PLEASE TAKE NOTICE that pursuant to Article 30 of the CPLR, you are hereby required to file and serve upon the undersigned the following Verified Bill of Particulars of Plaintiff's alleged cause of action herein within thirty (30) days from the date of service hereof.
PLEASE TAKE NOTICE, that pursuant to Rule 3120 of the Civil Practice Law and Rules, Defendant(s) demands that Plaintiff(s) produce and permit discovery by him, his attorneys, or another acting on his behalf of the following articles, documents, and things for inspection, copying, testing, and photographing within thirty (30) days after receipt hereof, at CASSELLA AND SANDUSKY, ONE METROTECH CENTER, 7th FLOOR, BROOKLYN, NY 11201, at which time said articles, documents and things will be physically inspected, copied tested, photographed, and mechanically reproduced.
Produce authorization(s) to obtain Summons and Complaint, Bill of Particulars (or like pleading) and any and all Medical Record(s) and Report(s) exchanged in all prior personal injury lawsuits brought by Plaintiff(s).
Failure to exchange copies of any treating physicians reports/records within the time set forth under the rule, will prevent the exam from going forward, and Plaintiff(s) will be responsible for any costs incurred due to a cancellation on such grounds.
) ) ss: ) I, BRENDON CASSELLA, an attorney duly admitted to practice law before the Courts of the State of New York, affirms the following to be true to under the penalties of perjury pursuant to CPLR § 2106: