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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NASSAU
`--------------------------------------------------------------- X
`MC WHRITZ DOUYON,
`Plaintiff,
`-against-
`CHARLES C. DAVENPORT and WINTER
`BROS. WASTE SYSTEM OF LONG ISLAND,
`Defendants.
`Index No.: 616213/2025
`DEMAND FOR VERIFIED
`BILL OF PARTICULARS
`--------------------------------------------------------------- X
`PLEASE TAKE NOTICE that, pursuant to Section 3041 to 3044 of the CPLR, you are
`hereby required to serve upon GORDON REES SCULLY MANSUKHANI, LLP, attorneys for
`defendant, CHARLES C. DAVENPORT and WINTERS BROS. WASTE SYSTEM OF
`LONG ISLAND, LLC i/s/h/a WINTER BROS. WASTE SYSTEM OF LONG ISLAND, a
`Verified Bill of Particulars with respect to plaintiff, pursuant to the following demand:
`1. Plaintiff’s date of birth;
`2. Plaintiff’s place of birth;
`3. Plaintiff’s Social Security Number;
`4. Plaintiff’s current address;
`5. Please furnish Plaintiff’s prior address(s) for the last ten (10) years;
`6. State the date and time of day of the occurrence.
`(A) State the exact location of the occurrence.
`(B) State the traffic controls, if any, that plaintiff will claim existed at the scene.
`(C) State what traffic controls it will be claimed the defendants violated.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
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`7. State the street or streets, including reference to intersections, crosswalks, corners or
`curbs, where necessary to accurately locate the place; and the direction in which each vehicle
`involved was traveling.
`8. Describe in detail how the accident occurred.
`9. State all acts and/or omissions constituting the alleged negligence, carelessness and
`wrongdoing on the part of this defendant, its agents, servants and/or employees.
`10. State any and all laws, rules, regulations and ordinances that are claimed to be either
`applicable to the occurrence or to have been violated by this defendant.
`11. Identify each and every injury the plaintiff claims he/she sustained in this accident;
`12. In what respect did plaintiff sustain a serious injury, as defined in subdivision (d) of
`§5102 of the Insurance Law, or economic loss greater than basic economic loss, as defined in
`subdivision (a) of §5102 of the Insurance Law.
`13. State the nature and extent of all injuries claimed.
`14. Specify those claimed to be permanent.
`15. Accurately state the length of time confined to bed.
`16. Accurately state length of time confined to home.
`17. State name of each and every hospital, clinic, or institution where any treatment or
`examination was rendered and length of time, if any, confined there. If not confined to any
`hospital, etc., so state.
`18. If it is claimed the plaintiff was treated by any health care providers, including but not
`limited to, doctors, chiropractors, nurses, physician assistants, or other health care professionals
`other than one at the hospital and/or clinic, give the name of said physician and his address.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
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`Accurately state the number of visits it is claimed the plaintiff made to each of the physicians, if
`any, specified above.
`19. State the nature of plaintiff’s employment.
`20. State the name and address of plaintiff’s employer.
`21. State length of time incapacitated from employment.
`22. State the nature and/or type of work customarily performed by the plaintiff.
`23. If self-employed, state nature of self-employment and business address.
`24. State the total amount claimed as loss of earnings, including detailed statement as to
`how such lost earnings were computed.
`25. Please provide the name and address of each and every employer plaintiff has been
`employed by for the past ten (10) years;
`26. If the plaintiff was a student, give the name and address of the school(s) attended, at or
`about the time of the accident, and accurately state the length of time incapacitated from attending
`said school(s).
`27. State the total amounts claimed as special damages for:
`(a) Physicians’ expenses;
`(b) Medical expenses;
`(c) Nurses’ expenses;
`(d) Hospital expenses;
`(e) Loss of earnings;
`(e) Any other expenses which it is claimed resulted from this occurrence.
`28. If this accident involves an automobile(s), give the year, make and model of each
`vehicle involved.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
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`29. If a claim for property damage is being asserted, accurately state cost or property
`alleged to have been damaged and its value before and after the occurrence.
`30. Itemized list of the property damage claimed, including the cost of repairing each and
`every item.
`31. State whether plaintiff has received any treatment for the pre-existing injury, illness or
`condition at anytime preceding this accident.
`32. If plaintiff has been involved in an accident subsequent to this one involving the same
`or similar injuries, state the type, date and location of the subsequent accident and the injuries
`sustained.
`33. If plaintiff claimed the defendant’s vehicle was defective, state:
`(a) which parts of the motor vehicle were defective;
`(b) what was the nature of each defect;
`(c) state whether actual or constructive notice is claimed;
`(d) if actual notice is claimed, a statement of when and to whom same was
`given, stating names and dates;
`(e) if it is alleged that defendant, his agents, servants and/or employees caused
`or created the condition, the date when such condition was caused or created; and
`(f) if constructive notice is claimed, for how long a time did the condition exist
`before the accident (in minutes, hours, days, weeks, etc., as closely as plaintiff can indicate).
