`NYSCEF DOC. NO. 28
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`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 12/06/2023
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`Index No.: 2023-5539
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`PLAINTIFF’S
`POST DEPOSITION
`DEMANDS
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`-against-
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`Plaintiff(s),
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF CHEMUNG
`----------------------------------------------------------------------X
`CAPREECE MOORE,
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`LESHA P. MASSOUP, DUKE HUR, J. B. HUNT
`TRANSPORT, INC. and COSTCO WHOLESALE
`CORPORATION,
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`Defendant(s).
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`----------------------------------------------------------------------X
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`PLEASE TAKE NOTICE that pursuant to Article 31 of the CPLR, the undersigned
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`demands that Defendants produce with twenty (20) days at the office of the undersigned for the
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`purpose of discovery, inspection, photocopying and photographing the following:
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`1. All photographs and videos taken by DUKE HUR, related to the subject accident and
`subject motor vehicle.
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`2. All photographs and videos taken by J. B. HUNT TRANSPORT, INC., related to the
`subject accident and subject motor vehicle.
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`3. All photographs and videos taken by COSTCO WHOLESALE CORPORATION,
`related to the subject accident and subject motor vehicle.
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`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.
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`Plaintiff 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.
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`4. All accident/incident reports regarding the subject accident prepared by the defendant,
`DUKE HUR.
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`1 of 3
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`FILED: CHEMUNG COUNTY CLERK 12/06/2023 03:24 PM
`NYSCEF DOC. NO. 28
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`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 12/06/2023
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`5. All accident/incident reports regarding the subject accident prepared by the defendant, J.
`B. HUNT TRANSPORT, INC.
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`6. All accident/incident reports regarding the subject accident prepared by the defendant,
`COSTCO WHOLESALE CORPORATION.
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`7. Any and all reports prepared in the ordinary course of business concerning the
`incident which is the subject of this lawsuit.
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`8. A copy of all appraisals, damage estimates and repair bills concerning damage to the
`defendants' vehicle arising out of this accident.
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`9. The MV-104 Motor Vehicle Department and/or accident report prepared by, or on
`behalf of the defendants with regard to the subject accident.
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`This demand explicitly requires a response from the Defendant(s) in person and under oath
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`regarding the existence of such other coverage and responses such as "None Known" or "None to
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`the Best of our Knowledge" from Defendant(s)' counsel will be deemed non-compliant.
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`Plaintiff will object at the time of trial of this action to the introduction of any
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`documents/material that were not previously exchanged by the defendants.
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`Dated:
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`New York, New York
`December 6, 2023
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`Yours, etc.
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`Deborah Lara
`___________________________
`DEBORAH LARA, 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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`TO:
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`
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`WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP
`Attorneys for Defendants
`Duke Hur and J.B. Hunt Transport, Inc.
`1500 Broadway, Suite 2401
`New York, New York 10036
`(929) 342-6000
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`2 of 3
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`FILED: CHEMUNG COUNTY CLERK 12/06/2023 03:24 PM
`NYSCEF DOC. NO. 28
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`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 12/06/2023
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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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`3 of 3
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