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COUNTY OF QUEENS
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Index No.
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COUNSELOR(S):
PLEASE TAKE NOTICE THAT ______________ ASSOCIATES, P.C. attorneys for the
defendant, demands that a verified bill of particulars be served upon them with the
following information within thirty (30) days:
1.
2.
Date of incident.
3.
Time of incident.
4.
5.
Describe the exact location of the premises in which it is claimed the subject
incident occurred, with sufficient detail as to allow the defendant to identify the particular
area and distinguish it from other areas of the premises. Plaintiff may narratively
describe the area in terms of compass points, size, shape, proximity to other fixed objects,
exits or structural landmarks, or in any sufficiently detailed description which will permit
identification.
6.
Is it claimed that the alleged incident was occasioned by virtue of slippery and/or
Is it claimed that there were any debris or foreign substance for foreign object(s)
at the location which caused or contributed to the happening of the alleged incident?
8.
If the answer to the above question is in the affirmative, describe each item of
debris and substance and foreign object(s) which plaintiff will claim caused or
contributed to the happening of the alleged incident.
9.
Set forth each and every act or omission of negligence on the part of the
defendant which plaintiff will claim caused or contributed to the alleged occurrence.
10.
11.
time of inception, to date and time of constructive notice will be claimed to be given
defendant(s).
12.
13.
14.
15.
16.
If confined to a hospital:
(a) length of time confined, giving dates;
(b) names and address of hospital.
17.
18.
A verified statement setting forth the residence and post office address of the
plaintiff.
20.
If any statutes, laws or rules are claimed to have been violated by the defendant,
set forth the title of any such law and the section or sections and subsections claimed to
have been violated.
21.
Set forth all statements made by the defendant in writing with respect to the
occurrence.
22.
State whether or not plaintiff(s) have been reimbursed for the claims of economic
reimbursement received and the name of the person, firm or organization who made such
reimbursement;
(b) If such reimbursement was made by an insurance company, state the number
of the policy under which it was paid;
(c) state whether or not plaintiff(s) has made a claim for reimbursement for
economic loss to any collateral source and which has not as yet been paid;
(d) if the answer to 24 (c) is in the affirmative, state the name of the person, firm
or organization to whom such claim was presented, the date of presentation, and the
amount claimed.
24.
Set forth whether plaintiff is claiming a reduced life expectancy, and if so, the
extent of same.
25.
Set forth whether the plaintiff(s) is claiming a reduced work expectancy, and if so
Set forth the total amount claimed as special damages for the following, and in
each instance set forth the date(s) that care is alleged to have been rendered and the
name(s) and address(es) of the provider(s):
(a) Physicians services;
Set forth each occurrence prior to the occurrence alleged in the complaint, in
which the plaintiff(s) sustained an injury to the bodily portion alleged to have been
injured during the occurrence alleged in the complaint, whether or not medical care was
obtained. If medical care was obtained, set forth the name(s) and address(es) of each and
every health care facility / physician / therapist who treated or examined the plaintiff(s)
for such prior injury.
28.
State whether the occurrence alleged in the complaint was reported to the
of plaintiffs slip, trip or fall on or upon a stoop. Walkway, step(s), stairway, remap,
hallway, landing, room as a result of debris, liquid or any substance then, set forth where
applicable as follows:
(a) The location stating without limitation, between what floors situated, counting
the ground floor as the first floor.
(b) The particular step on which the plaintiff(s) slipped, tripped or fell, counting
form the bottom or top stair;
(c) The location of the hallway stating without limitation, on what floor situated,
counting the ground floor as the first floor;
(d) The location in the hallway where the occurrence, alleged in the complaint
occurred;
(e) The location of the ramp, walkway, landing, room, including the location of
any alleged debris, liquid or substance;
(f) A description of the ramp, landing, room, debris, liquid or substance;
(g) The manner in which the alleged slip, trip or fall in, or upon a stoop, a step(s),
walkway, stairway, ramp, hallway, landing, room, debris, liquid or any substance caused
or contributed to the injuries alleged in the complaint.
30.
If the complaint alleges loss of services, then with regarding to any spouse who is
a party to this action, set forth the plaintiff(s) relationship now and at the time of the
occurrence alleged in the complaint. If plaintiff(s) was /were married at the time of the
occurrence and /or up to the present, state the date(s) and place(s) of marriage.
35.
36.
37.
(e) A description of the elevator, giving its size, height, floor material makeup,
type of door action (whether the same was a sliding door, push door or otherwise);
(f) The manner which the elevator was allegedly improperly maintained, if
alleged:
(g) The manner in which the elevator was allegedly improperly repaired, if
alleged:
(h) The manner in which the elevator was improperly serviced, if alleged:
(i) The manner in which the elevator closed upon the plaintiff(s) if alleged:
(j) The manner in which the occurrence referable to the elevator and/or elevator
shaft caused or contributed to the injuries alleged in the complaint.
39.
State whether the plaintiff(s) claim they sustained any property damage or
Jamaica, N.Y.
_____________________
By:
_______________ Associates, P.C.
123 main st
TO: