In the Bill of Particulars, the parties shall clearly delineate all claims of damages, including, but not limited to, loss of earnings/profit, medical expenses andphysical injuries/limitations.

Defendants shall process each authorization within 30 days of receipt and shall follow up at least monthly until the recordsare received.Ifplaintifftimely provides proper authorizations then non-receipt of materials shall not be grounds for delaying plaintiff's deposition unless proof of timely processing, or proof of rejection by the provider, and follow-up is submitted to the plaintiff and/or court.

At least 20 days before the date of such examination the plaintiff shall provide copies, to all other parties, of the medical records ofproviders whopreviously treated or examinedplaintiff with respect to the injuries alleged.

Failure to upload a consent order, or appear at the conference will "Administratively result in the matter being marked "Adminitratively Dismissed" on default.

Nothing in this paragraph relieves counsel of the obligation of demonstrating sufficient good faith efforts to resolve their discovery disputes withoutresort to court intervention via motion (see 22 NYCRR 202.7[a][2]).

of the Civil Practice Law and Rules, you are hereby required to serve a Verified Bill of Particulars for each plaintiff named in the instant action upon the undersigned within thirty (30) days after receipt of this Demand, setting forth the following:

An authorization for full access to all content and date for the three (3) years prior to the alleged incident date to present, for each internet/web based networking site maintained and/or participated in by plaintiff, including but not limited to any Facebook, MySpace, Twitter, LinkedIn, Flickr, Friendster, Pinterest, Foursquare, Bevo, About.me, Buzznet, Google Buzz, Google Plus, Orkut, Ning, LiveJournal, Snapfish, Vine, Instagram, YouTube, Open Diary, Evite, Blogspot, Zoosk, High Five, Tumblr, Snapchat, Fitbit, Friendster account and any other site relating to the social networking, recreational activities or employment and/or potential employment of plaintiff, made pursuant to the Stored Communications Act, 18 U.S.C. §2701 and particularly, §2702(b)(3).

For each Internet and web based social networking site maintained by plaintiff, including any Facebook, MySpace, Twitter, LinkedIn, Flickr, Friendster, Pinterest, Foursquare, Bevo, About.me, Buzznet, Google Buzz, Google Plus, Orkut, Ning, LiveJournal, Snapfish, Vine, Instagram, YouTube, Open Diary, Evite, Blogspot, Zoosk, High Five, Tumblr, Snapchat, Fitbit account, and any other site relating to the social networking, recreational activities or employment and/or potential employment of plaintiff, please produce and electronic and printed copy all account data and content for the period starting three years (3) prior to the date of the alleged incident through the present.

A demand is herein made for the preservation of all Internet/web based employment related and/or social networking websites, all photographs, video recordings, essays, emails, blogs, chat room discussions and statements contained in any such sites, any accounts created, maintained, managed, supervised, participated in or controlled by plaintiff, including but not limited to any employment related site in which plaintiff participates, as well as all Internet/web based social networking websites, including but not limited to plaintiff’s Facebook, MySpace, Twitter, LinkedIn, Flickr, Friendster, Pinterest, Foursquare, Bevo, About.me, Buzznet, Google Buzz, Google Plus, Orkut, Ning, LiveJournal, Snapfish, Vine, Instagram, YouTube, Open Diary, Evite, Blogspot, Zoosk, High Five, Tumblr, Snapchat, Fitbit account.

State whether any hardcopies exist for any post, e-mails, tweets, replies, retweets, direct message, status updates, wall comments, groups joined, activity streams, and blog entries you have deleted from each such account, as identified above in response to demand No. 6.

DOLLARTREESTORES,INC., was and still and for many years prior thereto, defendant is conducting business as a retail supermarket that was open and/or invited members of the public, Plaintiff, to be its customers and patrons including at a location with an address commonlyknown and designated as 2120 Rockaway Parkway, County of Kings and State of NewYork.

That at all times herein mentioned, the defendant DOLLARTREESTORES,INC., through its agents, servants, contractors and/or employees, hired all personnel related to premises, with an address commonly known and designated as 2120 employment at a certain Rockaway Parkway, in the County of Kings and State of NewYork.

