FILED: BRONX COUNTY CLERK 09/06/2023 12:04 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 808461/2023E
`
`RECEIVED NYSCEF: 09/06/2023
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF BRONX
`PHILIPP PREPETIT,
`
`
`Plaintiff
`
`
`JOHN DOE,? a fictitious name/person intended
`to be the unknown operator of a subject vehicle
`and MAFUJUR RAHAMAN,
`
`
`- against -
`
`Defendants
`
`
`
`
`
`
`
`RESPONSE TO DEMAND FOR
`DISCOVERY AND
`INSPECTION
`
` RESPONSE TO PRELIMINARY
`CONFERENCE ORDER AND
`DEMAND FOR MEDICAL
`REPORTS
`
`
`Index #: 808461/2023E
`
`
`COUNSELOR(S):
`
`PLEASE TAKE NOTICE that defendant, Mafujur Rahaman, by his/her /their
`
`attorneys, Law Office of Dennis C. Bartling, in RESPONSE TO DEMAND FOR
`DISCOVERY AND INSPECTION/PRELIMINARY CONFERENCE ORDER and
`DEMAND FOR MEDICAL REPORTS, set forth the following upon information and
`belief:
`
`Insurance:
`
`GOVERNMENT EMPLOYEES INSURANCE COMPANY
`POLICY NUMBER: 6105611161
`BODILY INJURY: $100,000/300,000
`PROPERTY DAMAGE: $100,000.00
`
`*Excess affidavit of insurance to be provided.
`
`
`Non-party witness: The defendant reserves the right to produce eyewitnesses should they
`later be discovered. At this time, defendant(s) is/are:
`
`
`
`No witnesses known
`
`
` Statement of adverse parties:
`
`
`
`
`None
`
`
`
`
`Photographs:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Attached herein
`
`
`
`
`
`
`
`1 of 6
`
`
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 808461/2023E
`
`RECEIVED NYSCEF: 09/06/2023
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF BRONX
`PHILIPP PREPETIT,
`
`
`Plaintiff
`
`
`JOHN DOE,? a fictitious name/person intended
`to be the unknown operator of a subject vehicle
`and MAFUJUR RAHAMAN,
`
`
`- against -
`
`Defendants
`
`
`
`
`
`
`
`RESPONSE TO DEMAND FOR
`DISCOVERY AND
`INSPECTION
`
` RESPONSE TO PRELIMINARY
`CONFERENCE ORDER AND
`DEMAND FOR MEDICAL
`REPORTS
`
`
`Index #: 808461/2023E
`
`
`COUNSELOR(S):
`
`PLEASE TAKE NOTICE that defendant, Mafujur Rahaman, by his/her /their
`
`attorneys, Law Office of Dennis C. Bartling, in RESPONSE TO DEMAND FOR
`DISCOVERY AND INSPECTION/PRELIMINARY CONFERENCE ORDER and
`DEMAND FOR MEDICAL REPORTS, set forth the following upon information and
`belief:
`
`Insurance:
`
`GOVERNMENT EMPLOYEES INSURANCE COMPANY
`POLICY NUMBER: 6105611161
`BODILY INJURY: $100,000/300,000
`PROPERTY DAMAGE: $100,000.00
`
`*Excess affidavit of insurance to be provided.
`
`
`Non-party witness: The defendant reserves the right to produce eyewitnesses should they
`later be discovered. At this time, defendant(s) is/are:
`
`
`
`No witnesses known
`
`
` Statement of adverse parties:
`
`
`
`
`None
`
`
`
`
`Photographs:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Attached herein
`
`
`
`
`
`
`
`1 of 6
`
`
`
`FILED: BRONX COUNTY CLERK 09/06/2023 12:04 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 808461/2023E
`
`RECEIVED NYSCEF: 09/06/2023
`
`
`
`
`Surveillance/videos: None
`
`Expert Witnesses: We have not yet identified or selected an individual who will be used
`as an expert witness.
`
`Repair records:
`
`
`
`
`Attached herein
`
`Accident reports prepared in the ordinary course of business:
`
`This is an improper demand. Defendant is not in possession of any accident report
`prepared in the ordinary course of business other than the Police Report, which is public
`record. Regarding any other reports, defendant objects pursuant to C.P.L.R.3101 to this
`demand, as it seeks disclosure of privileged material and/or materials, prepared in
`anticipation of litigation.
`
`Medical reports/records:
`
`
`
`None
`
`
`Cell phone/Automobile phone records:
`
`
`
`
`None, relevancy to be determined at depositions.
`
` A
`
`
`
`
`
`
`
`
`
` copy of defendant’s MV104:
`
`
`
`Defendant’s MV104 is a matter of public record.
`
`Melville, New York
`September 6, 2023
`
`
`We reserve the right to supplement this response.
`
`Please refer to our file number when corresponding with this office.
`
`DATED:
`
`Yours, etc.
