FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`
`
`Plaintiff(s),
`
`
`Index No.: 2023-5539
`
`
`COMBINED DEMANDS
`
`
`
`
`
`
`
`
`-against-
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF CHEMUNG
`----------------------------------------------------------------------X
`CAPREECE MOORE,
`
`
`
`
`
`
`
`
`
`
`
`
`LESHA P. MASSOUP, DUKE HUR, J.B. HUNT
`TRANSPORT, INC. and COSTCO WHOLESALE
`CORPORATION,
`
`Defendant(s).
`
`
`
`
`
`----------------------------------------------------------------------X
`
`
`PLEASE TAKE NOTICE, that Plaintiff by his attorneys THE PARIS LAW GROUP,
`P.C., hereby make(s) the following demands upon you:
`1.
`Demand for the Names and Addresses of all Witnesses;
`2.
`Demand for the Discovery and Inspection of any Statement of a party represented
`by the undersigned;
`Demand for Insurance Coverage Information;
`3.
`Demand for Photographs, Slides, Audio tapes, Video tapes and Motion pictures;
`4.
`Demand for any Accident and/or Police Reports;
`5.
`Demand for Expert Witness Information.
`6.
`returnable at the office of the undersigned within twenty (20) days at 10:00 a.m. as follows:
`
`DEMAND FOR THE NAMES AND ADDRESSES OF WITNESSES
`PLEASE TAKE NOTICE, that the undersigned hereby demands pursuant to CPLR §3101(a)
`and R.3120 (a) and the case of Zellman v. Metropolitan Transportation Authority, 40 A.D.2nd
`248, 339 N.Y.S.2d 255, that you set forth in writing and under oath the names and addresses of
`each person claimed by any party you represent to be a witness to any of the following:
`(a)
`The occurrence alleged in the complaint;
`
`
`
`
`
`1 of 14
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`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`(b)
`
`(c)
`
`(d)
`
`Any acts or conditions which have been alleged as causing the occurrence alleged
`in the complaint;
`The names and addresses of any witnesses to the acts or conditions substantiating
`the alleged affirmative defenses plead in your answer; and
`The names and addresses of any individuals who commenced legal action for
`injuries sustained as a result of the occurrence complained of in the instant action.
`If no such witnesses are known to any party you represent, state in the sworn reply to this
`demand. The undersigned will object upon trial to the testimony of any witnesses not so
`identified.
`PLEASE TAKE FURTHER NOTICE, that if any party you represent or its
`representatives, obtain names and addresses of persons who witnessed the occurrence alleged in
`the complaint or the acts, notice or conditions substantiating the alleged affirmative defenses or
`have first hand knowledge of such facts subsequent to the service of this notice, this information
`is to be furnished to the Plaintiff(s), whenever obtained. The Plaintiff(s) will object at the time
`of trial to the testimony of any persons not so identified.
`DEMAND FOR DISCOVERY AND INSPECTION OF ANY STATEMENT
`OF A PARTY REPRESENTED BY THE UNDERSIGNED
`
`PLEASE TAKE FURTHER NOTICE, that the undersigned demands upon behalf of the
`Plaintiff(s) in this action that pursuant to CPLR Article 31, you produce at the time and place above
`specified and permit the undersigned to discover, inspect and copy each and every statement made or
`taken by each party and his, her, or its agents, servants or employees now in your possession,
`custody or control or in the possession, custody or control of any party you represent in this action, if
`any such statement in any matter bears on the issues in this action. If no such statement(s) is(are) in
`the possession, custody or control of any parties you represent in this action, state in the sworn reply
`to this demand.
`
`
`
`
`
`
`
`
`
`2 of 14
`
`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`DEMAND FOR DISCOVERY AND INSPECTION
`OF INSURANCE COVERAGE
`
`PLEASE TAKE FURTHER NOTICE, that pursuant to the provisions of §3101 of the
`Civil Practice Law and Rules, any party you represent is required to serve upon the undersigned at
`the time and place specified above the declaration and coverage pages of any and all contracts of
`insurance and insurance policies, including the primary insurance policy of any party you represent,
`as well as reinsurance and/or excess liability, "umbrella," or "catastrophe" policies of any party you
`represent, the spouse of any party you represent or any relative residing with any party you
`represent, for liability on 11/12/2021 giving the name and addresses of each insurance carrier, the
`policy numbers thereof, the dates of coverage and/or policy periods, and the amounts of such and
`each policy coverage.