`34. Set forth the points of contract of each vehicle in the accident, with:
`(a) every other vehicle; and
`(b) every pedestrian.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
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`35. In which direction was each vehicle involved in the accident proceeding at the time of
`the occurrence.
`36. With regard to the plaintiff, state:
`(a) whether plaintiff was a pedestrian, a passenger in the motor vehicle or an
`operator of a motor vehicle;
`(b) if a pedestrian, state in which direction plaintiff was proceeding at the time
`of the alleged accident;
`(c) if a passenger in a motor vehicle, state in which vehicle plaintiff was a
`passenger and in which seat in said motor vehicle the plaintiff was seated.
`37. With regard to the plaintiff’s vehicle (whether owned or operated by plaintiff or in
`which plaintiff was a passenger), state:
`(a) the name and address of:
`(i) owner of plaintiff’s vehicle; and
`(ii) operator of plaintiff’s vehicle.
`(b) the license plate and registration number of the plaintiff’s motor vehicle;
`(c) the year, make and model of plaintiff’s vehicle.
`38. With regard to each defendant’s vehicle, state:
`(a) the name and address of the owner of each vehicle;
`(b) the name and address of the operator of each vehicle; and
`(c) the license plate and registration number of each vehicle.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
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`PLEASE TAKE FURTHER NOTICE that, if the above demand is not complied with
`within the next thirty (30) days, an application will be made to preclude the plaintiffs from giving
`any evidence thereof upon the trial of this action, pursuant to the aforementioned rules.
`Dated: Harrison, New York
`February 5, 2026
`Yours etc.,
`GORDON REES SCULLY &
`MANSUKHANI, LLP
`By:_____________________________
`Ryan E. Dempsey
`Attorneys for Defendants
`CHARLES C. DAVENPORT and
`WINTERS BROS. WASTE SYSTEM OF
`LONG ISLAND, LLC i/s/h/a WINTER
`BROS. WASTE SYSTEM OF LONG
`ISLAND
`500 Mamaroneck Avenue – Ste. 503
`Harrison, New York 10528
`T: (914) 777-2209
`E: rdempsey@grsm.com
`File No.: WINTERS – 1380391
`TO: Fra ncisco Castillo, Esq.
`FRANCISCO CASTILLO LAW, P.C.
`Attorneys for Plaintiff
`133-33 Brookville Blvd, Ste. 116
`Rosedale, New York 11422
`T: (718) 528-4424
`E: francisco@franciscocastillolaw.com
`1260869/64514821v.1
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NASSAU
`--------------------------------------------------------------- X
`MC WHRITZ DOUYON,
`Plaintiff,
`-against-
`CHARLES C. DAVENPORT and WINTER
`BROS. WASTE SYSTEM OF LONG ISLAND,
`Defendants.
`Index No.: 616213/2025
`DEMAND FOR VERIFIED
`BILL OF PARTICULARS
`--------------------------------------------------------------- X
`PLEASE TAKE NOTICE that, pursuant to Section 3041 to 3044 of the CPLR, you are
`hereby required to serve upon GORDON REES SCULLY MANSUKHANI, LLP, attorneys for
`defendant, CHARLES C. DAVENPORT and WINTERS BROS. WASTE SYSTEM OF
`LONG ISLAND, LLC i/s/h/a WINTER BROS. WASTE SYSTEM OF LONG ISLAND, a
`Verified Bill of Particulars with respect to plaintiff, pursuant to the following demand:
`1. Plaintiff’s date of birth;
`2. Plaintiff’s place of birth;
`3. Plaintiff’s Social Security Number;
`4. Plaintiff’s current address;
`5. Please furnish Plaintiff’s prior address(s) for the last ten (10) years;
`6. State the date and time of day of the occurrence.
`(A) State the exact location of the occurrence.
`(B) State the traffic controls, if any, that plaintiff will claim existed at the scene.
`(C) State what traffic controls it will be claimed the defendants violated.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
`1 of 6
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`7. State the street or streets, including reference to intersections, crosswalks, corners or
`curbs, where necessary to accurately locate the place; and the direction in which each vehicle
`involved was traveling.
`8. Describe in detail how the accident occurred.
`9. State all acts and/or omissions constituting the alleged negligence, carelessness and
`wrongdoing on the part of this defendant, its agents, servants and/or employees.
`10. State any and all laws, rules, regulations and ordinances that are claimed to be either
`applicable to the occurrence or to have been violated by this defendant.
`11. Identify each and every injury the plaintiff claims he/she sustained in this accident;
`12. In what respect did plaintiff sustain a serious injury, as defined in subdivision (d) of
`§5102 of the Insurance Law, or economic loss greater than basic economic loss, as defined in
`subdivision (a) of §5102 of the Insurance Law.
`13. State the nature and extent of all injuries claimed.
`14. Specify those claimed to be permanent.
`15. Accurately state the length of time confined to bed.
`16. Accurately state length of time confined to home.
`17. State name of each and every hospital, clinic, or institution where any treatment or
`examination was rendered and length of time, if any, confined there. If not confined to any
`hospital, etc., so state.
