verdict or judgment against this Answering Defendant, said verdict or judgment must be reduced pursuant to CPLR 4545(c) by those amounts which have or will replace or Plaintiff in whole or in part for past indemnify any or future claimed economic loss or from any collateral source such as insurance, Social Security, Workers' Compensation or employee benefit programs.
demands judgment dismissing the Plaintiff's Complaint against them, together with the costs and disbursements of this action, and for any expenses incurred by them in the defense thereof, including attorneys' fees actually expended.
State separately the names and addresses of all physicians, hospitals health providers treated Plaintiff connection with the and/or other care who in injuries allegedly sustained as a result of this incident and the dates of said treatment.
days of receipt of this notice, at the office of the undersigned, located at 81 Main Street, Suite 215, White Plains, New York 10601, the following objects.
Should Plaintiff fail to produce said documents and objects for inspection, and as required the undersigned will move this examination photocopying herein, Court, pursuant to CPLR 3124 and 3126, for the appropriate relief, sanctions and penalties prescribed therein.