SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
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`PEY LIN NEE,
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` Plaintiff,
` - against –
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`NEW YORK CITY TRANSIT AUTHORITY,
`METROPOLITAN TRANSIT AUTHORITY,
`METROPOLITAN TRANSIT AUTHORITY METRO
`NORTH-RAILROAD, AND METROPOLITAN
`TRANSIT AUTHORITY LONG ISLAND RAILROAD,
`
`Defendants.
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`Index No.: 153654/2025
`
`PLAINTIFF’S COMBINED
`DEMANDS FOR
`DISCOVERY
` PLEASE TAKE NOTICE, that the undersigned hereby makes the following demands upon you,
`pursuant to Article 31 of the CPLR, returnable at the offices of PAVLOUNIS & SFOUGGATAKIS,
`LLP, 9733 4th Avenue Brooklyn, New York 11209, within twenty (20) days.
` Demand for Witness Information
` Demand for Opposing Party Statements
` Demand for Insurance Agreements
` Demand for Photographs
` Demand for Surveillance Video
` Demand for Accident/Incident Reports
` Demand for Production of Documents
` Demand for Expert Witnesses Disclosure (CPLR 3101(d))
`Demand pursuant to New York State Comprehensive Insurance
`Disclosure Act
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` INSTRUCTIONS
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` A. If any of the within Demands cannot be responded to in full, please answer to the fullest
`extent possible, specifying the reasons for your inability to answer the remainder and stating what
`information you do have concerning the unanswered portion.
` B. Whenever there is an ambiguity with respect to the term document, you shall interpret the
`term so as to enlarge, rather than to restrict, discovery.
` C. The terms "relate to" and "pertaining to" shall mean to consist of, refer to, reflect or in any
`way be legally, logically, or functionally connected to with matters discussed.
` D. In the event a document is not produced because it is not presently in your po ssession,
`custody or control or because of a claim of privilege, identify the document by providing the following
`information:
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` 1. Approximate date;
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` 2. Type of document (e.g. memorandum, letter);
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` 3. General description of its subject matter;
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` 4. Identification of author and address, if applicable;
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` 5. Present location and custodian; and
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` 6. Any other description which may enable the custodian of records to locate the particular
`document.
` E. Whenever used herein, the singular shall be deemed to include the plural and the plural
`shall be deemed to include the singular; the masculine, feminine and neuter pronouns shall be deemed to
`include each other; the disjunctive "or" shall be deemed to include the conjunctive "and"; and the
`conjunctive "and" shall be deemed to include the disjunctive "or"; and each of the functional
`words -- "each," "every," "any," and "all" -- shall be deemed to include all the other functional words as
`necessary to bring within the scope of this request any documents or othe r information which might
`otherwise be construed outside the scope of these demands.
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` F. Whenever used herein, the terms "you" and "your" shall be construed to refer to the
`defendants, their employees, partners, associates, officers, assigns, agents, empl oyees, directors,
`shareholders, agents and anyone else acting on their behalf.
` DEFINITIONS
` The following definitions are for the purpose of clarifying the meaning of various words and
`phrases used herein and to help defendant understand the objectives of plaintiff's discovery efforts and
`thereby to assist the defendant in its effort to identify, locate, furnish and/or "index" the relevant
`information and materials.
` DOCUMENT
` The term "document" should be construed as broadly as permissible under the rule s of civil
`practice or civil procedure. The term is intended to encompass the following: any medium by which
`information may be communicated, recorded, or retrieved by people or computers. The term includes,
`without limitation, photographs, photostats, x -rays, motion pictures, audiotape, videotape, computer
`generated material (including e-mail), computer disks, CD-ROMS, computer tapes, and any other form
`or type of computer stored or computer retrievable data, microfilm, and microfiche or any other process
`by which information is reduced for storage or use.
` If the document or information is in a computer readable form, please specify the software
`(including the exact version and release) used to create the information. Also specify any other software,
`hardware or information such as passwords or user-suppled files that are required or desirable in order to
`examine and use the information contained on the disks. Specify the exact configuration of the hardware
`on which the information was created, including the memory size (and graphics control board in the event
`the information contains or requires graphics). Please give the exact name, release and version of the
`operating system used on the hardware on which the information was generated or modified.
` The term "document" should be deemed to include a request for any "document" which relates to
`the principal document or the subject matter of the principal document, including, e.g. (1) any material
`which was used or referred to in the preparation of the princ ipal document; (2) all attachments to the
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`document; (3) any document referred to in the principal document; and (4) all additions, deletions,
`substitutions, amendments or modifications to the original of the principal document.
` LEGAL ENTITY
` The term "leg al entity" is intended to refer to any kind or type of legal entity or method for
`conducting business. This phrase includes without restriction person(s) "doing business as" (DBA) some
`name by which the business is known by the public. It also includes p artnerships (whether general or
`special) or firms, proprietorships, any type of company, incorporated and/or unincorporated associations,
`public and private corporations, political corporations, or subdivisions, and any other type of business or
`public organization. The phrase includes any department, division, office, agency, affiliate, parent or
`subsidiary of the subject legal entity. The phrase includes any successor or predecessor legal entity. The
`phrase also includes any officer, agent, servant, or employee of the subject legal entity.
` DEMAND FOR WITNESS INFORMATION
` PLEASE TAKE NOTICE, that pursuant to Section 3101(a) of the Civil Practice Law and Rules
`and the demand of the plaintiff, you are requested to set forth in writing and under oath, the full name
`and last known address of each person claimed to be a witness to any of the following:
` A. The occurrence alleged in the complaint;
` B. Any acts, omissions or conditions which allegedly caused the occurrence in the complaint;
` C. Any actual notice allegedly given to the plaintiff or any employee or agent of the plaintiff
`of any condition which allegedly caused the occurrence alleged in the complaint;
` D. The nature and duration of any alleged condition which allegedly caused the occurrence
`alleged in the complaint;
` E. Any admissions of the plaintiff or any agent or employee of the plaintiff.
` F. Any actual notice allegedly given to the defendants or any employee or agent of the
`defendants of any condition which allegedly caused the occurrence alleged in the complaint;
` G. Any admissions of the defendants or any agent or employee of the defendants.
` If no such witnesses are known to defendants, so state in the sworn reply to this demand. The
`undersigned will object upon trial to the testimony of any witness not so identified.
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` DEMAND FOR OPPOSING PARTY STATEMENTS
` PLEASE TAKE NOTICE, that pursuant to Sections 3101(e) and 3120 of the Civil Practice Law
`and Rules and the demand of the plaintiff, you are to produce, at the time and place specified herein, and
`permit the undersigned to discover, inspect and copy each and every statement ma de or taken from the
`plaintiff and/or the agents, servants or employees of plaintiff, now in your possession, custody or control
`or the possession, custody or control of any party you represent in this action, if such statements in any
`manner bear on the issues in this action.
` DEMAND FOR INSURANCE AGREEMENTS
` PLEASE TAKE NOTICE, that pursuant to Section 3101(f) of the Civil Practice Law and Rules
`and the demand of the plaintiff, that you are to produce and permit the undersigned to inspect and copy
`the complete contents of any insurance agreement under which any person carrying on an insurance
`business may be liable to satisfy part or all of a judgment which may be entered in this action, or to
`indemnify or reimburse for payments made to satisfy the judgmen t which may be entered herein,
`including but not limited to collision, excess, umbrella and additional coverage, including but not limited
`to the declarations page, the policy, any riders, endorsements, and/or exclusions in force and effect on
`March 15, 2024; and indicate the total number of claims currently pending that fall within the same
`coverage period as this action and the amount of coverage remaining available. In the event that you
`claim that there is no excess or umbrella policy which might be available to satisfy any portion of any
`judgment against them which may be obtained by the plaintiff as a result of injuries sustained in the
`subject occurrence on March 15, 2024, it is hereby demanded that you provide an affidavit, sworn to by
`the party you represent, setting forth, based upon personal knowledge, that no such policy was in effect
`for March 15, 2024.
` DEMAND FOR PHOTOGRAPHS
` PLEASE TAKE NOTICE, that pursuant to Sections 3101 et. seq. of the Civil Practice Law and
`Rules and the demand of the plaintiff, you are to produce, at the time and place specified, and permit the
`undersigned to discover, inspect and copy, any and all photographs taken of the alleged scene or place of
`the occurrence complained of which are now in your possession, custody or control, or in the possession,
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`custody or control of any party you represent in this action, if such photographs bear in any manner upon
`the issues in this action.
` PLEASE TAKE NOTICE, that pursuant to Sections 3101 et. seq. of the Civil Practice Law and
`Rules and the demand of the plaintiff, you are to produce, at the time and place specified, and permit the
`undersigned to discover, inspect and copy, any and all photographs of the defendants' vehicle involved
`in this occurrence taken prior to the occurrence which are now in your possession, custody or control, or
`in the possession, custody or control of any party you represent in this action.
` PLEASE TAKE NOTICE, that pursuant to Sections 3101 et. seq. of the Civil Practice Law and
`Rules and the demand of the plaintiff, you are to produce, at the time and place specified, and permit the
`undersigned to discover, inspect and copy, any and all photographs of the defendants' vehicle involved
`in this occurrence taken subsequent to the occurrence which are no w in your possession, custody or
`control, or in the possession, custody or control of any party you represent in this action.
` PLEASE TAKE NOTICE, that pursuant to Sections 3101 et. seq. of the Civil Practice Law and
`Rules and the demand of the plaintiff, you are to produce, at the time and place specified, and permit the
`undersigned to discover, inspect and copy, any and all photographs of the vehicle of the plaintiff involved
`in this occurrence taken prior to the occurrence which are now in your possession, custody or control, or
`in the possession, custody or control of any party you represent in this action.
` PLEASE TAKE NOTICE, that pursuant to Sections 3101 et. seq. of the Civil Practice Law and
`Rules and the demand of the plaintiff, you are to produce, at the time and place specified, and permit the
`undersigned to discover, inspect and copy, any and all photographs of the vehicle of the plaintiff involved
`in this occurrence taken subsequent to the occurrence which are now in your possession, custody or
`control, or in the possession, custody or control of any party you represent in this action.
` DEMAND FOR SURVEILLANCE VIDEO
` PLEASE TAKE NOTICE , that plaintiff, by the undersigned attorneys, hereby demands,
`pursuant to Section 3101(a), (d), (e), and (i) an d Section 3120 of the Civil Practice Law and Rules, that
`you produce at the offices of the undersigned for inspection and copying, upon at least one full business
`day's advance notice, complete duplicates of any and all surveillance materials, depicting the location of
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`the incident complained of, or any portion thereof or depicting, or alleging to depict, the plaintiff,
`including but not limited to films, photographs, video -tapes and audio -tapes, including all out -takes,
`transcripts and memoranda thereof, whether or not defendant intends to use said materials at the time of
`trial, in your possession, custody or control, or in the possession, custody or control of any party you
`represent in this action. This demand includes surveillance materials depicting pe rson(s) other than the
`plaintiff(s) taken during the course of the surveillance investigation.
` PLEASE TAKE NOTICE, that the undersigned demands that you produce the name and address
`of the investigation company and the name and address of each videographe r, photographer and/or
`investigator that conducted surveillance and prepared, recorded, videotaped, developed, transferred and
`edited the surveillance materials referenced above.
` PLEASE TAKE NOTICE , that the undersigned demands that you produce all memora nda,
`transcripts, notes, logs, journals, billing records and time records of each videographer, photographer
`and/or investigator, including but not limited to an itemized list indicating the date(s) and time(s) each
`videographer, photographer and/or investigator conducted surveillance.
` PLEASE TAKE NOTICE, that the undersigned demands that you provide all records regarding
`the amount or footage of film, videotape and/or audiotape used, the type of equipment used to take,
`develop, convert, transfer and edit such film, videotape or audiotape, the make and model of all
`equipment, lenses and range setting employed.
` PLEASE TAKE NOTICE, that the undersigned demands that you produce each videographer,
`photographer and investigator that conducted surveillance and prepared, recorded, videotaped, developed
`and edited the surveillance materials referenced above for an oral deposition within thirty (30) days from
`the date of the service of the surveillance materials.
` PLEASE TAKE NOTICE , that in the event any such materials come into your possession,
`custody or control, or into the possession, custody or control of any party you represent in this action or
`of any of your agents, servants, employees, hirees, or contractors, at any time af ter the date of this
`demand, then demand is made that you produce such material for inspection and copying, upon at least
`one full business day's advance notice, within twenty (20) days after said materials come into your
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`possession, custody or control, or into the possession, custody or control of any party you represent in
`this action or of any of your agents, servants, employees, hirees, or contractors.
