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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
_____________________________________---------- ------X
WILLIAM S. PETERSON, as Administrator of the Estate Index No.: EF008643-2018
of LAURIE A. PETERSON, Individually,
Plaintiffs,
-against- JUDICIAL SUBPOENA
Witness-
-Non-Party
EAN HOLDINGS, LLC, MARSHALL A. JOHNSON,
WILLIAM P. SCHROH, JR, AND LYNNE S. SCHROH
Defendants.
_____________ ________ ______ ..---- ---X
TO: Mr. Matthew Kahlke
Attn: Mr. Gregory R. Schmid, Director of Operations
Orange County Department of Emergency Services
22 Wells Farm Road, Goshen, New York 10924
WE COMMAND YOU, that all busiñess and excuses being laid aside, you appear and
attend before Carman Callahan & Ingham, LLP at the following location:
Diamond - Goshen
Reporting
12 Scotchtown Avenue
Goshen, New York 10924
on the 16th day of January, 2020 at 2:00 o'clock in the afternoon, or any date prior thereto, to
provide sworn deposition testimony as a Non-Party witness, and that you bring with you, and
produce at that time and place certified copies of the complete records, documents, notes, reports
and/or information that 1) related to your comments on the Incident Detail Reports relative to
Incident No. Incident Date 9-24-17 Incident No. 09242017-
09242017-111876, 11:59:04;
011033, Incident Date 9-24-17 11:59:04; Incident No. 09242017-031087, Incident Date 9-24-17
11:57:42; Incident No. 09242017-031901, Incident date 9-24-17 12:03:22; and Incident No.
09242017-031088, Incident Date 9-24-17 11:57:57.; and 2) all incident reports, transcripts and/or
audio recordings of 9-1-1 calls,related to a motor vehicle accident on 9-24-17 on State Road 17,
1/2 mile south of Warwickbrook Road, Town of Tuxedo, State of New York, which is the
subject of this litigation.
Failure to comply with this Subpoena ispunishable as a contempt of Court and shall
make you liable to the person on whose behalf this Subpoena was issued for a penalty not to
exceed fifty dollars and all damages sustained by reason of your failure to comply.
WITNESS, Stephanie L. Bo ttorney for Defend t, M shall A. Johnson, the 6th day
of January, 2020.
o rs, tc.,
SO ORDERED:
. E , Q.
CARMAN, CALLA AN & INGHAM, LLP
J.S.C. Hon. Steven Milligram Attorneys for Defeñdañt Marshall A. Jobmson
Dated: 266 Main Street
Farmingdale, New York 11735
(516) 249-3450
File No.: 2652-0268
KINDLY CONTACT YOUR ATTORNEY OR THIS OFFICE PRIOR TO YOUR
APPEARANCE FOR DEPOSITION
Index No. EF008643-2018 Year 20
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
WILLIAM S. PETERSON, as Administrator of the Estate of LAURIE A. PETERSON,
Individually,
Plaintiff(s),
-against-
EAN HOLDINGS, LLC, MARSHALL A. JOHNSON, WILLIAM P. SCHROH, JR, AND
LYNNE S. SCHROH
Defendant(s),
Judicial Subpcena - Witness-
Non-Party
CARMAN, CALLAHAN & INGHAM, LLP
AttomersforEAN HOLDINGS, LLC, MARSHALL A. JOHNSON,
ofeeW H JR, AND LYNNE S. SCHROH
266 Main Street
Farmingdale, N.Y. 11735
516-249-3450
To
Attorney(s) for
Service of a copy of thewithin is herebyadmitted.
Dated,
Attorney(s)for
Please take notice
NOTICEOPENTRY
thatthe within isa(certifed) true copy of a
duly entered in theoffice of theclerk of thewithin named court on 20
NOTICEOFSETTLEMENT
thatan order of which the within is a true
copy willbe preseard for
settlement to theHON. one of thejudges
of thewithin named court,at
on 20 at M.
Dated,
Yours, etc.
CARMAN, CALLAHAN & INGHAM, LLP
Attorneys for
Ofce and Post Ofice
Address
Aüon.cy(a)for 266 MainStreet
Farmingdale, N.Y. 11735
..
STATE OF NEW YORK, COUNTY OF ss:
I, the
undersigned, an attorneyadmitted to practicein thecourtsof theNew York State,
cer ¹°"
O certifythatthewithin
has been compared by me withthe originaland found to be a true
and camplete copy.