`If, after investigation, no such reinsurance, excess liability, "umbrella," or "catastrophe"
`policies are found to exist, so state in a sworn reply to this demand.
`DEMAND FOR PHOTOGRAPHS, AUDIO TAPES,
`SLIDES, VIDEO TAPES AND MOTION PICTURES
`
`PLEASE TAKE FURTHER NOTICE, that undersigned demands on behalf of the
`Plaintiff(s) that pursuant to CPLR Article 31, you produce at the time and place above specified and
`permit the undersigned to discover, inspect, photograph and copy each and every photograph, audio
`tapes, slides, videotapes or motion pictures in defendant's custody, possession or control depicting
`the following:
`(a)
`(b)
`(c)
`(d)
`(e)
`(f)
`
`The location where it is alleged that the occurrence complained of took place;
`The condition complained of in the complaint;
`Any vehicles involved in the occurrence depicting said vehicles after the occurrence;
`The Plaintiff(s);
`Any actions or activities of the Plaintiff(s);
`The injuries sustained by the Plaintiff(s);
`
`
`
`
`
`3 of 14
`
`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`If no such photographs, slides, video or motion pictures are in the possession, custody or
`control of any parties you represent in this action, so state in the sworn reply to this demand.
`
`DEMAND FOR ACCIDENT REPORT
`
`PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §3101 and the case of Pataki
`v. Kiseda, 80 A.D.2d 100, 437 N.Y.S.2d 692 (2d Dept. 1981), that the undersigned demands upon
`behalf of the Plaintiff(s) in this action that you produce at the time and place above specified and
`permit the undersigned to discover, inspect and copy each and every written report of the occurrence
`which is the subject matter of this action, prepared in the regular course of business operations or
`practices of any party you represent, or persons or firms acting on behalf of any party you represent.
` If no such report is in existence, so state in the sworn reply to this demand.
`REQUEST FOR DISCLOSURE OF EXPERT WITNESS
`INFORMATION PURSUANT TO CPLR §3101(d)
`
`PLEASE TAKE NOTICE, that pursuant to §3101(d) of the Civil Practice Law and Rules,
`the undersigned hereby requests that you produce, within twenty (20) days after service of this
`request, at THE PARIS LAW GROUP, P.C., the following information:
`(a)
`Identify each person the party upon whom this request is served expects to call as an
`expert witness at the trial of this action.
`The subject matter in reasonable detail upon which each expert named above is
`expected to testify at the trial of this action.
`The substance of the facts and opinions upon which each expert named above is
`expected to testify at the trial of this action.
`The complete qualifications of each expert named above.
`(d)
`A summary of the grounds for the opinion of each expert named above.
`(e)
`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 are to be furnished to the
`undersigned pursuant to these demands.
`PLEASE TAKE FURTHER NOTICE that in the event of your failure to comply, a motion
`will be made for an Order to Strike your Answer, with costs.
`
`(b)
`
`(c)
`
`
`
`
`
`
`
`
`
`
`
`
`
`4 of 14
`
`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`Dated:
`
`
`New York, New York
`September 11, 2023
`
`
`
`
`
`
`
`
`
`TO:
`
`
`Law Office of Keith D. Miller
`Attorneys for Defendant
`LESHA P. MASSOUP
`1000 7th North Street, Suite 120
`Liverpool, NY 13088
`315-701-5768
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Yours, etc.
`
`Jason L. Paris
`___________________________
`JASON L. PARIS, ESQ.
`THE PARIS LAW GROUP, P.C.
`Attorneys for Plaintiff
`CAPREECE MOORE
`60 East 42nd Street, Suite 4000
`New York, NY 10165
`212-970-8754
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`5 of 14
`
`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`
`
`Plaintiff(s),
`
`Index No.: 2023-5539
`
`
`NOTICE OF DISCOVERY
`AND INSPECTION
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF CHEMUNG
`----------------------------------------------------------------------X
`CAPREECE MOORE,
`
`
`
`
`
`
`
`
`
`
`
`
`LESHA P. MASSOUP, DUKE HUR, J.B. HUNT
`TRANSPORT, INC. and COSTCO WHOLESALE
`CORPORATION,
`
`Defendant(s).
`
`
`
`
`
`----------------------------------------------------------------------X
`
`
`
`
`
`
`-against-
`
`PLEASE TAKE NOTICE, that pursuant to CPLR §3120, Defendants are hereby required to
`produce, furnish and permit discovery by the Plaintiff by his attorneys, the following items or
`documents for inspection within twenty (20) days at 2:00 o'clock in the afternoon, at the office of
`THE PARIS LAW GROUP, P.C.:
`The primary liability insurance policy insuring the Defendant(s) on 11/12/2021.