`18. If it is claimed the plaintiff was treated by any health care providers, including but not
`limited to, doctors, chiropractors, nurses, physician assistants, or other health care professionals
`other than one at the hospital and/or clinic, give the name of said physician and his address.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
`2 of 6
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`Accurately state the number of visits it is claimed the plaintiff made to each of the physicians, if
`any, specified above.
`19. State the nature of plaintiff’s employment.
`20. State the name and address of plaintiff’s employer.
`21. State length of time incapacitated from employment.
`22. State the nature and/or type of work customarily performed by the plaintiff.
`23. If self-employed, state nature of self-employment and business address.
`24. State the total amount claimed as loss of earnings, including detailed statement as to
`how such lost earnings were computed.
`25. Please provide the name and address of each and every employer plaintiff has been
`employed by for the past ten (10) years;
`26. If the plaintiff was a student, give the name and address of the school(s) attended, at or
`about the time of the accident, and accurately state the length of time incapacitated from attending
`said school(s).
`27. State the total amounts claimed as special damages for:
`(a) Physicians’ expenses;
`(b) Medical expenses;
`(c) Nurses’ expenses;
`(d) Hospital expenses;
`(e) Loss of earnings;
`(e) Any other expenses which it is claimed resulted from this occurrence.
`28. If this accident involves an automobile(s), give the year, make and model of each
`vehicle involved.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
`3 of 6
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`29. If a claim for property damage is being asserted, accurately state cost or property
`alleged to have been damaged and its value before and after the occurrence.
`30. Itemized list of the property damage claimed, including the cost of repairing each and
`every item.
`31. State whether plaintiff has received any treatment for the pre-existing injury, illness or
`condition at anytime preceding this accident.
`32. If plaintiff has been involved in an accident subsequent to this one involving the same
`or similar injuries, state the type, date and location of the subsequent accident and the injuries
`sustained.
`33. If plaintiff claimed the defendant’s vehicle was defective, state:
`(a) which parts of the motor vehicle were defective;
`(b) what was the nature of each defect;
`(c) state whether actual or constructive notice is claimed;
`(d) if actual notice is claimed, a statement of when and to whom same was
`given, stating names and dates;
`(e) if it is alleged that defendant, his agents, servants and/or employees caused
`or created the condition, the date when such condition was caused or created; and
`(f) if constructive notice is claimed, for how long a time did the condition exist
`before the accident (in minutes, hours, days, weeks, etc., as closely as plaintiff can indicate).
`34. Set forth the points of contract of each vehicle in the accident, with:
`(a) every other vehicle; and
`(b) every pedestrian.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
`4 of 6
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`35. In which direction was each vehicle involved in the accident proceeding at the time of
`the occurrence.
`36. With regard to the plaintiff, state:
`(a) whether plaintiff was a pedestrian, a passenger in the motor vehicle or an
`operator of a motor vehicle;
`(b) if a pedestrian, state in which direction plaintiff was proceeding at the time
`of the alleged accident;
`(c) if a passenger in a motor vehicle, state in which vehicle plaintiff was a
`passenger and in which seat in said motor vehicle the plaintiff was seated.
`37. With regard to the plaintiff’s vehicle (whether owned or operated by plaintiff or in
`which plaintiff was a passenger), state:
`(a) the name and address of:
`(i) owner of plaintiff’s vehicle; and
`(ii) operator of plaintiff’s vehicle.
`(b) the license plate and registration number of the plaintiff’s motor vehicle;
`(c) the year, make and model of plaintiff’s vehicle.
`38. With regard to each defendant’s vehicle, state:
`(a) the name and address of the owner of each vehicle;
`(b) the name and address of the operator of each vehicle; and
`(c) the license plate and registration number of each vehicle.
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
`5 of 6
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`PLEASE TAKE FURTHER NOTICE that, if the above demand is not complied with
`within the next thirty (30) days, an application will be made to preclude the plaintiffs from giving
`any evidence thereof upon the trial of this action, pursuant to the aforementioned rules.
`Dated: Harrison, New York
`February 5, 2026
`Yours etc.,
`GORDON REES SCULLY &
`MANSUKHANI, LLP
`By:_____________________________
`Ryan E. Dempsey
`Attorneys for Defendants
`CHARLES C. DAVENPORT and
`WINTERS BROS. WASTE SYSTEM OF
`LONG ISLAND, LLC i/s/h/a WINTER
`BROS. WASTE SYSTEM OF LONG
`ISLAND
`500 Mamaroneck Avenue – Ste. 503
`Harrison, New York 10528
`T: (914) 777-2209
`E: rdempsey@grsm.com
`File No.: WINTERS – 1380391
`TO: Fra ncisco Castillo, Esq.
`FRANCISCO CASTILLO LAW, P.C.
`Attorneys for Plaintiff
`133-33 Brookville Blvd, Ste. 116
`Rosedale, New York 11422
`T: (718) 528-4424
`E: francisco@franciscocastillolaw.com
`1260869/64514821v.1
`FILED: NASSAU COUNTY CLERK 02/05/2026 01:19 PMINDEX NO. 623511/2025
`NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/05/2026
`6 of 6
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