', statethatI am
the of
attorney(s) recordfor in thewithin
action;I haveread the foregoing and know thecontents thereof;
the same is true
to my own kñówicdge, except as to the
matters thereinallegedto be oninformation and belief,and as tothose matters
I believe be true.
it to The reason thisverification
is made by me and not by
The grounds of my beliefas toallmatters notstatedupon my own knowledge are as follows:
I affirmthatthe foregoingstatemcats under
are true, the penaltiesof perjury.
Dated:
STATE OF NEW YORK, COUNTY OF ss:
1, the
undcrsigned, being sworn, depose and say: I am
inthe action;I haveread theforegoing
and know the contentsthereof;the same is true
to my own knowledge, except
as tothe mattersthereinstatedto be allegedon iñf6rmatiün and belief,and as tothose mattersI believeit to
be true.
corporal'
O the
Verification
of
a corporation and a partyinthe withinaction;I have readthe fGregeing
and know thecontents thereof;and the same is true
to my own knowledge,
except as to the matters thereinstated to be allegedupon information and belief,and as tothose matters I believe tobe true.This
verificaticsis made by me because the above partyis a corporationand I aman officerthereof.
The grounds of my beliefas toallmatters notstatedupon my own kñõwledge are as follows:
Sworn tobefore me on
STATE OF NEW YORK, COUNTY OF ss: (Ir morethanonebox is checked-indicate afternamestypeof serviceused.)
I, the
undersigned, being sworn,say;I am not a partyto theaction,am over I8years ofage and resideat
On I servedthe within
a copy to eachof the persons at the
lastknown address after
set forth each name below.
O by mailing fõllówing
by deliveringa truecopy ofeach personally toeach person named below atthe address indicated.Iknew each person served
O serviceanto be theperson meeticñed and described in saidpapers as a party
therein:
by transmittinga copy to the
fülicwing persons by O FAX at the telephone
number set forth
aftereach name below O E-MAIL
O e on at theE-Mail address after
set forth each name below,which was designated by theattorneyfor such purpose.and by mailing a
*
copy to theaddress setforthaftereach name.
O by dispatching a copy by cremight deliveryto eachof thefallswing persons at thelast
known address set forth
aftereach name
8°"
below.
Sworn tobefore me on
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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE _____________________________________---------- ------X WILLIAM S. PETERSON, as Administrator of the Estate Index No.: EF008643-2018 of LAURIE A. PETERSON, Individually, Plaintiffs, -against- JUDICIAL SUBPOENA Witness- -Non-Party EAN HOLDINGS, LLC, MARSHALL A. JOHNSON, WILLIAM P. SCHROH, JR, AND LYNNE S. SCHROH Defendants. _____________ ________ ______ ..---- ---X TO: Mr. Matthew Kahlke Attn: Mr. Gregory R. Schmid, Director of Operations Orange County Department of Emergency Services 22 Wells Farm Road, Goshen, New York 10924 WE COMMAND YOU, that all busiñess and excuses being laid aside, you appear and attend before Carman Callahan & Ingham, LLP at the following location: Diamond - Goshen Reporting 12 Scotchtown Avenue Goshen, New York 10924 on the 16th day of January, 2020 at 2:00 o'clock in the afternoon, or any date prior thereto, to provide sworn deposition testimony as a Non-Party witness, and that you bring with you, and produce at that time and place certified copies of the complete records, documents, notes, reports and/or information that 1) related to your comments on the Incident Detail Reports relative to Incident No. Incident Date 9-24-17 Incident No. 09242017- 09242017-111876, 11:59:04; 011033, Incident Date 9-24-17 11:59:04; Incident No. 09242017-031087, Incident Date 9-24-17 11:57:42; Incident No. 09242017-031901, Incident date 9-24-17 12:03:22; and Incident No. 09242017-031088, Incident Date 9-24-17 11:57:57.; and 2) all incident reports, transcripts and/or audio recordings of 9-1-1 calls,related to a motor vehicle accident on 9-24-17 on State Road 17, 1/2 mile south of Warwickbrook Road, Town of Tuxedo, State of New York, which is the subject of this litigation. Failure to comply with this Subpoena ispunishable as a contempt