On August 22, 2019 a
DEMAND FOR: - Combined Demands
was filed
involving a dispute between
Ines Gonzalez-Crispin,
Inez Gonzalez Crispin,
and
Carl J. Ponticello
As The Executor Of The Estate Of Santo C. Ponticello, Deceased,
Jel-Wb Food Corp,
Jel-Wb Food Corp.,
Laurino Enterprises,
Mcdonald'S Corporation,
Mcdonald'S Restaurants Of New York, Inc.,
Ra-Line Foods, Inc.,
Santo C. Ponticello,
for Torts - Other Negligence (Premises & Motor Vehicle)
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 01/21/2020 03:49 PM INDEX NO. 158224/2019
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 01/21/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------x
INEZ GONZALES CRISPIN, Index No.: 158224/19
Plaintiff, COMBINED DEMANDS
-against-
McDONALD'S CORPORATION, McDONALD'S
RESTAURANTS OF NEW YORK, INC., LAURINO
ENTERPRISES, JEL-WB FOOD CORP., RA-LINE
FOODS, INC. and SANTO C. PONTICELLO,
Defendants.
-______________________________--------------------------------X
PLEASE TAKE NOTICE that pursuant to the applicable provisions of the Civil Practice
Law and Rules, you are hereby required to serve upon the undersigned within twenty (20) days
after receipt of these Demands, the following:
1. Copies of the medical reports of those physicians who have previously treated
or examined the party seeking recovery and duly executed and acknowledged
written authorizations permitting the undersigned to obtain and make copies of
physicians'
alltreating office records and all hospital records, and other records,
technicians'
including x-rays and reports, pertaining to the plaintiff.
2. The name and address of each person known or claimed by you or any party
you represent in this action to be a witness to the occurrence, or the condition
complained of, alleged in the complaint in this action.
3. All photographs under control of the plaintiff or his attorney, or representatives,
showing the site of the occurrence, before, after and at the time of the
occurrence complained of in plaintiff's complaint.
4. Any and allstatements, abstracts or recordings, and/or writings taken by plaintiff
or by his agents, or attorneys, of the defendant, itsagents and/or employees
herein, with regard to the within litigation.
5. Written authorizations permitting the undersigned to obtain work and school
records pertaining to the plaintiff.
6. Written authorization permitting the undersigned to obtain copy of file
1 of 3
FILED: NEW YORK COUNTY CLERK 01/21/2020 03:49 PM INDEX NO. 158224/2019
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 01/21/2020
maintained by No-Fault Insurance Carrier.
7. Written authorization permitting the undersigned to obtain copy of
Worker's Compensation file.
8. Written authorization permitting the undersigned to obtain copy of
Income Tax Returns.
9. The name and addresses of the attorneys who have appeared in this action
together with the name of the party from whom such attorney has appeared.
10. The identity of each person whom the plaintiff expects to call as an expert
Witness at the time of trial with respect to the issue of liability and damages.
a. Set forth in detail the subject matter on which each such expert is
expected to testify, together with the substance of facts and
opinions on which each expert is expected to testify.
b. Set forth the qualifications of each such expert witness.
c. Provide a summary of the grounds for each expert's opinion.
PLEASE TAKE FURTHER NOTICE, that these Demands are continuing in nature and
that if any of the above items are obtained after the date of these Demands, they are to be
furnished to the undersigned pursuant to these Demands.
PLEASE TAKE FURTHER NOTICE, that this defendant will object at the time of trial
to the introduction of any expert testimony by any person, or with respect to any information
not provided as requested above.
Dated: Staten Island, New York
January 21, 2020
Yours etc.
ZACHARY & ZACHARY, P.C.
Attorneys for Defendant PONTICELLO
75 Little Clove Road
Staten Island, New York 10301
(718) 442-2828
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FILED: NEW YORK COUNTY CLERK 01/21/2020 03:49 PM INDEX NO. 158224/2019
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 01/21/2020
TO: Law Office of Arcia & Associates, P.C.
Attorneys for Plaintiff
2nd
79-09 Roosevelt Avenue, FlOOr
Jackson Heights, New York 11372
Stonberg Moran, LLP
Attorneys for Defendants McDonald's Corporation;
McDonald's Restaurants of New York, Inc., Laurino Enterprises & JEL-WB Food Corp.
