On December 31, 2019 a
Trial Materials
was filed
involving a dispute between
Raymond Debras,
and
J.P. Morgan Chase,
Lois A. Barlotta,
Richard C. Barlotta,
for Torts - Motor Vehicle
in the District Court of Rockland County.
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FILED: ROCKLAND COUNTY CLERK 07/31/2020 02:56 PM INDEX NO. 037330/2019
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/31/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND Index No.: 037330/2019
-------------------------------------------------------X
RAYMOND DEBRAS,
PLAINTIFF'S
Plaintiff(s), : DEMAND FOR
: EXPERTS
-against- :
RICHARD C. BARLOTTA, LOIS A. BARLOTTA, :
and J.P. MORGAN CHASE, :
Defendant(s). :
e E PLEASE TAKE NOTICE, that pursuant to CPLR 3101(d), et seq., the undersigned
demand that each party provide the following information:
1. The name(s) and address(s) of all expert witnesses each party intends
to have testify at trial.
2. The qualifications of each expert in the field he or she will be offered as
an expert witness; but not limited to educational backgrounds, professional
including
licenses obtained and state where gained, related academic experiences, work
experiences, relevant articles publishes, lectures given and professional associations
with which the expert may be affiliated.
3. The subject matter on which each expert is expected to testify.
4. The substance of the facts and opinions on which the expert is expected
to testify.
5. The dates of all reports provided by the expert to the attorney.
(a) State when the expert(s) were retained by counsel.
6. Provide a summary of the grounds of each expert's opinion and attach
any data in support of each opinion and conclusion:
(a) State whether the expert(s) has had occasion to visit the scene
of this occurrence, and provide the dates involved:
(b) Attach a complete copy of each expert's report, including
photographs, exhibits, diagrams, charts and any other material prepared by this expert
in connection with this retainer.
1 of 2
FILED: ROCKLAND COUNTY CLERK 07/31/2020 02:56 PM INDEX NO. 037330/2019
NYSCEF DOC. I
NO. 11 RECEIVED NYSCEF: 07/31/2020
7. State whether any of the named experts have previously testified on
behalf of your law office in other litigation. Ifso, provide case name, court and index
number.
PLEASE TAKE NOTICE, that the within demand is a continuing demand and,
in the event, that an expert is retained subsequent to your response to this demand,
you are to provide updated answers to the forgoing discovery demands. Your failure
to do so will result in the applicable motion for preclusion of any testimony of any
expert not identified pursuant to this demand.
Dated: Spring Valley, New York
July 29, 2020 Yours etc.
Law Office of Reuven J. Epstein
ce B :
Reuven J. Epstein, Esq.
Attorney(s) for Plaintiff(s)
[ RAYMOND DEBRAS
ae 271 West Route 59
Spring Valley, New York 10977
(845) 371-1900
To: Attorney William A. Magliano
8 . g Manson & McCarthy
Attorney(s) for Defendant(s)
RICHARD C. BARLOTTA, LOIS A. BARLOTTA,
and J.P. MORGAN CHASE
90 Crystal Run Road
Middletown, New York 10940
(845) 692-9700
2 of 2
Document Filed Date
July 31, 2020
Case Filing Date
December 31, 2019
Category
Torts - Motor Vehicle
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FILED: ROCKLAND COUNTY CLERK 07/31/2020 02:56 PM INDEX NO. 037330/2019 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/31/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND Index No.: 037330/2019 -------------------------------------------------------X RAYMOND DEBRAS, PLAINTIFF'S Plaintiff(s), : DEMAND FOR : EXPERTS -against- : RICHARD C. BARLOTTA, LOIS A. BARLOTTA, : and J.P. MORGAN CHASE, : Defendant(s). : e E PLEASE TAKE NOTICE, that pursuant to CPLR 3101(d), et seq., the undersigned demand that each party provide the following information: 1. The name(s) and address(s) of all expert witnesses each party intends to have testify at trial. 2. The qualifications of each expert in the field he or she will be offered as an expert witness; but not limited to educational backgrounds, professional including licenses obtained and state where gained, related academic experiences, work experiences, relevant articles publishes, lectures given and professional associations with which the expert may be affiliated. 3. The subject matter on which each expert is expected to testify. 4. The substance of the facts and opinions on which the expert is expected to testify. 5. The dates of all reports provided by the expert to the attorney. (a) State when the expert(s) were retained by counsel. 6. Provide a summary of the grounds of each expert's opinion and attach any data in support of each opinion and conclusion: (a) State whether the expert(s) has had occasion to visit the scene of this occurrence, and provide the dates involved: (b) Attach a complete copy of each expert's report, including photographs, exhibits, diagrams, charts and any other material prepared by this expert in connection with this retainer. 1 of 2 FILED: ROCKLAND COUNTY CLERK 07/31/2020 02:56 PM INDEX NO. 037330/2019 NYSCEF DOC. I NO. 11 RECEIVED NYSCEF: 07/31/2020 7. State whether any of the named experts have previously testified on behalf of your law office in other litigation. Ifso, provide case name, court and index number. PLEASE TAKE NOTICE, that the within demand is a continuing demand and, in the event, that an expert is retained subsequent to your response to this demand, you are to provide updated answers to the forgoing discovery demands. Your failure to do so will result in the applicable motion for preclusion of any testimony of any expert not identified pursuant to this demand. Dated: Spring Valley, New York July 29, 2020 Yours etc. Law Office of Reuven J. Epstein ce B : Reuven J. Epstein, Esq. Attorney(s) for Plaintiff(s) [ RAYMOND DEBRAS ae 271 West Route 59 Spring Valley, New York 10977 (845) 371-1900 To: Attorney William A. Magliano 8 . g Manson & McCarthy Attorney(s) for Defendant(s) RICHARD C. BARLOTTA, LOIS A. BARLOTTA, and J.P. MORGAN CHASE 90 Crystal Run Road Middletown, New York 10940 (845) 692-9700 2 of 2