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DEMAND FOR: Good Faith Request for Responses

Document KEVIN CABRERA v. SHOREHAM HOTEL HOLDING, LLC, et al, 151186/2024, 34 (N.Y. Sup. Ct., New York County Feb. 12, 2025)

February 12, 2025 Re: Kevin Cabrera v. Shoreham Hotel Holding, LLC, et al. Property: 33 West 55th Street, 2nd Floor, Room 216

Dear Mr. Levitz, As you are aware, my office represents the Defendants in connection with the above- referenced matter.

Based on a review of our file, we understand that Plaintiff had someone with him by the name of “Rozie,” at the time of the incident.

Please amend your responses to include the contact information for witness Rozie and the length of time the condition existed as per the notice portion of our combined demands.

Plaintiff’s continued failure to provide proper responses to discovery will hinder our client’s defense of this matter and could require our clients to engage in motion practice.

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DEMAND FOR: Discovery & Inspection

Document KEVIN CABRERA v. SHOREHAM HOTEL HOLDING, LLC, et al, 151186/2024, 31 (N.Y. Sup. Ct., New York County Jan. 22, 2025)

PLEASE TAKE NOTICE that, pursuant to CPLR § 3120, Plaintiff is hereby required to produce and furnish to the attorneys for Defendants, SHOREHAM HOTEL HOLDING, LLC, SHOREHAM HOTEL ASSOCIATES, L.P., and RONBET WEST 55th STREET, LLC, the following items or documents for discovery and inspection to the office of MILBER MAKRIS PLOUSADIS & SEIDEN, LLP, 1000 Woodbury Road, Suite 402, Woodbury, New York, 11797, within twenty (20) days of receipt of this Notice:

Duly executed HIPAA compliant authorizations, for Kolb Radiology, (dates unrestricted).

Duly executed HIPAA complaint authorizations Lenox Hill Radiology (dates unrestricted).

Duly executed HIPAA compliant authorizations for any health care provider who treated Plaintiff for lumbar injuries and/or conditions prior to July 16, 2023 (dates unrestricted).

Duly executed HIPAA compliance authorizations for any diagnostic testing to Plaintiff’s lumbar spine prior to July 16, 2023 (dates unrestricted).

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DEMAND FOR: Good Faith- Discovery

Document KEVIN CABRERA v. SHOREHAM HOTEL HOLDING, LLC, et al, 151186/2024, 30 (N.Y. Sup. Ct., New York County Jan. 6, 2025)

Milber Makris Plousadis & Seiden, LLP 1000 Woodbury Road, Suite 402 Woodbury, NewYork 11797 Re: Cabrera v. Shoreham Hotel Holding LLC, Et al. Index #: 151186/2024 (New York) Dear Counselors: As you know, referenced matter.

this office represents the Plaintiff KEVIN CABRERAin the above- Upon reviewing our file, we are not able to locate a complete response to our Combined Discovery Demands and Notice of Discovery and Inspection Insurance Disclosure, which for was served on December 4, 2024 (NYSCEFDoc.

this as our good faith If a response is not Please consider to obtain this discovery.

effort date, we will have no choice but ten (10) days of today's received within to seek the assistance the Court.

of Thank you for your anticipated courtesies.

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NOTICE OF DISCOVERY AND INSPECTION Notice of D&I for Insurance Disclosure

Document KEVIN CABRERA v. SHOREHAM HOTEL HOLDING, LLC, et al, 151186/2024, 29 (N.Y. Sup. Ct., New York County Dec. 4, 2024)

attorneys, AJLOUNYINJURYLAW PLEASETAKENOTICE that Plaintiff, hereof, Defendant, SHOREHAM hereby demands that, within twenty (20) days after

and RONBET WEST55" STREETLLC, serve upon the office by their service of the undersigned, the following:

A copy of the declaration and coverage pages of any and all contracts of insurance and insurance policies, in effect on the date of the subject accident, providing excess liability and/or "umbrella" If, coverage to any party you represent, setting a) Nameand addresses of each insurance carrier; b) Policy numbers thereof; c) Name(s) of insured; d) Dates of coverage and/or policy e) Amounts of such and each policy no such excess liability/"umbrella" forth and periods; coverage.

after investigation, the following: policies are found to exist, so state in a sworn reply to this demand.

By: Michael Levitz, Esq. for Plaintiffs- -Attorneys 320 Old Country Road, Suite 205 Garden City, NewYork 11530

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