PLEASE TAKE NOTICE that pursuant to CPLR 3041, plaintiff(s) is required within 30 days following service of this demand to serve upon MURIEL GOODE-TRUFANT, Corporation Counsel, a verified bill of particulars setting forth in reasonable detail a statement of the following: 1.

Furnish a copy of each medical provider’s report and diagnostic film(s) referring to any physical, psychiatric or psychological examination of plaintiff(s) conducted before the occurrence of the injuries alleged in the complaint and reasonably related thereto.

If plaintiff(s) allege(s) economic loss, please provide duly executed authorizations (which expire upon the conclusion of this case) permitting the Office of the Corporation Counsel of the City of New York to obtain records on file at the last employer.

Provide duly executed authorizations (which expire upon the conclusion of this case) permitting the Office of the Corporation Counsel of the City of New York to obtain records pertaining to all criminal proceedings related to the incident alleged in this lawsuit.

Provide copies of any documents, records or logs relating to any maintenance (including cleaning, altering, and shoveling) performed at, or to, the location, premises, or item complained of in plaintiff(s) complaint prior to the happening of the alleged accident or occurrence.

Defendant, FIRST CHURCH OF GOD IN CHRIST OF BROOKLYN, NEW YORK, INC., by its attorneys GOETZ SCHENKER BLEE & WIEDERHORN, as and for its answer to the plaintiff's complaint, respectfully alleges:

Pursuant to CPLR Article 16, the liability of defendant, FIRST CHURCH OF GOD IN CHRIST OF BROOKLYN, NEW YORK, INC., to the plaintiff(s) herein for non-economic loss is limited to defendant FIRST CHURCH OF GOD IN CHRIST OF BROOKLYN, NEW YORK, INC.‘s (s’) equitable share determined in accordance with the relative culpability of each person causing or contributing to the total liability for non-economic loss.

Whatever injuries and/or damages sustained by the plaintiff at the time and place alleged in the Complaint, were due to the acts of parties over whom the defendant was not obligated to exercise any control or supervision.

That if plaintiff(s) was caused to sustain damages by reason of the claims set forth in the complaint, all of which are specifically denied, and if any judgment is recovered by the plaintiff(s) against this answering defendant, that under a contract entered into between the parties or by reason of express or implied warranty, the co-defendants, HISTORY FIRST CHURCH OF GOD IN CHRIST AND BROOKLYN GHANA SEVENTH DAY ADVENTIST CHURCH, will be liable over to this answering defendant pursuant to the terms of the indemnity agreement in said contract or warranty, for the full amount of any verdict or judgment awarded to the plaintiff(s) against this answering defendant, together with attorney’s fees, costs and disbursements.

That this defendant is entitled to be indemnified by reason of a breach of contract and/or common law indemnity and held harmless by the co-defendant(s) for the claim and suit of the plaintiff herein.

Defendant, CITY OF NEW YORK, by its attorneys GOETZ SCHENKER BLEE & WIEDERHORN, as and for its answer to the plaintiff's complaint, respectfully alleges:

Whatever injuries and/or damages sustained by the plaintiff at the time and place alleged in the Complaint, were due to the acts of parties over whom the defendant was not obligated to exercise any control or supervision.

That if plaintiff(s) was caused to sustain damages by reason of the claims set forth in the complaint, all of which are specifically denied, and if any judgment is recovered by the plaintiff(s) against this answering defendant, that under a contract entered into between the parties or by reason of express or implied warranty, the co-defendants, HISTORY FIRST CHURCH OF GOD IN CHRIST AND BROOKLYN GHANA SEVENTH DAY ADVENTIST CHURCH, will be liable over to this answering defendant pursuant to the terms of the indemnity agreement in said contract or warranty, for the full amount of any verdict or judgment awarded to the plaintiff(s) against this answering defendant, together with attorney’s fees, costs and disbursements.

That this defendant is entitled to be indemnified by reason of a breach of contract and/or common law indemnity and held harmless by the co-defendant(s) for the claim and suit of the plaintiff herein.

WHEREFORE, defendant(s) CITY OF NEW YORK, demands judgment dismissing the complaint herein together with the costs and disbursements of this action.