert witnesses each party will call to testify at trial. 2. The qualifications of each expert in the field he or she will be offered as an expert witness. 3. The substance of the facts and opinions on which the expert is expected to testify. 4. The grounds forming the basis for the experts’ opinion. 5. The dates of all reports provided by the expert to attorney. If the defendant does not respond to this request in a timely fashion, the undersigned will object at trial to the testimony of any such expert or experts whose information is not provided. Dated: New York, New York October 12, 2015 /S/ Steven A. Weg Steven A. Weg GOLDBERG & RIMBERG, PLLC Attorneys for Plaintiff 115 Broadway, 3rd Floor New York, New York 10006 (212) 697-3250