` DEMAND FOR ACCIDENT/INCIDENT REPORTS
` PLEASE TAKE NOTICE, that the undersigned demands pursuant to CP LR 3101(g), that you
`are to produce a true copy of each and every accident and/or incident prepared in the ordinary course of
`business of any party you represent which is referable to the incident complained of herein.
`DEMAND FOR PRODUCTION OF DOCUMENTS (PREMISES)
` TAKE FURTHER NOTICE, that pursuant to the demand of the plaintiff you are to produce and
`permit the undersigned to inspect and copy any residential or commercial lease, including all amendments
`and riders thereto, between the defendant and any ot her person or entity which governs any portion of
`the subject internal staircase located at 47th Street and Madison Avenue entrance, and was going
`from the 47th Street Cross-Passage from the upper level to the lower level, New York, NY. which
`was involved in the happening of the occurrence complained of on March 15, 2024.
` TAKE FURTHER NOTICE, that pursuant to the demand of the plaintiff you are to produce and
`permit the undersigned to inspect and copy all maintenance and repair records regarding the subject
`internal staircase located at 47th Street and Madison Avenue entrance, and was going from the
`47th Street Cross-Passage from the upper level to the lower level, New York, NY. for a period of
`three (3) years prior to March 15, 2024.
` TAKE FURTHER NOTICE, that pursuant to the demand of the plaintiff you are to produce and
`permit the undersigned to inspect and copy any and all cleaning records, including schedules of regular
`cleaning, regarding the subject internal staircase located at 4 7th Street and Madison Avenue
`entrance, and was going from the 47th Street Cross-Passage from the upper level to the lower level,
`New York, NY. for a period of three (3) years prior to March 15, 2024.
` TAKE FURTHER NOTICE, that pursuant to the demand of t he plaintiff you are to produce
`and permit the undersigned to inspect and copy records of any construction, demolition, alteration,
`modification and/or rehabilitation projects involving the subject internal staircase located at 47th
`Street and Madison Avenue entrance, and was going from the 47th Street Cross-Passage from the
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`upper level to the lower level, , New York, NY.. for a period of three (3) years prior to March 15, 2024.
` TAKE FURTHER NOTICE, that pursuant to the demand of the plaintiff you are to produce and
`permit the undersigned to inspect and copy all local building code violations received by the defendants
`regarding the subject internal staircase located at 47th Street and Madison Avenue entrance, and
`was going from the 47th Street Cross -Passage from the upper level to the lower level, New York,
`NY. for a period of three (3) years prior to March 15, 2024, including the date each violation was issued,
`what it was issued for, who it was issued by, and, if the violation was cleared, the date it was cleared.
` TAKE FURTHER NOTICE, that pursuant to the demand of the plaintiff you are to produce for
`discovery, inspection and copying, any contract between the party you represent and any other person or
`entity regarding the management of the subject pr emises which was in force and effect on March 15,
`2024.
` TAKE FURTHER NOTICE, that pursuant to the demand of the plaintiff you are to produce the
`name, and if not still employed by the defendant, the current or last known address of each and every
`person employed by the defendants for the purpose of performing maintenance, repair and/or cleaning of
`any portion of the subject premises for a period of 1 year prior to March 15, 2024.
` DEMAND IS FURTHER MADE that you are to produce copies of the following documents:
` 1) The name of each and every person or entity who it is claimed by the party you represent to have been
`contractually obligated to remove snow and/or ice from on or around the internal staircase located at
`47th Street and Madison Avenue entrance, and was going from the 47th Street Cross-Passage from
`the upper level to the lower level, , New York, NY. on March 15, 2024.
` 2) Each and every lease, contract or other writing which is claimed by the party you represent to establish
`the responsibility for any person or entity named in response to sub-paragraph (1) of this demand as being
`responsible for the removal of snow and/or ice from in, on or around the internal staircase located at
`47th Street and Madison Avenue entrance, and was going from the 47th Street Cross-Passage from
`the upper level to the lower level, , New York, NY. on March 15, 2024.
` 3) Each and every document, contract, lease or writing, other than those produced in response to
`subparagraph (2) of this demand, which details the respective rights, responsibilities, duties and/or
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`obligations of the party you represent and any third person or entity with respect to the removal of snow
`and/or ice from in, on and/or around the internal staircase located at 47th Street and Madison Avenue
`entrance, and was going from the 47th Street Cross-Passage from the upper level to the lower level,
`, New York, NY. on March 15, 2024.
