PLEASETAKENOTICE, that pursuant Practice Law and Rules 31 of the Civil to Article upon oral examination of all adverse parties will be taken before a Notary Public who the testimony, party herein and is not a or employee of an attorney, is not an attorney, for any party or prospective person who would be disqualified or because of consanguinity to act as a juror because of interest to be held via Zoom, at 7 Bayview Avenue, remote video conference or affinity to any party herein, Northport, NewYork on the 20* day of January, 2025, at 10:00 o'clock in the forenoon of that day to evidence material and necessary in the -- defense -- of this action: with respect facts and circumstances All of the relevant on the 18* day of December, 2020, including damages.

in connection with the accident which occurred and negligence, negligence, contributory liability to produce at such examination the said person to be examined is That the required reports, memorandaand other writings Any and all relevant to the subject matter following: records, of the instant action.

Dated: Northport, NewYork October 29, 2024 Yours, etc.

) ) ANABERNHARDT,being duly sworn, deposes and says: is over 18 years of age and resides That your deponent in Northport, NewYork.

That on the 29th day of October, 2024, deponent served the within, NOTICEFOR

PLEASETAKENOTICE, pursuant to the applicable rules of the CPLR, the undersigned demandsthat you serve and/or comply with the following within 20 days from the date hereof with to plaintiff's dated July 8, 2024: Supplemental Bill of Particulars A duly executed authorization A duly executed authorization to obtain plaintiff's to obtain plaintiff's workers' compensation file.

A duly executed HIPAA-compliant Lower Manhattan Hospital regarding A duly executed HIPAA-compliant authorization plaintiff's second surgery on June 4, 2024. authorization to obtain plaintiff's records from Dr. Darren J. Friedman.

Aduly executed HIPAA-compliant for August 7, 2021, and September 7, 2022. authorization to obtain plaintiff's MRIfilms and

undersigned pursuant PLEASETAKEFURTHERNOTICE that upon your failure to produce the documents a motion maybe made for discovery demandedherein, Dated: Northport, NewYork October 29, 2024 and inspection and costs maybe requested.

) ) ANABERNHARDT,being duly sworn, deposes and says: is over 18 years of age and resides That your deponent in Northport, NewYork.

Moreover, million Defendant holds umbrella policy with NewEmpire Group, Ltd., under Certificate No MCREA- to the annexed 7146-03, which has a coverage limit of $5,000,000 pursuant of Participation.

To the extent insurance coverage is identified, the (five million dollars), dollars) Certificate excess or umbrella policies additional Defendant will supplement this response accordingly.

PLEASETAKENOTICEthat the Defendant reserves the right to supplement and/or amendthis response, up to, and including Dated: Northport, NewYork October 21, 2024 the time of trial.

MICHELLEMUNCHbeing duly sworn, deposes and says: is over 18 years of age and resides That your deponent is not a party to this action, at Northport, NewYork. )

) That on the 23rd day of October 2024, deponent served a true copy of the annexed

to and forming part of this Certificate

12:01AM standard time at the mailing address of the Risk Purchasing Group Memberas stated herein.

Total Locations: Units: Total Residential Commercial: 0 Sq.

Ft.

Vacant Land: Parking: Total Autos:

Uponthe foregoing documents,it is ordered that plaintiffs’ motion to amendis granted without opposition.

Pursuant to CPLR § 3025(b), “[a] party may amendhis pleading, or supplementit by setting forth additional or subsequenttransactions or occurrences, at any time by leave of court or by stipulation of all parties.” Leave to amend pleadingsis generally freely granted, absent prejudice and surprise resulting from the delay.

To find prejudice, there must be someindication that the defendant has been hinderedin the preparation of his case or prevented from taking some measure in support of his position.

Here, plaintiff seeks leave to amend the caption by correcting the name of defendant “Same Day Delivery, Inc.” to “Same Day Delivery Inc.,” and leave to issue a Supplemental Summonsand file and serve an Amended Complaintin this action to add “Amazon Logistics, Inc.”as a direct party defendant.

Accordingly,it is hereby ORDEREDthatthe plaintiff's motion for leave to amend the complaintis granted; and it is further ORDEREDthat the amended complaint, in the form annexed to the motion papers, shall be deemed served upon service of a copy of this order with notice of entry upon all parties who have appearedin the action; andit is further ORDEREDthat a supplemental summonsand amended complaint, in the form annexed to the motion papers, shall be served, in accordance with the Civil Practice Law and Rules, upon the additional parties in this action within 30 daysafter service of a copy of this order with notice of entry; and it is further 150967/2020 ALLEVA, ANTHONYvs.