of Court and shall make you liable to the person on whose behalf this Subpoena was issued for a penalty not to exceed fifty dollars and all damages sustained by reason of your failure to comply. WITNESS, Stephanie L. Bo ttorney for Defend t, M shall A. Johnson, the 6th day of January, 2020. o rs, tc., SO ORDERED: . E , Q. CARMAN, CALLA AN & INGHAM, LLP J.S.C. Hon. Steven Milligram Attorneys for Defeñdañt Marshall A. Jobmson Dated: 266 Main Street Farmingdale, New York 11735 (516) 249-3450 File No.: 2652-0268 KINDLY CONTACT YOUR ATTORNEY OR THIS OFFICE PRIOR TO YOUR APPEARANCE FOR DEPOSITION Index No. EF008643-2018 Year 20 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE WILLIAM S. PETERSON, as Administrator of the Estate of LAURIE A. PETERSON, Individually, Plaintiff(s), -against- EAN HOLDINGS, LLC, MARSHALL A. JOHNSON, WILLIAM P. SCHROH, JR, AND LYNNE S. SCHROH Defendant(s), Judicial Subpcena - Witness- Non-Party CARMAN, CALLAHAN & INGHAM, LLP AttomersforEAN HOLDINGS, LLC, MARSHALL A. JOHNSON, ofeeW H JR, AND LYNNE S. SCHROH 266 Main Street Farmingdale, N.Y. 11735 516-249-3450 To Attorney(s) for Service of a copy of thewithin is herebyadmitted. Dated, Attorney(s)for Please take notice NOTICEOPENTRY thatthe within isa(certifed) true copy of a duly entered in theoffice of theclerk of thewithin named court on 20 NOTICEOFSETTLEMENT thatan order of which the within is a true copy willbe preseard for settlement to theHON. one of thejudges of thewithin named court,at on 20 at M. Dated, Yours, etc. CARMAN, CALLAHAN & INGHAM, LLP Attorneys for Ofce and Post Ofice Address Aüon.cy(a)for 266 MainStreet Farmingdale, N.Y. 11735 .. STATE OF NEW YORK, COUNTY OF ss: I, the undersigned, an attorneyadmitted to practicein thecourtsof theNew York State, cer ¹°" O certifythatthewithin has been compared by me withthe originaland found to be a true and camplete copy. ', statethatI am the of attorney(s) recordfor in thewithin action;I haveread the foregoing and know thecontents thereof; the same is true to my own kñówicdge, except as to the matters thereinallegedto be oninformation and belief,and as tothose matters I believe be true. it to The reason thisverification is made by me and not by The grounds of my beliefas toallmatters notstatedupon my own knowledge are as follows: I affirmthatthe foregoingstatemcats under are true, the penaltiesof perjury. Dated: STATE OF NEW YORK, COUNTY OF ss: 1, the undcrsigned, being sworn, depose and say: I am inthe action;I haveread theforegoing and know the contentsthereof;the same is true to my own knowledge, except as tothe mattersthereinstatedto be allegedon iñf6rmatiün and belief,and as tothose mattersI believeit to be true. corporal' O the Verification of a corporation and a partyinthe withinaction;I have readthe fGregeing and know thecontents thereof;and the same is true to my own knowledge, except as to the matters thereinstated to be allegedupon information and belief,and as tothose matters I believe tobe true.This verificaticsis made by me because the above partyis a corporationand I aman officerthereof. The grounds of my beliefas toallmatters notstatedupon my own kñõwledge are as follows: Sworn tobefore me on STATE OF NEW YORK, COUNTY OF ss: (Ir morethanonebox is checked-indicate afternamestypeof serviceused.) I, the undersigned, being sworn,say;I am not a partyto theaction,am over I8years ofage and resideat On I servedthe within a copy to eachof the persons at the lastknown address after set forth each name below. O by mailing fõllówing by deliveringa truecopy ofeach personally toeach person named below atthe address indicated.Iknew each person served O serviceanto be theperson meeticñed and described in saidpapers as a party therein: by transmittinga copy to the fülicwing persons by O FAX at the telephone number set forth aftereach name below O E-MAIL O e on at theE-Mail address after set forth each name below,which was designated by theattorneyfor such purpose.and by mailing a * copy to theaddress setforthaftereach name. O by dispatching a copy by cremight deliveryto eachof thefallswing persons at thelast known address set forth aftereach name 8°" below. Sworn tobefore me on