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` DEMAND FOR EXPERT WITNESS INFORMATION (3101(d)
` TAKE FURTHER NOTICE that pursuant to Section 3101(d) of the Civil Practice Law and
`Rules, you are hereby required to furnish the attorneys for the plaintiffs, discovery as to each person
`whom you expect to call as an expert regarding the following:
` 1. State the name and address of every expert retained or employed by you in anticipation of
`this litigation or preparation for trial whom you expect to call as a witness at the trial. For each, state the
`following:
` A. The subject matter on which the expert is expected to testify.
` B. The substance of the facts and opinions to which the expert is expected to testify.
` C. A brief summary of the grounds for each such opinion.
` D. A brief chronological resume of each witness' educational background and professional
`background, including the associations or societies of which each expert is a member.
` E. Whether each named expert will testify as an expert at the trial of this action.
` 1. With respect to any and all proposed medical expert witnesses, indicate:
` A. The area of expertise.
` B. Educational background, including the name and address of each medical school attended.
` C. The name and address of each hospital at which an internship and residency was served
`and the dates thereof.
` D. The name and address of each hosp ital in which privileges of admitting patients is
`extended, and the nature of the privilege.
` E. The name and address of each hospital or university of affiliation.
` F. The state or states in which this individual was licensed to practice medicine.
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` G. Each state in which this individual is actively engaged in the practice of medicine.
` H. Membership in any professional societies and the date of each such membership.
` I. The present board certifications and/or qualifications, if any, and the dates thereof for each
`expert witness.
` J. The subject matter of testimony for each expert, including any alleged departure from
`good and accepted medical practice.
` K. The substance of the facts and opinions of the expert testimony, including a summary of
`the grounds for each opinion.
` L. If you expect to call an economist or actuary, state:
` a. A specific description of the losses for which such calculations will be made (i.e., present
`value of the loss of future earnings, present value of the loss of second job ea rnings, present value of
`future medical expenses, etc.).
` b. The undiscounted amount of such loss.
` c. The present value of the dollar amount of such loss.
` d. The discount rate applied by such person to determine present value and the reason for
`such rate.
` e. The number of years involved in such discounting process and the opinions and facts on
`which the economist bases the determination of that number of years.
` f. With regard to testing concerning a growth of future income in an annual or other basis at
`a projected rate of income greater than the income earned by the plaintiff when last employed, state the
`growth rate for such income as estimated by such person, the opinions and facts on which that estimate
`is based, and specifying the publication and location by the defendant.
` g. Specify each factor other than those which have been noted above, which the person has
`used in calculating the net amount of the present value of the loss and identify specifically the source
`material and page number on which such person bases his opinion or draws the facts on which he relied.
` h. With regard to any information secured from any test, publication, graph, chart or study
`other than as already designated above upon which the expert relied in reaching his conclusions, describe
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`or designate such publication or matter in writing with sufficient specificity to permit its identification
`and location by plaintiff.
` i. In detail, state precisely the manner in which the person reached the conclusions showing
`the mathematical calculations involved.
` j. With regard to any report, memoranda, or any other matter in writing showing in whole
`or in part the expert's conclusions or the facts upon which such conclusions were based, state the date of
`such writing and the names and addresses of persons having copies of it.
` k. State the names, addresses and qualifications of all expert witnesses and other persons
`known to defendants to have made studies or analyses as to the cause of the alleged injury involved
`herein.
`DEMAND PURSUANT TO NEW YORK STATE
`COMPREHENSIVE INSURANCE DISCLOSURE ACT
`1. All primary, excess and umbrella policies, contracts or agreements issued by private or publicly traded
`stock companies, mutual insurance companies, captive insurance entities, ri sk retention groups,
`reciprocal insurance exchanges, syndicates, including, but not limited to, Lloyd's underwriters as defined
`in section six thousand one hundred sixteen of the Insurance Law, surplus line insurers and self insurance
`programs sold or delivered within the State of New York applicable to the occurrence complained of in
`this action which allow for defense, indemnification, etc. of the defendants herein.
` 2. A complete copy of any policy, contract or agreement referred to in paragraph one above, including
`but not limited to declarations, insuring agreements, conditions, exclusions, endorsements and similar
`provisions of any related policy applicable to the occurrence complained of in this action.
` 3. The contact information, including t he telephone number and email address, of any person or
`persons responsible for adjusting the claim made to or against any of the defendants in this action,
`including third party administrators and persons within the insuring entity to whom the third party
`administrator is required to report.