`
`____________________________________
`Richard Stiek, Esq.
`Law Office of Dennis C. Bartling
`Attorneys for Defendant
`Mafujur Rahaman
`2 Huntington Quadrangle, STE 1N01
`Melville, New York 11747
`
`2 of 6
`
`
`
`FILED: BRONX COUNTY CLERK 09/06/2023 12:04 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 808461/2023E
`
`RECEIVED NYSCEF: 09/06/2023
`
`516-229-4312
`855-305-2687
`rstiek@geico.com
`Our File No: 23-0084062
`Claim No: 8761748270000001
`
`
`TO:
`Raytsin Law Firm Pc
`Attorneys for Plaintiff
`221-10 Jamaica Ave, STE 106
`Jamaica, New York 11428-2037
`718-355-9797
`
`
`
`
`
`
`
`
`
`3 of 6
`
`
`
`FILED: BRONX COUNTY CLERK 09/06/2023 12:04 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 808461/2023E
`
`RECEIVED NYSCEF: 09/06/2023
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF BRONX
`PHILIPP PREPETIT,
`
`
`Plaintiff
`
`
`
`- against -
`
`
`JOHN DOE,? a fictitious name/person intended
`to be the unknown operator of a subject vehicle
`and
`MAFUJUR RAHAMAN,
`
`
`
`DEMAND FOR MEDICAL REPORTS
`
`
`Index #: 808461/2023E
`
`Defendant
`
`
`PLEASE TAKE NOTICE that pursuant to UNIFORM Trial Court Rule 202.17,
`
`plaintiff is required to provide at least Twenty (20) days prior to defendant(s) doctors’
`physical examinations of the plaintiff(s), copies of the medical reports of those medical
`providers who have previously treated or examined the plaintiff. These reports shall
`include a detailed recital of the injuries and conditions as to which testimony will be
`offered at the trial, referring to and identifying those x-ray and technicians’ reports which
`will be offered at trial, including a description of the injuries alleged and a diagnosis, and
`prognosis. Medical reports may consist of completed medical provider, workers’
`compensation, or insurance forms that provide the information required by this
`paragraph.
`
`PLEASE TAKE FURTHER NOTICE that upon failure to comply with this
`
`demand, objection shall be made upon trial of this action as to the offering into evidence
`and/or eliciting testimony as to any of the items requested herein which have not been
`disclosed.
`
`DATED:
`
`Melville, New York
`September 6, 2023
`
`Yours, etc.
`
` ____________________________________
`Richard Stiek, Esq.
`Law Office of Dennis C. Bartling
`Attorneys for Defendant
`Mafujur Rahaman
`2 Huntington Quadrangle, STE 1N01
`Melville, New York 11747
`516-229-4312
`855-305-2687
`rstiek@geico.com
`Our File No: 23-0084062
`
`
`
`
`
`4 of 6
`
`
`
`FILED: BRONX COUNTY CLERK 09/06/2023 12:04 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 808461/2023E
`
`RECEIVED NYSCEF: 09/06/2023
`
`Claim No: 8761748270000001
`
`
`TO:
`Raytsin Law Firm Pc
`Attorneys for Plaintiff
`221-10 Jamaica Ave, STE 106
`Jamaica, New York 11428-2037
`718-355-9797
`
`
`
`
`
`
`
`
`
`
`5 of 6
`
`
`
`FILED: BRONX COUNTY CLERK 09/06/2023 12:04 PM
`NYSCEF DOC. NO. 7
`
`
`INDEX NO. 808461/2023E
`
`RECEIVED NYSCEF: 09/06/2023
`
`
`
`
`
`
`Index No.: 808461/2023E
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF BRONX
`PHILIPP PREPETIT,
`
`
`
`
`Plaintiff
`
`
`
`- against -
`
`
`JOHN DOE,? a fictitious name/person intended
`to be the unknown operator of a subject vehicle
`and MAFUJUR RAHAMAN,
`
`
`Response to Demands For Discovery
`and Inspection/Response to Preliminary
`Conference Order and Demand For
`Medical Reports
`
`Defendant
`
`
`
`Law Office of Dennis C. Bartling
`Attorneys for the Defendant
`Mafujur Rahaman
`Law Office of Dennis C. Bartling,
` 2 Huntington Quadrangle, STE 1N01
`Melville, New York 11747
`516-229-4402
`------------------------------------------------------------------------------------------------------------
`TO:
`Raytsin Law Firm Pc
`Attorneys for Plaintiff
`221-10 Jamaica Ave, STE
`106
`Jamaica, New York 11428-
`2037
`718-355-9797
`------------------------------------------------------------------------------------------------------------
`Due and timely service of a copy of the within ______________________ Response to
`Demand For Discovery and Inspection/Preliminary Conference Order and Demand For
`Medical Reports is hereby admitted.
`
`Dated September 6, 2023
`
`
`
`
`
`
`
`
`
`
`
`6 of 6
`
`
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