`1.
`2.
`Any personal, umbrella, excess or other insurance agreements covering the
`Defendant(s) on 11/12/2021 which may be liable to satisfy part or all of the judgment entered herein
`or to indemnify or reimburse for payment made to satisfy any such judgment.
`This demand explicitly requires a response from the Defendant(s) in person and under oath
`regarding the existence of such other coverage and responses such as "None Known" or "None to the
`Best of our Knowledge" from Defendant(s)' counsel will be deemed non-compliant.
`3.
`A copy of any statement given by, or on behalf of, the Plaintiff(s) concerning this
`occurrence, whether such statement is oral or recorded, whether or not transcribed, whether signed or
`unsigned.
`The names and addresses of any and all witnesses known to the Defendant(s) or to
`4.
`Defendant(s)' attorney who may have witnessed the occurrence or who may have first-hand
`
`
`
`
`6 of 14
`
`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`knowledge of same. If no such persons are known to Defendant(s) or Defendant(s)' representatives,
`so state in reply to this demand.
`The Plaintiff(s) will object at the time of trial of this action to the testimony of any persons
`not so identified.
`PLEASE TAKE FURTHER NOTICE, that this is a continuing demand, and that if the
`Defendant(s) or Defendant(s)' representatives obtain names and addresses of persons who may
`witnessed the occurrence or who may have first-hand knowledge of the same subsequent to the
`service of this notice, or obtain any statement(s) made by said witnesses, such information must be
`furnished to the Plaintiff(s) whenever so obtained. The Plaintiff(s) will object at the time of trial of
`this action to the introduction of any statements or testimony not previously identified.
`5.
`All photographs and/or pictures of the accident, the accident scene, the vehicles
`involved, any buildings, signals, signs, trees, shrubs or other landscape features which existed at the
`place of the occurrence.
`6.
`All photographs, videotapes, motion pictures and the like taken of the Plaintiff(s)
`which Defendant(s) will seek to introduce at the time of trial.
`The Plaintiff(s) will object at the time of trial of this action to the introduction of any
`photographs, videotapes, motion pictures and the like not so exchanged.
`7.
`The MV-104 Motor Vehicle Department report prepared by, or on behalf of, the
`Defendant(s) with regard to the accident of 11/12/2021.
`8.
`A copy of all appraisals, damage estimates and repair bills concerning damage to
`Defendants' vehicle arising out of this accident.
`9.
`Name and address of the auto body repair shop that repaired Defendant(s)' vehicle.
`10.
`If the Defendant(s)' vehicle was leased, the title or ownership certificate to
`Defendant(s)' leased vehicle, and the names and addresses of all owners listed on such certificate
`applicable on 11/12/2021.
`
`
`
`
`
`7 of 14
`
`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`If the Defendant(s)' vehicle was leased, the motor vehicle lease agreement in force on
`11.
`Defendant(s)' leased vehicle on 11/12/2021, and the names and addresses of all lessors or lessees
`listed in said agreement.
`12.
`Any and all reports prepared in the ordinary course of business concerning the
`incident which is the subject of this lawsuit.
`The aforesaid discovery may be complied with by sending true copies of the aforementioned
`documents to the undersigned prior to the time hereinabove set forth for the production thereof.
`PLEASE TAKE FURTHER NOTICE, that the foregoing are continuing demands and that
`if any of the above items are obtained or come into the possession of the Defendant(s), their agents,
`servants, employees and/or attorneys after the date of this demand, they are to be furnished pursuant
`to this demand.
`Dated:
`New York, New York
`September 11, 2023
`
`
`Yours, etc.
`
`Jason L. Paris
`___________________________
`JASON L. PARIS, ESQ.
`THE PARIS LAW GROUP, P.C.
`Attorneys for Plaintiff
`CAPREECE MOORE
`60 East 42nd Street, Suite 4000
`New York, NY 10165
`212-970-8754
`
`
`
`
`
`
`
`
`
`TO:
`
`
`Law Office of Keith D. Miller
`Attorneys for Defendant
`LESHA P. MASSOUP
`1000 7th North Street, Suite 120
`Liverpool, NY 13088
`315-701-5768
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`8 of 14
`
`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`
`
`Plaintiff(s),
`
`
`
`
`
`-against-
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF CHEMUNG
`----------------------------------------------------------------------X
`CAPREECE MOORE,
`
`
`
`
`
`
`
`
`
`
`LESHA P. MASSOUP, DUKE HUR, J.B. HUNT
`TRANSPORT, INC. and COSTCO WHOLESALE
`CORPORATION,
`
`Defendant(s).