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` 4. The amounts available under any policy, contract or agreement to satisfy the judgment which may
`be the result of this action, or to reimburse for payments made to satisfy such judgment applicable in this
`action.
` 5. The identification with the caption, venue, index number, docket number or other case identifier of
`any lawsuit(s) that has/have reduced, eroded or may reduce or erode any policy amount or limits
`applicable to the occurrence complained of in this action. In addition, plaintiff requests the dates the
`lawsuit(s) was/were filed and the identity and contact information of the attorneys for all represented
`parties in any such lawsuit(s).
` 6. The amount, if any of any payment of attorneys fees that have eroded or reduce the face value of
`the policy, along with the name and address of any attorney who received any such payment.
` 7. Any insurance applications which resulted in the issuance any policies contemplated by the
`foregoing items.
` PLEASE TAKE NOTICE, that under CPLR section 3101(f)(2) defendants, third party defendants or
`defendants on any cross claims or counter claims are required to, and have an ongoing obligation to make
`reasonable efforts to ensure that information disclosed pursua nt to this demand remains accurate and
`complete and must provide updated information to plaintiff within thirty days of receiving indication that
`any prior disclosure was inaccurate or incomplete.
` PLEASE TAKE FURTHER NOTICE, that under CPLR section 31 01(f)(2), this demand and its
`attendant obligations exist during the pendency of the entire litigation herein, and continue for sixty days
`after any settlement or final judgment, inclusive of all appeals.
` PLEASE TAKE FURTHER NOTICE, that under CPLR se ction 3101(f)(2), any response to the
`foregoing demands shall be certified by the defendant, third party defendant or defendant on a cross claim
`and/or counter claim as well as counsel appearing for any such party, sworn in the form of an affidavit
`or affirmation where appropriate stating that the disclosed information is accurate and complete and that
`reasonable efforts have been undertaken to ensure same.
` PLEASE TAKE FURTHER NOTICE, that under CPLR section 3101(f)(2), your response to this
`demand is required after sixty days of service of this demand, and if information responsive to same has
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`been served in this action prior to this demand, any information not exchanged previously must issue
`within sixty days hereof. The above discovery may be complie d with by sending true copies of the
`aforementioned documents and/or responses to the undersigned on or before the date mentioned above.
` TAKE FURTHER NOTICE, that the foregoing are continuing demands and that if the above
`items are obtained after the date of the response to these demands, they are to be furnished to the offices
`of the undersigned pursuant to these demands.
`Dated: Brooklyn, New York
` July 17, 2025
` Yours, etc.
` Andrew G. Stouggatakis
` Andrew G. Sfouggatakis, Esq.
` PAVLOUNIS & SFOUGGATAKIS, LLP
` Attorneys for Plaintiff
` PEY LIN NEE
` 9733 4th Avenue
` Brooklyn, New York 11209
` (718) 787-1430
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`TO: SHAFER PARTNERS, LLP
` Attorneys for all Defendants
`125 Maiden Lane, Suite 16A
`New York, NY 10038-3202
`(212) 267-0011
`File #: LIR-00118
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`FILED: NEW YORK COUNTY CLERK 07/17/2025 02:32 PMINDEX NO. 153654/2025
`NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 07/17/2025
`14 of 19
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`--------------------------------------------------------------------X
`PEY LIN NEE,
`
` Plaintiff,
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` -against-
`
`NEW YORK CITY TRANSIT AUTHORITY,
`METROPOLITAN TRANSIT AUTHORITY,
`METROPOLITAN TRANSIT AUTHORITY METRO
`NORTH-RAILROAD, AND METROPOLITAN
`TRANSIT AUTHORITY LONG ISLAND RAILROAD,
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` Defendants.
`--------------------------------------------------------------------X
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`Index No.: 153654/2025
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`DEMAND FOR A VERIFIED
`BILL OF PARTICULARS AS
`TO AFFIRMATIVE
`DEFENSES
`
`C O U N S E L O R S:
` PLEASE TAKE NOTICE, that pursuant to Section 3044 and Rule 3042 of the Civil Practice
`Law and Rules, defendants are hereby required to serve a Verified Bill of P articulars upon the
`undersigned within thirty (30) days after the receipt of this demand.
`
` A detailed statement of the act or acts of negligence, culpability, lack of care or omissions on the
`part