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FILED: KINGS COUNTY CLERK 06/19/2020 01:19 PM INDEX NO. 526735/2019
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 06/19/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------- ------------X Index No. 526735/2019
ANDREY PIKALOV,
Plaintiff,
- against - NOTICE TO PRODUCE
TO CO-DEFENDANTS
LAM CHI CHI, PAUL SCOTT SCHAEDTLER, and
YOEL HENRIQUEZ,
Defendants.
---------------- ----
X
PLEASE TAKE NOTICE that pursuant to Section 3120 of the Civil Practice Law and Rules,
the defendant, SCOTT PAUL SCHAEDTLER s/h/a PAUL SCOTT SCHAEDTLER, by his attorneys
O'CONNOR, McGUINNESS, CONTE, DOYLE, OLESON, WATSON & LOFI'US, LLP, demands that
the co-defendants, LAM CHI CHI and YOEL HENRIQUEZ, produce and permit discovery by the
said defendant, his attorneys, or others acting on his behalf, within twenty (20) days after the
receipt of this notice, of the following articles, documents and things for inspection, copying,
testing and photographing.
1. Provide the names and addresses of all eyewitnesses to the accident;
2. Provide a copy of any statements in the possession of co-defendants or their
attorneys regarding the accidents in question;
co-defendants'
3. Provide a copy of all photographs depicting property damage to
automobile and/or any other automobile involved in the accident, along with any
co-defendants'
photographs of the accident location that are in possession;
4. a. State whether you have 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.
b. State the name and address of each insurance company.
c. State the maximum amount of all liability coverage of each insurance
company, indicating the amount per person, the amount for allpersons and
the amount for each accident.
d. If there is excess or umbrella insurance liability coverage available, state the
name and address for 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.
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FILED: KINGS COUNTY CLERK 06/19/2020 01:19 PM INDEX NO. 526735/2019
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 06/19/2020
e. In the case of no coverage, disclaimer, reservation of rights or any other
conditions relevant to any of the above coverages of the party, please so state.
f. Attach a copy of each insurance agreement identified above to your answers
to this demand.
co-defendants'
5. Provide a copy of the MV-104 New York State accident report
concerning the accident in question; and
6. Provide a copy of the repair bill and/or estimate for property damage sustained to
co-defendants'
automobile as a result of the accident.
PLEASE TAKE FURTHER NOTICE that a written communication enclosing the afore
requested information may be sent prior to the above mentioned date and time in lieu of a personal
appearance on the above mentioned date.
Dated: White Plains, New York
June 19, 2020
Yours, etc.,
O'CONNOR McGUINNESS CONTE DOYLE
OLE WATSON & LOFTUS, LLP
By:
Richard C. Oleson
Attorneys for Defendant, SCOTT PAUL
SCHAEDTLERs/h/a PAUL SCOTT SCHAEDTLER
One Barker Avenue, Suite 675
White Plains, New York 10601
P: (914) 948-4500 / F: (914) 948-0645
File Number: 9o1-3604
TO: SCAHILL LAW GROUP, P.C.
Attorneys for Defendant, LAM CHI CHI
1o65 Stewart Avenue, Suite 210
Bethpage, New York 11714
(516) 294-5200
JAMES G. BILELLO & ASSOCIATES
Attorneys for Defendant, YOEL HENRIQUEZ
too Duffy Avenue, Suite 500
Hicksville, New York 11801
LEVITSKY LAW FIRM
Attorneys for Plaintiff
2"4
3163 Coney Island Avenue, Floor
Brooklyn, New York 11235
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FILED: KINGS COUNTY CLERK 06/19/2020 01:19 PM INDEX NO. 526735/2019 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 06/19/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------- ------------X Index No. 526735/2019 ANDREY PIKALOV, Plaintiff, - against - NOTICE TO PRODUCE TO CO-DEFENDANTS LAM CHI CHI, PAUL SCOTT SCHAEDTLER, and YOEL HENRIQUEZ, Defendants. ---------------- ---- X PLEASE TAKE NOTICE that pursuant to Section 3120 of the Civil Practice Law and Rules, the defendant, SCOTT PAUL SCHAEDTLER s/h/a PAUL SCOTT SCHAEDTLER, by his attorneys O'CONNOR, McGUINNESS, CONTE, DOYLE, OLESON, WATSON & LOFI'US, LLP, demands that the co-defendants, LAM CHI CHI and YOEL HENRIQUEZ, produce and permit discovery by the said defendant, his attorneys, or others acting on his behalf, within twenty (20) days after the receipt of this notice, of the following articles, documents and things for inspection, copying, testing and photographing. 1. Provide the names and addresses of all eyewitnesses to the accident; 2. Provide a copy of any statements in the possession of co-defendants or their attorneys regarding the accidents in question; co-defendants' 3. Provide a copy of all photographs depicting property damage to automobile and/or any other automobile involved in the accident, along with any co-defendants' photographs of the accident location that are in possession; 4. a. State whether you have 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. b. State the name and address of each insurance company. c. State the maximum amount of all liability coverage of each insurance company, indicating the amount per person, the amount for allpersons and the amount for each accident. d. If there is excess or umbrella insurance liability coverage available, state the name and address for 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. 1 of 2 FILED: KINGS COUNTY CLERK 06/19/2020 01:19 PM INDEX NO. 526735/2019 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 06/19/2020 e. In the case of no coverage, disclaimer, reservation of rights or any other conditions relevant to any of the above coverages of the party, please so state. f. Attach a copy of each insurance agreement identified above to your answers to this demand. co-defendants' 5. Provide a copy of the MV-104 New York State accident report concerning the accident in question; and 6. Provide a copy of the repair bill and/or estimate for property damage sustained to co-defendants' automobile as a result of the accident. PLEASE TAKE FURTHER NOTICE that a written communication enclosing the afore requested information may be sent prior to the above mentioned date and time in lieu of a personal appearance on the above mentioned date. Dated: White Plains, New York June 19, 2020 Yours, etc., O'CONNOR McGUINNESS CONTE DOYLE OLE WATSON & LOFTUS, LLP By: Richard C. Oleson Attorneys for Defendant, SCOTT PAUL SCHAEDTLERs/h/a PAUL SCOTT SCHAEDTLER One Barker Avenue, Suite 675 White Plains, New York 10601 P: (914) 948-4500 / F: (914) 948-0645 File Number: 9o1-3604 TO: SCAHILL LAW GROUP, P.C. Attorneys for Defendant, LAM CHI CHI 1o65 Stewart Avenue, Suite 210 Bethpage, New York 11714 (516) 294-5200 JAMES G. BILELLO & ASSOCIATES Attorneys for Defendant, YOEL HENRIQUEZ too Duffy Avenue, Suite 500 Hicksville, New York 11801 LEVITSKY LAW FIRM Attorneys for Plaintiff 2"4 3163 Coney Island Avenue, Floor Brooklyn, New York 11235 2 of 2