`
`
`
`
`
`----------------------------------------------------------------------X
`
`
`
`
`Index No.: 2023-5539
`
`
`DEMAND FOR A
`VERIFIED BILL OF
`PARTICULARS AS TO
`AFFIRMATIVE
`DEFENSES
`
`
`
`
`PLEASE TAKE NOTICE, that the Plaintiff(s) hereby demand(s) of Defendants that
`serve the undersigned within twenty (20) days from the date of service of this Notice, a Verified
`Bill of Particulars as to the Affirmative Defenses plead in Answer, setting forth in detail the
`following:
`1.
`
`A detailed statement of the act or acts of negligence culpability, lack of care or
`omissions on the part of the plaintiff, which it will be claimed, caused or contributed
`to the accident.
`(a)
`Set forth the time and location of said acts and/or omissions.
`A statement of the degree, extent and/or proportion to which it will be claimed
`Plaintiff's alleged negligence contributed to the accident.
`State whether it will be claimed Plaintiff's alleged negligent acts were committed
`and/or omitted by Plaintiff(s) solely or jointly with other persons.
`(a)
`If with other persons, set forth the names and addresses of other persons.
`(b)
`Set forth a detailed statement of the act or acts of negligence and omissions
`which will be alleged on the part of each other person.
`Set forth the degree, extent and/or proportion to which it will be claimed the
`alleged negligence of each other person contributed to the accident.
`Set forth the time and location of each of the aforesaid mentioned acts by
`each person.
`
`(c)
`
`(d)
`
`
`2.
`
`3.
`
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`9 of 14
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`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`(b)
`(c)
`
`Set forth whether it will be alleged the injuries and/or damages sustained by
`Plaintiff(s) were in any way caused, initiated, continued and/or contributed to any
`acts or omissions of Plaintiff(s). If so, set forth:
`(a)
`A detailed statement of the acts or omissions by Plaintiff(s) which, it will be
`alleged caused, initiated, continued and/or contributed to Plaintiff’s injuries
`and/or damages and the manner in which said acts or omissions occurred;
`The time and exact location of said act or omissions;
`The proportion, extent, degree and nature of Plaintiff’s injuries and/or
`damages it will be alleged the acts and/or omissions of Plaintiff(s) caused,
`continued and/or contributed to Plaintiff’s injuries.
`Whether it will be claimed any other persons caused, continued and/or contributed to
`Plaintiff's injuries and/or damages. If so, set forth:
`(a)
`The names and addresses of all such persons.
`(b)
`The time and location of each person's acts or omissions.
`(c)
`The manner in which each person’s acts or omission occurred.
`(d)
`The proportion, degree, and extent it will be alleged each person caused,
`continued and/or contributed to Plaintiff's injuries and/or damages.
`Set forth the total promotion, degree or extent to which it will be claimed Plaintiff’s
`injuries and/or damages are diminished by Plaintiff’s alleged negligence.
`Whether it will be alleged the vehicle in which Plaintiff(s) was(were) seated was
`equipped with seat belts and/or restraining devices. If so, state:
`(a)
`The type of seat belt and/or device.
`(b)
`Describe the material of which the seat belts were made.
`(c)
`Describe the style and make of each seat belt and/or device.
`(d) Whether it will be alleged said seat belts and/or device were in good and
`proper working order.
`The last time, prior to the date of accident, it will be alleged said belts and/or
`devices were inspected or checked, and the name and address of the person
`performing the inspection.
`(f) Whether it will be alleged said belts and/or device has been repaired prior to
`the accident. If so, state:
`(i)
`The type of repair.
`(ii)
`The time and location of repair.
`(iii) Name and address of person or persons who performed the repairs.
`
`(e)
`
`4.
`
`5.
`
`6.
`
`7.
`
`
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`
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`
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`
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`10 of 14
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`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`(g)
`
`A statement of the number of belts and/or devices it is alleged was(were)
`present in said vehicle at the time of the accident, specifying the exact
`location in the vehicle of each said belt and/or device.
`Whether it will be alleged that Plaintiff(s) was(were) not wearing a seat belt and/or
`restraining device at the time of the accident. If so, state the basis of this allegation.