505 Eighth Avenue, Suite 2302
New York, New York 10018
RA-LINE FOODS, Inc.
35 Old Country Road
Westbury, New York 11590
3 of 3
Document Filed Date
January 21, 2020
Case Filing Date
August 22, 2019
Category
Torts - Other Negligence (Premises & Motor Vehicle)
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FILED: NEW YORK COUNTY CLERK 01/21/2020 03:49 PM INDEX NO. 158224/2019 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 01/21/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------x INEZ GONZALES CRISPIN, Index No.: 158224/19 Plaintiff, COMBINED DEMANDS -against- McDONALD'S CORPORATION, McDONALD'S RESTAURANTS OF NEW YORK, INC., LAURINO ENTERPRISES, JEL-WB FOOD CORP., RA-LINE FOODS, INC. and SANTO C. PONTICELLO, Defendants. -______________________________--------------------------------X PLEASE TAKE NOTICE that pursuant to the applicable provisions of the Civil Practice Law and Rules, you are hereby required to serve upon the undersigned within twenty (20) days after receipt of these Demands, the following: 1. Copies of the medical reports of those physicians who have previously treated or examined the party seeking recovery and duly executed and acknowledged written authorizations permitting the undersigned to obtain and make copies of physicians' alltreating office records and all hospital records, and other records, technicians' including x-rays and reports, pertaining to the plaintiff. 2. The name and address of each person known or claimed by you or any party you represent in this action to be a witness to the occurrence, or the condition complained of, alleged in the complaint in this action. 3. All photographs under control of the plaintiff or his attorney, or representatives, showing the site of the occurrence, before, after and at the time of the occurrence complained of in plaintiff's complaint. 4. Any and allstatements, abstracts or recordings, and/or writings taken by plaintiff or by his agents, or attorneys, of the defendant, itsagents and/or employees herein, with regard to the within litigation. 5. Written authorizations permitting the undersigned to obtain work and school records pertaining to the plaintiff. 6. Written authorization permitting the undersigned to obtain copy of file 1 of 3 FILED: NEW YORK COUNTY CLERK 01/21/2020 03:49 PM INDEX NO. 158224/2019 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 01/21/2020 maintained by No-Fault Insurance Carrier. 7. Written authorization permitting the undersigned to obtain copy of Worker's Compensation file. 8. Written authorization permitting the undersigned to obtain copy of Income Tax Returns. 9. The name and addresses of the attorneys who have appeared in this action together with the name of the party from whom such attorney has appeared. 10. The identity of each person whom the plaintiff expects to call as an expert Witness at the time of trial with respect to the issue of liability and damages. a. Set forth in detail the subject matter on which each such expert is expected to testify, together with the substance of facts and opinions on which each expert is expected to testify. b. Set forth the qualifications of each such expert witness. c. Provide a summary of the grounds for each expert's opinion. PLEASE TAKE FURTHER NOTICE, that these Demands are continuing in nature and that if any of the above items are obtained after the date of these Demands, they are to be furnished to the undersigned pursuant to these Demands. PLEASE TAKE FURTHER NOTICE, that this defendant will object at the time of trial to the introduction of any expert testimony by any person, or with respect to any information not provided as requested above. Dated: Staten Island, New York January 21, 2020 Yours etc. ZACHARY & ZACHARY, P.C. Attorneys for Defendant PONTICELLO 75 Little Clove Road Staten Island, New York 10301 (718) 442-2828 2 of 3 FILED: NEW YORK COUNTY CLERK 01/21/2020 03:49 PM INDEX NO. 158224/2019 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 01/21/2020 TO: Law Office of Arcia & Associates, P.C. Attorneys for Plaintiff 2nd 79-09 Roosevelt Avenue, FlOOr Jackson Heights, New York 11372 Stonberg Moran, LLP Attorneys for Defendants McDonald's Corporation; McDonald's Restaurants of New York, Inc., Laurino Enterprises & JEL-WB Food Corp. 505 Eighth Avenue, Suite 2302 New York, New York 10018 RA-LINE FOODS, Inc. 35 Old Country Road Westbury, New York 11590 3 of 3