FILED: NEW YORK COUNTY CLERK 06/11/2014 INDEX NO /2013 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/11/2014

Similar documents
FILED: QUEENS COUNTY CLERK 02/07/ :50 PM INDEX NO /2016 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/07/2017

DEFINITIONS AND INSTRUCTIONS

FILED: NEW YORK COUNTY CLERK 12/15/ :09 AM INDEX NO /2017 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 12/15/2017

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION Landlord and Tenant Branch

January 24, Via Electronic Transmission

IN THE DISTRICT COURT, COUNTY OF CASS, NORTH DAKOTA

Defendants. X THE PEOPLE OF THE STATE OF NEW YORK. WE COMMAND YOU, That all business and excuses being laid aside, you appear at

FILED: NEW YORK COUNTY CLERK 04/11/2013 INDEX NO /2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 04/11/2013

FILED: NEW YORK COUNTY CLERK 07/13/ :56 PM INDEX NO /2015 NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 07/13/2018

Sample. Index No: [Insert] RJI No: [Insert] PLAINTIFF S NOTICE TO PRODUCE

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION Landlord And Tenant Branch

STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS ECONOMIC CRIMES SUBPOENA DUCES TECUM WITHOUT APPEARANCE POWDERZ, INC.

FILED: ORANGE COUNTY CLERK 03/17/ :37 PM

DIVISION OF ST. THOMAS/ ST. JOHN PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT WAHEED HAMED

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

FILED: NEW YORK COUNTY CLERK 02/29/ :38 PM INDEX NO /2014 NYSCEF DOC. NO. 580 RECEIVED NYSCEF: 03/01/2016

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

FILED: NEW YORK COUNTY CLERK 12/18/ :44 PM INDEX NO /2014 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 12/18/2015

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

December 12, Via facsimile transmission: Mitchell A. Leon President DesignWrite Inc. 175 Wall Street Princeton, NJ 08540

CAUSE NO. 18-C STREETS TO SHEETS ANIMAL IN THE COUNTY COURT AT LAW RESCUE Plaintiff, v. NO. 1

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

Case Doc Filed 11/22/17 Entered 11/22/17 17:35:58 Desc Exhibit 2 Page 1 of 6

In the Superior Court Allen County, Indiana Cause No.. 02D PL-499

FILED: KINGS COUNTY CLERK 07/28/ :10 PM INDEX NO /2015 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 07/28/2017. Exhibit UU

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

APPENDIX I SAMPLE INTERROGATORIES

For Preview Only - Please Do Not Copy

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Control N rnber: ' Item Number: 397. Addendurn StartPage: 0

Information or instructions: Combined discovery requests, admissions, production of documents and interrogatories

CAUSE NO ZACK MAXWELL, IN THE DISTRICT COURT

Case 3:16-cv SB Document 13-1 Filed 06/03/16 Page 1 of 5

ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS ECONOMIC CRIMES SUBPOENA DUCES TECUM C/O:

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION TRUSTEE S FIRST DISCOVERY REQUESTS TO SOLAR INTEGRATED TECHNOLOGIES GMHB

FILED: NEW YORK COUNTY CLERK 07/01/ :00 AM INDEX NO /2016 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 07/01/2017

Case 0:17-cv CMA Document 58 Entered on FLSD Docket 11/30/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

IN THE CIRCUIT COURT OF COUNTY, ARKANSAS DIVISION PLAINTIFF DEFENDANT S FIRST INTERROGATORIES TO PLAINTIFF

DISTRICT COURT CLARK COUNTY, NEVADA

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA. v. Case No.: 2012 CA

FILED: NEW YORK COUNTY CLERK 09/08/ :45 PM INDEX NO /2015 NYSCEF DOC. NO. 195 RECEIVED NYSCEF: 09/08/2017

Case 3:16-md VC Document Filed 01/09/19 Page 1 of 18 EXHIBIT A

Plaintiff, Defendant. PLEASE TAKE NOTICE that Plaintiff Acme Home & Garden, LLC demands answers

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ) ) ) ) ) ) ) ) ) ) ) ) Debtor.

Medicaid Fraud Control Unit Investigative Subpoena Duces Tecum

FILED: KINGS COUNTY CLERK 12/22/ :45 PM INDEX NO /2015 NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 12/22/2017

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA Charlotte Division

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND. v. * Case No. 17-cv-2006-EH * * * * * * * * * * * * *

Case: JGR Doc#:231 Filed:02/23/17 Entered:02/23/17 16:06:19 Page1 of 2 UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF COLORADO

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA PALM BEACH DIVISION CASE NO CIV-KAM

PLEASE TAKE NOTICE that pursuant to CPLR 3101, 3120, et. seq., Defendant

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA

FILED: NEW YORK COUNTY CLERK 05/07/2012 INDEX NO /2011 NYSCEF DOC. NO RECEIVED NYSCEF: 05/07/2012

ANTITRUST CIVIL INVESTIGATIVE DEMAND

19-CV-0222 CAUSE NO. Plaintiff, v. GALVESTON COUNTY, TEXAS

FILED: NEW YORK COUNTY CLERK 09/08/ :45 PM INDEX NO /2015 NYSCEF DOC. NO. 194 RECEIVED NYSCEF: 09/08/2017

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case 1:09-cv EJL Document 5 Filed 02/26/2009 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

Case KJC Doc 4929 Filed 12/14/17 Page 1 of 12 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE. x : : : : : : x.

U.S. Department of Justice

December 12, Via Electronic Transmission

FILED: NEW YORK COUNTY CLERK 04/12/ :50 AM INDEX NO /2016 NYSCEF DOC. NO. 143 RECEIVED NYSCEF: 04/12/2017. Exhibit A

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

THE STATE OF NEW HAMPSHIRE. Docket No CV Sanjeev Lath

Defendants. A motion by Wimbledon Financing Master Fund, Ltd., on its own behalf and as

FILED: NEW YORK COUNTY CLERK 09/04/ :54 PM INDEX NO /2013 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 09/04/2014

ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS ECONOMIC CRIME DIVISION FIRST INVESTIGATIVE SUBPOENA DUCES TECUM

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Medical Record Discovery Issues in the Motor Vehicle Case

Land Trust Agreement. Certification and Explanation. Schedule of Beneficial Interests

Case Doc 225 Filed 10/05/18 Entered 10/05/18 14:02:08 Desc Main Document Page 1 of 9

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

FILED: KINGS COUNTY CLERK 06/08/ :39 PM INDEX NO /2017 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 06/08/2017

COUNTY OF SANTA CLARA

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case 1:99-cv ECH Document 295 Filed 03/19/2008 Page 1 of 26 IN THE UNITED STATES COURT OF FEDERAL CLAIMS

Case 3:16-cv Document 1-1 Filed 02/29/16 Page 1 of 68 SUBPOENA UNITED STATES OF AMERICA NATIONAL LABOR RELATIONS BOARD

YOU ARE HEREBY COMMANDED to produce to Eric Wm. Hendon, Esq., Assistant Attorney

ASSOCIATION OF AMERICAN ) PHYSICIANS AND SURGEONS, INC. ) etc., et al., ) ) Plaintiffs ) CIVIL ACTION NO

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Miami Division CASE NO CIV-SIMONTON

INDEPENDENT AFFILIATE AGREEMENT

TRI-CITY HEALTHCARE DISTRICT BOARD OF DIRECTORS POLICY. As used in this Policy, the following terms shall have the following meanings:

~/

AGE FOTOSTOCK SPAIN, S.L. NON-EXCLUSIVE PHOTOGRAPHER AGREEMENT FOR RIGHTS MANAGED LICENSING

PROMOTION OF ACCESS TO INFORMATION ACT SECTION 51 MANUAL FOR MASSDISCOUNTERS T/A GAME AND DION WIRED

Don t Get Burned: Proper Implementation of the Litigation Hold Process is Your Best SPF (Spoliation Protection Factor)

Remote Support Terms of Service Agreement Version 1.0 / Revised March 29, 2013

2014/098567/07 SEED ANALYTICS (PROPRIETARY) LIMITED MANUAL. in terms of. Section 51 of. The Promotion of Access to Information Act.

ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS ECONOMIC CRIMES SUBPOENA DUCES TECUM

BILL, Explanatory. (These notes form no part of the Bill but are intended only to indicate its general purport)

CANADIAN SOCIETY OF CORPORATE SECRETARIES

ORDINANCE NO WHEREAS, Manatee County residents and businesses have suffered economic losses recently; and,

Case 2:10-md CJB-SS Document 2 Filed 08/10/10 Page 1 of 19 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

Case: 2:16-cv WOB-JGW Doc #: 112 Filed: 10/27/16 Page: 1 of 7 - Page ID#: 1626

MISSOURI SUNSHINE LAW

1 SB By Senators Orr and Holley. 4 RFD: Governmental Affairs. 5 First Read: 13-FEB-18. Page 0

ACCESS TO PORT PUBLIC RECORDS

COMMON TERMS AND CONDITIONS FOR CASH MANAGEMENT PRODUCTS & SERVICES

Transcription:

FILED: NEW YORK COUNTY CLERK 06/11/2014 INDEX NO. 650582/2013 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 06/11/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: PART 61 ---------------------------------------------------------------x CANDICE FEINBERG LALICATA. Index No. 650582/2013 Plaintiff, PLAINTIFF S FIRST SET OF DOCUMENT - against - REQUESTS PROPOUNDED ON DEFENDANT DIANA STEVEN LALICATA, DIANA FERNANDEZ, FERNANDEZ JAMES HART, BRIAN MARTINEZ and JOHN DOE 1, Defendants. ---------------------------------------------------------------x PLEASE TAKE NOTICE that, pursuant to Article 31 of the Civil Practice and Rules and in accordance with the definitions and instructions set forth below, Plaintiff Candice Feinberg Lalicata, by and through her attorneys, Law Offices of Adam D. Perlmutter, P.C., propounds the following First Set of Document Requests (the Document Requests ) on Defendant Diana Fernandez to be complied with in full by serving the requested documents on Plaintiff by April 12, 2014. INSTRUCTIONS A. Documents shall be produced in their original state, i.e., in their original file folders in the exact order as found, without removal or rearrangement of anything contained therein. B. Each demand herein is continuing and requires prompt supplementary responses if further responsive documents are subsequently obtained or discovered by the parties or otherwise come into their possession, custody or control.

C. If you claim that any responsive document is privileged or for any other reason not discoverable, the response hereto shall state: (a) the type of document (e.g., memorandum, report, chart, etc.); (b) the date of the document; (c) title of the document; (d) a description of the subject matter of the document; (e) the name(s) and address(es) of the person(s) who prepared the document, the person(s) to whom it was directed or circulated and the person(s) now in possession of the document; and (f) the nature of and factual and legal basis for the privilege claimed or other ground for non-production. D. If any document called for by this document request is not within the party's possession, custody or control, such party shall so state in writing. E. Unless otherwise specified herein, the relevant time period for each request shall be from January 1, 2012 through the present date. DEFINITIONS A. The word "document" is used in the broadest possible sense to mean any printed, written, taped, recorded, graphic, computerized printout, electronically stored or other tangible matter, from whatever source, however produced or reproduced or capable of being reproduced, whether in draft or otherwise, whether sent or received or neither, including, but not limited to, the original and all non-identical copies of any and all writings, correspondence, letters, telegrams, cables, contracts, proposals, agreements, minutes, notes, memoranda, analyses, projections, work papers, books, records, reports, diaries, statements, questionnaires, charts, sketches, diagrams, drawings, photographs, cassettes, disks, tape recordings, financial statements, and all other information or data, records or compilations, including all underlying supporting or preparatory material. "Document" includes but is not limited to documents kept by individuals in their desks, at home or elsewhere. 2

B. "Communication" means any act or instance whereby messages, fax, data, ideas, thoughts, beliefs, feelings, opinions or any other information is transmitted orally, visually, in writing, electronically, by facsimile or by any other means or media. C. The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the request all responses that might otherwise be construed to be outside its scope. D. The use of the singular form of any word includes the plural, and vice versa. E. "Person" means any natural person or any business, legal or governmental entity or association. F. "Concerning" means relating to, referring to, describing, evidencing or constituting. G. In addition, as used herein, the following terms shall have the following meanings: i. Fernandez shall mean defendant Diana Fernandez, including but not limited to her, her successors, subsidiaries, divisions, affiliates, officers, directors, attorneys, employees, agents, representatives, accountants, advisors, and all other persons acting or purporting to act on her behalf. ii. Steven Lalicata shall mean defendant Steven Lalicata, including but not limited to him, his estate, his successors, subsidiaries, divisions, affiliates, officers, directors, attorneys, employees, agents, representatives, accountants, advisors, and all other persons acting or purporting to act on his behalf. iii. Brian Martinez shall mean defendant Brian Martinez, including but not limited to him, his estate, his successors, subsidiaries, divisions, affiliates, officers, directors, attorneys, 3

employees, agents, representatives, accountants, advisors, and all other persons acting or purporting to act on his behalf. iv. James Hart shall mean defendant James Hart, including but not limited to him, his estate, his successors, subsidiaries, divisions, affiliates, officers, directors, attorneys, employees, agents, representatives, accountants, advisors, and all other persons acting or purporting to act on his behalf. H. Unless and except to the extent otherwise defined herein, all defined terms in the Complaint shall have the same meaning herein. DOCUMENT REQUESTS Document Request No. 1 Any and all documents, including but not limited to correspondence, facsimiles, phone calls, emails, and text messages, between you and/or any agent thereof, and Steven Lalicata, Brian Martinez, James Hart and/or Candice Feinberg Lalicata. Document Request No. 2 Any and all documents reflecting or pertaining to any payments and/or conveyances of any value whatsoever, including but not limited to correspondence, facsimiles, phone calls, emails, accounting records, checks, deposits, wire transfers, transfers, mortgages, satisfaction of mortgages and any other financial transactions between you and/or any agent thereof, and Steven Lalicata, Brian Martinez, James Hart and/or Candice Feinberg Lalicata. 4

Document Request No. 3 Any and all documents related to electronic mail addresses registered to and/or opened by Fernandez and/or utilized by the same, whether or not she registered or opened the electronic mail account corresponding to that address. Document Request No. 4 Any and all documents related to credit card accounts registered to and/or opened by Fernandez and/or utilized by the same, whether or not she registered or opened the credit card account, including but not limited to account statements, records of paymennt and credit card agreement. Document Request No. 5 Any and all documents, including statements, debit advices, credit advices, and correspondence related any back accounts, including but not limited to checking, savings, SEP, IRA, certificate or deposit, or lines of credit, registered to and/or opened by Fernandez and/or utilized by the same, whether or not he registered or opened the corresponding account. Document Request No. 6 Any and all documents related to any cellular telephone numbers registered to and/or opened by Fernandez and/or utilized by the same, whether or not she registered or opened the cellular telephone number account corresponding to that cellular telephone number, including but not limited to monthly statements, user information, and subscriber information. Document Request No. 7 Any and all passports by nationality and identification numbers registered to or possessed by Fernandez. 5

Document Request No. 8 Any and all documents reflecting any air travel by Fernandez including but not limited to tickets, itineraries, emails and corespondence from any airlines. Document Request No. 9 Any and all documents related to any hotel stays by Fernandez, including but not limitmed to room bills, invoices, reservations, and credit card receipts for any hotel, motel, suites, or other temporary rental lodging provider utilized by Fernandez, whether or not she registered or made the reservation for the lodging. Document Request No. 10 Copies of any and all federal, local and state tax returns filed by Fernandez with federal, state or municipal taxing authorities, including by not limited to the Internal Revenue Service, the New York State Department of Taxation and Finance, and the New York City Department of Finance. Document Request No. 11 Any and all documents related any motor vehicles owned, registered, purchased, traded and/or transfer to or from Fernandez whether titled, registered or insured in New York State or elsewhere. Document Request No. 12 Any and all documents related to any purchases in excess of one thousand dollars made by Fernandez for any and all goods or services whatsoever. Document Request No. 13 And and all documents realted to any gifts in any form whatsoever, whether cash, currency, goods or services, given to or received by Fernandez. 6

Document Request No. 14 Any and all documents related to any personal, home, laptop and/or business computers utilized and/or owned by Fernandez including any personal digital assistants, smartphones, ipads or other digital tablets or devices of any form whatsoever. Documents Request No. 15 Any and all documents realted to any digital cloud storage services, such as DropBox, Google Drive, Google Documents, and SpiderOak, utilized by Fernandez to store any and all personal information, content and/or data, including but not limited electronic mails, documents, photographs, and video films. Document Request No. 16 Any and all documents related to employment by Fernandez. Document Request No. 17 Any and all dcouments related to social networking sites utilized by Fernandez including but not limited services such as Facebook, MySpace, Twitter, Bebo, Tumblr, Instagram and LinkedIn. Document Request No. 18 Any and all documents related to residences utilized by Fernandez whether owned outright, subject to mortgage(s), rented, leased, holdover, shared, sublet, or occupied in any way or in any form of tenancy in law or in equity whatsoever, including but not limted any mortgage statements, closing statements, leases or payments regarding the same. 7