`Set forth a detailed statement setting forth in what respect the alleged failure to wear
`belts and/or devices contributed to the injuries and damages of plaintiff.
`Set forth what injuries and damages will be alleged Plaintiff(s) constituted to in
`failing to wear restraining devices.
`Set forth specifically to what extent and/or proportion it will be claimed the alleged
`failure to wear available belts and/or devices contributed to Plaintiff's injuries.
`Set forth specifically what injuries and/or sequellae it will be alleged Plaintiff(s)
`would not have sustained had they been wearing restraining devices.
`Set forth in detail the manner in which it will be alleged Plaintiff's failure to use
`available seat belts contributed to and/or caused their injuries.
`Set forth if it will be claimed that as a result of the alleged failure to use available
`seat belts and/or devices a portion and/or portions of Plaintiff’s body came into
`contact with any portion of the vehicle in which Plaintiff(s) was(were) seated, which
`contact would not have occurred but for the alleged failure to use seat belts and/or
`devices. If so, state:
`(a) Which portions of Plaintiff's body.
`(b) Which parts of the vehicle.
`(c)
`The manner in which it will be alleged the use of seatbelts and/or devices
`would have avoided said contact.
`PLEASE TAKE FURTHER NOTICE that upon your failure to comply with the foregoing
`demand, Plaintiff(s) will move for an Order of Preclusion herein, pursuant to the rules of this Court.
`Dated:
`New York, New York
`September 11, 2023
`
`8.
`
`9.
`
`10.
`
`11.
`
`12.
`
`13.
`
`14.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Yours, etc.
`
`Jason L. Paris
`___________________________
`JASON L. PARIS, ESQ.
`THE PARIS LAW GROUP, P.C.
`Attorneys for Plaintiff
`CAPREECE MOORE
`60 East 42nd Street, Suite 4000
`New York, NY 10165
`
`
`
`
`
`
`
`
`
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`
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`
`11 of 14
`
`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`TO:
`
`
`Law Office of Keith D. Miller
`Attorneys for Defendant
`LESHA P. MASSOUP
`1000 7th North Street, Suite 120
`Liverpool, NY 13088
`315-701-5768
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`
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`
`12 of 14
`
`

`

`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 09/11/2023
`
`
`
`Index No.: 2023-5539
`
`
`NOTICE TO TAKE
`DEPOSITION UPON
`ORAL EXAMINATION
`
`
`
`
`
`Plaintiff(s),
`
`
`
`
`
`-against-
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF CHEMUNG
`----------------------------------------------------------------------X
`CAPREECE MOORE,
`
`
`
`
`
`
`
`
`
`
`
`
`LESHA P. MASSOUP, DUKE HUR, J.B. HUNT
`TRANSPORT, INC. and COSTCO WHOLESALE
`CORPORATION,
`
`Defendant(s).
`
`
`
`
`
`----------------------------------------------------------------------X
`
` C
`
` O U N S E L O R:
`
`PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules,
`the testimony, upon oral examination of the Defendant, LESHA P. MASSOUP, as an adverse party
`will be taken before a notary public, who is not an attorney, or employee of an attorney, for any
`party or prospective party herein and is not a person who would be disqualified to act as a juror
`because of interest or because of consanguinity or affinity to any party herein; at Supreme Court of
`the State of New York, County of Chemung on October 5, 2023 or any adjourned day at 10:00 a.m.
`in the of that day with respect to evidence materially necessary to the prosecution of this action.
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`That the said person to be examined is required to produce at such examination the
`following: Any and all notes, records, reports or memorandum concerning an accident which
`occurred on 11/12/2021.
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`Dated:
`New York, New York
`September 11, 2023
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`Yours, etc.
`
`Jason L. Paris
`___________________________
`JASON L. PARIS, ESQ.
`THE PARIS LAW GROUP, P.C.
`Attorneys for Plaintiff
`CAPREECE MOORE
`60 East 42nd Street, Suite 4000
`New York, NY 10165
`212-970-8754
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`FILED: CHEMUNG COUNTY CLERK 09/11/2023 09:17 AM
`NYSCEF DOC. NO. 17
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`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 09/11/2023
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`TO:
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`Law Office of Keith D. Miller
`Attorneys for Defendant
`LESHA P. MASSOUP
`1000 7th North Street, Suite 120
`Liverpool, NY 13088
`315-701-5768
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`14 of 14
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