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]).

Hon.

Rachel Freier, IAS Part 6, Room441 IT IS HEREBYSTIPULATEDANDAGREED,by and between and on consent of the ANGELLANGUMASRODRIGUEZand defendants

and TRANSCOINC., that defendants' Order to Show is hereby withdrawn.

Cause (Motion No. 1) returnable on January 15, 2024, Dated: NewYork, NewYork 14, 2025 January

At IAS Part 72 of the Supreme Court of the State of New York, County of Kings, held at the Courthouse, 260 Adams Street, Brooklyn, New York on the ____ day of ___________, , 2024.

On reading and filing the annexed Affirmation of Lorne M. Reiter, dated November 27, 2024, with all of the exhibits annexed thereto, and upon all prior pleadings and proceedings heretofore had herein; and it being the first application of its kind made to the Court; it is hereby ORDERED that plaintiff ANGEL LANGUMAS RODRIGUEZ appear and show cause before this Court at the IAS Ex Parte Part 72 at the Supreme Court, Kings County Courthouse, 260 Adams Street, Brooklyn, New York 11201 on the ________ day of ____________ at 9:30 o’clock in the forenoon, or as soon thereafter as counsel may be heard, why an order should not be granted, pursuant to CPLR §3126(3), dismissing the plaintiff’s Verified Complaint for her willful failure to comply with defendants’ demand for ad damnum; or, in the alternative; pursuant to CPLR §3124, directing that the plaintiff comply with defendants’ demand for ad damnum.

ORDERED that service of a copy of this Order, and a copy of the papers upon which it is based, be made upon counsel for all parties by _______________________ on or before the ____ day of ____________ , 2024.

Personal Service shall be deemed good and sufficient service thereof.

15th January, 2025 23rd December 11th

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