`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF SUFFOLK
`-------------------------------------------------
`ERIC SCHER,
`Plaintiff,
`-against-
`
`MICHELLE BLUM,
`NUTRISH MISH INC.,
`Defendants.
`-------------------------------------------------
`Index No.: 612102/2025
`
`
`Scher v. Blum, et al., Index No. 612102/2025 – Deficient Answer to Interrogatory No. 6
`
`Dear Mr. Wan:
`I am writing regarding Defendants’ Responses to Plaintiff’s First Set of Interrogatories.
`Interrogatory No. 6 asks Defendants to:
`“State whether any personal expenses were charged to company accounts during the Time
`Period; if so, identify each such charge (date, amount, vendor), who incurred it, how it was
`coded, and whether/when it was reimbursed.”
`Defendants’ answer is:
`“This request calls for a legal conclusion, and as a matter of law, best left to the province of the
`Court.”
`This is plainly improper and non-responsive. Interrogatory No. 6 asks a factual question about
`whether personal expenses were run through Nutrish Mish, Inc.’s accounts and, if so, to identify
`those charges. It does not ask for a legal conclusion. CPLR 3133 requires full and complete
`answers to interrogatories. Even if Defendants wished to assert an objection, they are still
`FILED: SUFFOLK COUNTY CLERK 12/01/2025 12:33 PMINDEX NO. 612102/2025
`NYSCEF DOC. NO. 151 RECEIVED NYSCEF: 12/01/2025
`1 of 2
`
`
`
`
`
`
`
`2
`
`required to answer “to the extent not objectionable” and provide the responsive factual
`information.
`Accordingly, I demand that Defendants serve a supplemental sworn answer to Interrogatory
`No. 6 no later than December 5, 2025, either:
`1. stating unequivocally that no personal expenses were charged to company accounts
`during the relevant time period; or
`2. identifying each such charge, including the date, amount, vendor, who incurred it, how it
`was coded, and whether/when it was reimbursed, as requested in the interrogatory.
`Michelle Blum’s deposition is currently noticed for December 11, 2026. I require a proper
`answer to Interrogatory No. 6 before that deposition to avoid unnecessary delay at the deposition
`and to conduct a fair and efficient examination.
`If you do not provide a full and proper supplemental answer by the above date, I will be forced to
`seek Court intervention, including a motion to compel under CPLR 3124 and an application for
`appropriate relief regarding Ms. Blum’s deposition and costs of the motion.
`Please confirm by return email that you will provide the supplemental answer by the deadline.
`Sincerely,
`Eric Scher
`Plaintiff, Pro Se
`
`East Setauket, New York
`Dated: December 1, 2025
`Respectfully submitted,
`/s/ Eric Scher
`Eric Scher, Pro Se
`EMAIL: Notblocked1@protonmail.com
`
`TO: Smith, Carroad, Wan & Parikh, P.C. (via NYSCEF)
`FILED: SUFFOLK COUNTY CLERK 12/01/2025 12:33 PMINDEX NO. 612102/2025
`NYSCEF DOC. NO. 151 RECEIVED NYSCEF: 12/01/2025
`2 of 2
`
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
