FILED: KINGS COUNTY CLERK 05/04/ :49 AM INDEX NO /2017 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/04/2018

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Theodore Terry
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1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS X YVONNE JEAN BAPTISTE, Plaintiff, RESPONSE TO DEFENDANT'S -against- COMBINED DEMANDS NEW YORK CITY TRANSIT AUTHORITY AND BUS OPERATOR "JOHN DOE" BEING THE Index No.: FICTITIOUS OPERATOR OF BUS ROUTE B6, /2017 Defendants X PLEASE TAKE NOTICE that the Plaintiff, in answer to Defendants, NEW YORK CITY TRANSIT'S Combined Demands, dated December 16, 2015 and without conceding the competency, relevancy or materiality of the matters herein and reserving the right to further amend these answers as more information becomes available or if omissions or errors have been made herein states upon information and belief as follows: RESPONSE TO DEMAND FOR MEDICAL AND HOSPITAL RECORDS: Find attached copies of the following: Emergency room records from Kings County Hospital Center Treatment records of Brooklyn Health Center Treatment records of Midtown Health Center RESPONSE TO DEMAND FOR NAMES AND ADDRESSES OF ALL WITNESSES The only known witnesses are the parties named herein; when and if the identity of any other witnesses becomes available, same will be forwarded forthwith. RESPONSE TO NOTICE OF DISCOVERY AND INPSECTION FOR EXPERT INFORMATION The Plaintiff has not yet decided upon the identity of any expert witnesses at this time; when and if such decision is made, same will be forwarded forthwith. 1 of 5

2 RESPONSE TO NOTICE TO PRODUCE PHOTOGRAPHS The Plaintiff is not currently in possession of any such photographs at this time. RESPONSE TO NOTICE FOR DISCOVERY & INSPECTION OF INCOME TAX AND EMPLOYMENT Annexed hereto is an authorization to receive plaintiff's employment records from Beacon Hotel, 2130 Broadway, New York, NY RESPONSE TO NOTICE FOR DISCOVERY AND INSPECTION FOR COLLATERAL SOURCE To be supplied. RESPONSE TO DEMAND FOR WORKERS' COMPENSATION RESPONSE TO NOTICE FOR DISCOVERY AND INSPECTION FOR MARRIAGE CERTIFICATES RESPONSE TO NOTICE TO PRODUCE STATUTORY HEARING Find attached a copy of the 50 - H transcript. RESPONSE TO DEMAND FOR SCHOOL RECORDS RESPONSE TO DEMAND FOR PHARMACY RECORDS To be supplied, if applicable. RESPONSE TO DEMAND FOR METROCARD To be supplied if Plaintiff is still is possession of same. RESPONSE TO NOTICE OF DISCOVERY AND INSPECTION OF BIRTH CERTIFICATE The Plaintiff is not an infant. RESPONSE TO DEMAND FOR STATEMENTS The Plaintiff is not currently in possession of any such statements ' 2 of 5

3 RESPONSE TO DEMAND FOR DISCOVERY & INSPECTION FOR WRITTEN STATEMENTS The Plaintiff is not currently in possession of any such written statements RESPONSE TO DEMAND TO PRODUCE CONTRACTS RESPONSE TO DEMAND TO PRODUCE CONSTRUCTION CONTRACTS RESPONSE TO DEMAND FOR DOCUMENTS RESPONSE TO NOTICE TO PRODUCE ACCIDENT REPORTS applicable, plaintiff is not in possession of any accident reports. Dated: Staten Island, New York January 5, 2018 Your. ANTHON L AldEDURI AMEDURI, GALANTE & FRISCIA, LLP Attorneys for Plaintiff 471 Bement Avenue Staten Island, New York (718) Our File No TO: Lawrence Heisler Attorneys for Defendant - NYC TRANSIT AUTHORITY 130 Livingston Street - 11th FlOOr BU of 5

4 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) : ss: COUNTY OF RICHMOND ) Our File No.: 5034 Janet Cruz Diaz, being sworn says: I am not a party to the action, am over 18 years of age and reside in Richmond County. On January 12, 2018, I served a true copy of the annexed RESPONSE TO DEFENDANT'S COMBINED DEMANDS by mailing the same in a sealed envelope, with postage prepaid thereon, in a post-office or official depository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressee as indicated below: Law Office of Lawrence Heisler 130 Livingston Street, 1lth F1 Cruz Dia Sworn to before me this 12"' of January, 2018 r' / /? ary Pub c r Aluf.,0~+45 r ~w -V ~ ~ ANTHOf-IV 1. GAI.ANTE '~ tan Pubht. Elme of New Yor. No Qualified in thchmond Coun Cuacniso,ion Expiivr Nov. 30,$0~ '~'u 'vdiztr,r4'-~g 4 of 5

5 Index No. 323 Z ]] Å2d/4 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND YVONNE JEAN BAPTISTE Plaintiff, -against- NEW YORK CITY TRANSIT AUTHORITY AND "JOHN DOE", being the fictitious operator of bus route B6, Defendants RESPONSE TO DEFENANT'S COMBINED DEMAND AMEDURI, GALANTE 4 FRISCIA, LLP Attorneys for Plaintiff 471 Bement Avenue Staten Island, New York (718) TO: Lawrence Heisler Attorneys for Defendant NEW YORK CITY TRANSIT 130 Livingston Street, 1lth F1 (718) of 5

FILED: RICHMOND COUNTY CLERK 09/17/ :10 PM INDEX NO /2014 NYSCEF DOC. NO. 72 RECEIVED NYSCEF: 09/17/2018

FILED: RICHMOND COUNTY CLERK 09/17/ :10 PM INDEX NO /2014 NYSCEF DOC. NO. 72 RECEIVED NYSCEF: 09/17/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND GREEN TREE SERVICING LLC Index No.: 135889/2014 NOTICE OF MOTION TO Plaintiff(s), CONFIRM REFEREE REPORT AND FOR A v. JUDGMENT OF MICKY J. LAWRENCE;