On July 01, 2019 a
Motion-Secondary
was filed
involving a dispute between
Bok Ill Song,
and
Sophia S Lee,
for Torts - Motor Vehicle
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 02/18/2020 09:09 AM INDEX NO. 711386/2019
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/18/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
X
BOK ILL SONG, AFFIRMATION IN SUPPORT
Plaintiff(s), Index No. 711386/2019
-against-
SOPHIA S LEE,
Defendant(s).
X
MICHAEL J. FALLETTA, ESQ., an attorney at law associated with the Law
Offices of Karen L. Lawrence, attorney for the Defendant(s) SOPHIA S LEE, affirms under the
penalty of perjury, and pursuant to CPLR 2106 that the following facts are true, upon information
and belief based upon a file maintained by your affirmant's office.
This action is one to recover damages for negligence for an alleged motor vehicle
accident. A copy of the Summons and Complaint is attached as Exhibit A
Issue was joined by the service of the answer of the Defendant on July 12, 2019.
On said day, dersañds, copies of which are annexed hereto for medical reports, x-ray reports,
authorizations, response to combined demand and a bill of particulars, were served herein. The
aforementioned Answer and demands are attached as Exhibit B.
The Preliminary Conference was held on November 6, 2019 directing plaintiff to
provide medical reports, x-ray reports, authorizations, response to combined demands, and a bill
of particulars in 30 days. A copy of the Preliminary Conference order is attached as exhibit C.
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FILED: QUEENS COUNTY CLERK 02/18/2020 09:09 AM INDEX NO. 711386/2019
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/18/2020
To date Plaintiff has failed to comply with said Prelimimmy Conference order nd
demands for a Bill of Particulars, response to combined demands, and for medical reports, x-ray
reports and authorizations.
In accordance with the applicable rules of this Court, written request(s) was made
Plaintiff(s)'
to counsel on February 8, 2020, January 2, 2020. A copy of said written requests are
annexed hereto and made a part hereof.
To date, we have failed to receive a Bill of Particulars and all other discovery
necessitating the instant motion.
WHEREFORE, your affirmant prays for an order precluding Plaintiff from
putting into evidence any medical evidence and for such other and further relief as to the Court
may deem just and proper.
DATED: Garden City, NY
February 14, 2020
lkICHAEL J. FALLfTTA
2
2 of 2
Document Filed Date
February 18, 2020
Case Filing Date
July 01, 2019
Category
Torts - Motor Vehicle
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Preview
FILED: QUEENS COUNTY CLERK 02/18/2020 09:09 AM INDEX NO. 711386/2019 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/18/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS X BOK ILL SONG, AFFIRMATION IN SUPPORT Plaintiff(s), Index No. 711386/2019 -against- SOPHIA S LEE, Defendant(s). X MICHAEL J. FALLETTA, ESQ., an attorney at law associated with the Law Offices of Karen L. Lawrence, attorney for the Defendant(s) SOPHIA S LEE, affirms under the penalty of perjury, and pursuant to CPLR 2106 that the following facts are true, upon information and belief based upon a file maintained by your affirmant's office. This action is one to recover damages for negligence for an alleged motor vehicle accident. A copy of the Summons and Complaint is attached as Exhibit A Issue was joined by the service of the answer of the Defendant on July 12, 2019. On said day, dersañds, copies of which are annexed hereto for medical reports, x-ray reports, authorizations, response to combined demand and a bill of particulars, were served herein. The aforementioned Answer and demands are attached as Exhibit B. The Preliminary Conference was held on November 6, 2019 directing plaintiff to provide medical reports, x-ray reports, authorizations, response to combined demands, and a bill of particulars in 30 days. A copy of the Preliminary Conference order is attached as exhibit C. 1 of 2 FILED: QUEENS COUNTY CLERK 02/18/2020 09:09 AM INDEX NO. 711386/2019 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/18/2020 To date Plaintiff has failed to comply with said Prelimimmy Conference order nd demands for a Bill of Particulars, response to combined demands, and for medical reports, x-ray reports and authorizations. In accordance with the applicable rules of this Court, written request(s) was made Plaintiff(s)' to counsel on February 8, 2020, January 2, 2020. A copy of said written requests are annexed hereto and made a part hereof. To date, we have failed to receive a Bill of Particulars and all other discovery necessitating the instant motion. WHEREFORE, your affirmant prays for an order precluding Plaintiff from putting into evidence any medical evidence and for such other and further relief as to the Court may deem just and proper. DATED: Garden City, NY February 14, 2020 lkICHAEL J. FALLfTTA 2 2 of 2