`NYSCEF DOC. NO. 8
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`INDEX NO. 612686/2018
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`RECEIVED NYSCEF: 11/20/2018
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`
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NASSAU
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`EXTECH BUILDING MATERIALS, INC.,
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` Plaintiff,
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`v.
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`RED HOOK CONSTRUCTION GROUP - I,
`LLC, ET AL.,
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` Defendants.
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`
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`INDEX #: 612686/2018
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`DEFENDANTS’ FIRST REQUEST OF
`DISCOVERY AND INSPECTION
`PROPOUNDED UPON PLAINTIFF,
`PURSUANT TO CPLR §3120
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`Pursuant to CPLR §3120, Defendants hereby demand that Plaintiff produce and permit,
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`Defendants to inspect, copy, test, and/or photograph any designated documents set forth in
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`Exhibit “1” annexed hereto or any things which are in the possession, custody or control of
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`Plaintiff, which are set forth in Exhibit “1” annexed hereto on Tuesday, December 11, 2018 at
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`190 Motor Parkway, Suite 200, Hauppauge, New York, 11788.
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`Dated: November 20, 2018
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`Justin H. Scheier /s/
`Justin H. Scheier
`The Scheier Law Firm, LLC
`Attorneys for Defendants
`1465 Post Road East – Suite 100
`Westport, Connecticut 06880
`201.568.3210
`js@scheierlaw.com
`
`ntp (extech)
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`1 of 2
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`FILED: NASSAU COUNTY CLERK 11/20/2018 09:39 AM
`NYSCEF DOC. NO. 8
`
`INDEX NO. 612686/2018
`
`RECEIVED NYSCEF: 11/20/2018
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`
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`EXHIBIT “1”
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`DEFINITIONS
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`1. Whenever the word “Plaintiff” is used, it is understood that said term refers to the
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`Extech Building Materials, Inc.
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`2. Whenever the word “Defendants” is used, it is understood that said term refers to either
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`and/or both Red Hook Construction Group - I, LLC and/or Christopher Lynch.
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`3. Whenever the word “Materials” is used, it is understood that said term refers to the
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`building materials referenced in paragraph 8 of Plaintiff’s Verified Complaint.
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`REQUESTED DOCUMENTS
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`1. True and exact copy of the Credit Application and Agreement referenced in paragraph
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`7 of Plaintiff’s Verified Complaint.
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`2. True and exact copies of any and all purchase orders and/or purchase requests made by
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`Defendants to Plaintiff from January 1, 2013 to the present.
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`3. True and exact copies of any and all payments made by Defendants to Plaintiff from
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`January 1, 2013 to the present.
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`4. True and exact copies of the payments referenced in paragraph 9 of Plaintiff’s Verified
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`Complaint.
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`5. True and exact copies of all documents concerning, dealing with, referencing, and/or
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`regarding the delivery of the Materials (including but not limited to signed bills of lading and/or
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`signed delivery tickets).
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`6. True and exact copies of any and all written documents (including but not limited to
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`any and all documents concerning, dealing with, referencing, and/or regarding payment terms
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`and/or finance charges) by and between Plaintiff and Defendants.
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`ntp (extech)
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`2 of 2
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