`ERW ENTERPRISES LLC, SAMUEL
`OLUEBUBECHUKWU ANUFORO AND JOHN
`KAWSKI,
`
`-against-
`
`Defendant(s),
`
`
`
`
`
`
`FILED: BRONX COUNTY CLERK 06/12/2024 03:38 PM
`NYSCEF DOC. NO. 16
`
`INDEX NO. 819366/2023E
`
`RECEIVED NYSCEF: 06/12/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF BRONX
`
`SAMUEL UZOMA ANUFORO,
`
`Plaintiff(s),
`
`
`NOTICE FOR
`DISCOVERY AND
`INSPECTION TO
`PLAINTIFF(S)
`
`Index No: 819366/2023E
`
`Please take notice that pursuant to the applicable rules of the provisions of the Civil Prac-
`
`tice Law and Rules, the Defendant(s), Samuel O. Anuforo, demand(s) that the plaintiff(s) pro-
`
`duce for discovery and inspection and copying within twenty (20) days after the service of this
`
`demand, the following documents in your possession, custody and control:
`
`As for the Accident of October 14, 2016
`
`1.
`
`Duly executed written authorizations entitling the defendants to obtain copies of
`
`the entire medical records, including diagnostic testing, for all medical providers, doctors and
`
`hospitals who have treated and/or examined the plaintiff’s with regard to the accident, including
`
`but not limited to:
`
`a.
`
`Metropolitan Medical Services PC, Opus Psychological Services PC,;
`Medmart of NY Corp. Raia Medical Health PC, Super Acupuncture and
`Herboloby, Manjoorsa PT PC, Jodi Jacobs DC PLLC, Michael George
`Alleyne MD PC, Total Anesthesia Provider PC, Five Towns Physicians
`PC, Stand Up MRI of Bronx PC, South Bronx Medical.
`
`The caption, county of venue, index number, accurate and legible copies of any
`
`2.
`
`and all pleadings, accurate and legible copies of all EBT transcripts and/or hearing transcripts,
`
`names and addresses of all attorneys who have appeared for any party, and finally, the complete
`
`non-privileged legal file, from:
`
`1 of 3
`
`
`
`FILED: BRONX COUNTY CLERK 06/12/2024 03:38 PM
`NYSCEF DOC. NO. 16
`
`INDEX NO. 819366/2023E
`
`RECEIVED NYSCEF: 06/12/2024
`
`a.
`
`Korsunskiy Legal Group, Ofshtein Law Firm
`
`3.
`
`Duly executed written authorization entitling the defendants to obtain plaintiff’s
`
`no-fault file, Worker’s Compensation provider or other collateral source provider concerning
`
`plaintiff’s accident, including:
`
`a.
`
`Geico claim no.: 0299374340101087.
`
`Please take further notice, that said documents and information are to be provided, or
`
`copies of same served upon the offices of the undersigned within twenty (20) days after service
`
`of this demand upon you.
`
`Please take further notice, that the foregoing are continuing demands and that if any of
`
`the above items are obtained after the date of this demand, they should be furnished to the under-
`
`signed. The undersigned will object, upon the trial of this matter, to the introduction of any evi-
`
`dence or testimony with reference to any items sought herein and not provided.
`
`Dated: Jericho, New York
`
`June 5, 2024
`
`
`OFSHTEIN LAW FIRM, P.C.
`Attorney(s) for Plaintiff(s)
`Samuel U. Anuforo
`398 Kings Hwy
`Brooklyn, NY 11223
`(718) 455-5252
`eugene@ofshteinlaw.com
`
`SMITH, SOVIK, KENDRICK &
`SUGNET, PC
`Attorney(s) for Co-Defendant(s)
`John Kawski, ERW Enterprises LLC
`250 South Clinton Street
`Suite 600
`Syracuse, NY 13202-1252
`(315) 474-2911
`
`
`
`
`
`Sincerely,
`JAMES F. BUTLER & ASSOCIATES
`Attorney(s) for Defendant(s)
`Samuel O. Anuforo
`P. O. Box 9040
`300 Jericho Quadrangle, Suite 260
`Jericho, NY 11753
`(516) 229-6000
`File Number: 24NEWY12035
`Claim Number: 52-51W4-73H
`
`2
`
`2 of 3
`
`
`
`FILED: BRONX COUNTY CLERK 06/12/2024 03:38 PM
`NYSCEF DOC. NO. 16
`
`
`
`
`
`Index No: 819366/2023E
`
`SAMUEL UZOMA ANUFORO,
`
`
`INDEX NO. 819366/2023E
`
`RECEIVED NYSCEF: 06/12/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK, COUNTY OF BRONX
`
`
`ERW ENTERPRISES LLC, SAMUEL OLUEBUBECHUKWU ANUFORO AND JOHN KAWSKI,
`
`
`
`
`
`-against-
`
`NOTICE FOR DISCOVERY AND INSPECTION TO PLAINTIFF(S)
`
`Plaintiff(s),
`
`Defendant(s),
`
`
`
`
`
`
`JAMES F. BUTLER & ASSOCIATES
`Attorneys for Defendant(s)
`Attorneys for Samuel O. Anuforo
`P. O. Box 9040
`300 Jericho Quadrangle, Suite 260
`Jericho, NY 11753
`(516) 229-6000
`
`
`
`Attorney Certification:
`The undersigned, an attorney admitted to practice in the Courts of New York State, certifies that, upon infor-
`mation, belief and reasonable inquiry, the contentions contained in the above referenced document(s) are not
`frivolous.
`
`Dated: Jericho, New York
`
`June 5, 2024
`
`
`_____________________________________________
`FAZIAH GAFUR, ESQ.
`
`Sincerely,
`JAMES F. BUTLER & ASSOCIATES
`Attorney(s) for Defendant(s)
`Samuel O. Anuforo
`P. O. Box 9040
`300 Jericho Quadrangle, Suite 260
`Jericho, New York 11753
`(516) 229-6000
`
`
`
`
`OFSHTEIN LAW FIRM, P.C.
`Attorney(s) for Plaintiff(s)
`Samuel U. Anuforo
`398 Kings Hwy
`Brooklyn, NY 11223
`(718) 455-5252
`eugene@ofshteinlaw.com
`
`SMITH, SOVIK, KENDRICK & SUGNET, PC
`Attorney(s) for Co-Defendant(s)
`John Kawski, ERW Enterprises LLC
`250 South Clinton Street
`Suite 600
`Syracuse, NY 13202-1252
`(315) 474-2911
`
`
`
`
`
`
`3 of 3
`
`
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