That at all times hereinafter alleged, Defendant, DOLLARTREESTORES,INC., supermarket known and/or employees, operated a certain through its agents, contractors servants, Tree" with an address commonly known and designated as 2120 Rockaway Parkway, as "Dollar in the County of Kings and State of NewYork.

alleged, Defendant, DOLLARTREESTORES,INC., supermarket known a certain through its agents, and/or employees, inspected contractors servants, Tree" with an address commonly known and designated as 2120 Rockaway Parkway, as "Dollar in the County of Kings and State of NewYork.

That at all times hereinafter through its agents, servants, contractors and/or all personnel hired related to employees, Tree" with an address commonlyknown supermarket known as "Dollar employment at a certain and designated as 2120 Rockaway Parkway, in the County of Kings and State of NewYork.

(20) days after twenty Defendants, DOLLARTREESTORES, INC., and DOLLARTREEINC., service hereof, serve upon the office of the undersigned, the following:

and coverage pages of any and all contracts of insurance and insurance policies, in effect accident, providing excess liability and/or "umbrella" coverage to any party you represent, setting forth the following: a) Nameand addresses of each insurance carrier; b) Policy numbers thereof; c) Name(s) of insured; d) Dates of coverage and/or policy periods; and e) Amounts of such and each policy coverage.

after If, investigation, no such excess liability/"umbrella" policies are found to exist, so state in a sworn reply to this demand.

violation failure to promptly disclose coverage is a PLEASETAKEFURTHERNOTICE, that failure to produce said documents in a timely manner will result in a motion for appropriate relief.

320 Old Country Road, Suite 205 Garden City, NewYork 11530 (5 16) 535-5555

The undersigned hereby respectfully requests a Preliminary Conference.

The names, addresses and telephone numbers of all attorneys appearing

and DOLLARTREE, INC., 100 Duffy Avenue, Suite 510 NewYork, 11801 Hicksville,

320 Old Country Road, Suite 205 Garden City, NewYork 11530

and DOLLARTREE, INC., 100 Duffy Avenue, Suite 510 Hicksville, NewYork, 11801

If none, . Relationship to instant case PARFIES in the space provided.

All demandsare objected to, to the extent they are overly broad, unduly burdensome, redundant, constitute interrogatories, and/or seek information and/or materials that are irrelevant, privileged, testimonial in nature and/or otherwise beyond the scope of discovery or improper for inclusion herein:

Plaintiff suffered the following injuries which were caused, aggravated, exacerbated and/or otherwise enhanced by the Defendant's negligence, the sequelae of which are, upon information and belief, and permanent in nature:

" OnDecember 1, 2021, Plaintiff 80 mgInjection, underwent a Methylpresnisolone : The patient was asked to lie conducted at Pain Physicians, N.Y. in the lateral decubitus hip turned upward.

" " " " " " " " chondromalacia involving the midline facetmore so supenorly and involving and underlying cortical thinning of the trochlear the lateral facet subcortical reactive toward groove extending where there is inferiorly bone marrow edema the suprapatellar bursa; with a mild alta Trochlear the medial underlying inferolaterally; Paucity of patellofemoral fluid which extends into synovial Edema in the prepatellar subcutaneous tissues; involvement of the distal Localized patellar tendinosis/tendinopathy position to the patella; Strain of the medial collateral attachment ligament femoral at its site; Edemaposteromedially the level of the joint margin associated with a paucity of fluid in at the medial gastrocnemius-semimembranosus semimembranosus bursa and there is distal tendinosis/tendinopathy; Strain/Sprain; Restricted Range of Motion.

" " " " " the superolateral aspect of the labium; bursa representing bursitis with Fraying and superficial tear involving Synovial at the hip articular fluid surface; Accumulation of fluid in the greater trochanteric edemaand inflammation; peritendinous The gluteus medius tendon becomes enlarged and inhomogeneous distally representing with superimposed interstitial extending tendinosis/tendinopathy approximately tearing 1.8 cmin length extending site on the greater superior to its attachment just trochanter; Sprain/Strain; Restricted Range of Motion. "