On October 28, 2014 a
No Value
was filed
involving a dispute between
German Prado,
and
Building Dev Corp,
North Flats Llc,
The North Flats Llc,
for Tort
in the District Court of Kings County.
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FILED: KINGS COUNTY CLERK 03/19/2015 02:54 PM INDEX NO. 510059/2014
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/19/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------------)(
GERMAN PRADO,
Index No.: 510059/2014
Plaintiff,
-against- DEMAND FOR
PHOTOGRAPHS
I
. ·j THE NORTH FLATS, LLC, NORTH FLATS, LLC and
BUILDING DEV. CORP.,
Defendants.
-------------------------------------------------------------------------)(
PLEASE TAKE NOTICE that, pursuant to §31 01, Plaintiff is required to produce for
discovery, inspection and copying to the undersigned attorneys for defendants, THE NORTH
FLATS, LLC and BUILDING DEV. CORP., within thirty (30) days of the receipt of this
demand, the following:
1. All films, photographs and videotapes of the scene of the alleged occurrence
which is the subject of this litigation.
2. All films, photographs and videotapes of any instrumentalities, equipment and
other things or objects allegedly involved in this litigation.
3. All films, photographs and videotapes of the plaintiff which demonstrate the
injuries allegedly sustained.
PLEASE TAKE FURTHER NOTICE that, upon plaintiffs failure to produce the
aforesaid films, photographs and videotapes, a motion will be made for appropriate relief.
PLEASE TAKE FURTHER NOTICE this is a continuing demand and requires
production of the above items if subsequently obtained during the pendency of this action.
Dated: Hawthorne, New York
March 19, 2015
Yours, etc.
TRAUB LIEBERMAN STRAUS
& SHREWSBERRY, LLP
By:
Evan B. Rudnicki, Esq.
Mid-Westchester Executive Park
Seven Skyline Drive
Hawthorne, New York 10532
(914) 347-2600
Attorneys for Defendants
The North Flats, LLC and
Building Dev. Corp.
TO: ISAACSON SCHIOWITZ & KORSON, LLP
Martin Schiowitz, Esq.
371 Merrick Road, Suite 302
Rockville Centre, New York 11570
(516) 208-1300
Attorneys for Plaintiff
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Document Filed Date
March 19, 2015
Case Filing Date
October 28, 2014
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FILED: KINGS COUNTY CLERK 03/19/2015 02:54 PM INDEX NO. 510059/2014 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 03/19/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------------)( GERMAN PRADO, Index No.: 510059/2014 Plaintiff, -against- DEMAND FOR PHOTOGRAPHS I . ·j THE NORTH FLATS, LLC, NORTH FLATS, LLC and BUILDING DEV. CORP., Defendants. -------------------------------------------------------------------------)( PLEASE TAKE NOTICE that, pursuant to §31 01, Plaintiff is required to produce for discovery, inspection and copying to the undersigned attorneys for defendants, THE NORTH FLATS, LLC and BUILDING DEV. CORP., within thirty (30) days of the receipt of this demand, the following: 1. All films, photographs and videotapes of the scene of the alleged occurrence which is the subject of this litigation. 2. All films, photographs and videotapes of any instrumentalities, equipment and other things or objects allegedly involved in this litigation. 3. All films, photographs and videotapes of the plaintiff which demonstrate the injuries allegedly sustained. PLEASE TAKE FURTHER NOTICE that, upon plaintiffs failure to produce the aforesaid films, photographs and videotapes, a motion will be made for appropriate relief. PLEASE TAKE FURTHER NOTICE this is a continuing demand and requires production of the above items if subsequently obtained during the pendency of this action. Dated: Hawthorne, New York March 19, 2015 Yours, etc. TRAUB LIEBERMAN STRAUS & SHREWSBERRY, LLP By: Evan B. Rudnicki, Esq. Mid-Westchester Executive Park Seven Skyline Drive Hawthorne, New York 10532 (914) 347-2600 Attorneys for Defendants The North Flats, LLC and Building Dev. Corp. TO: ISAACSON SCHIOWITZ & KORSON, LLP Martin Schiowitz, Esq. 371 Merrick Road, Suite 302 Rockville Centre, New York 11570 (516) 208-1300 Attorneys for Plaintiff i -.I ,, ';',l 2