Preview
FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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INTEGRATED PROJECT DELIVERY PARTNERS, INC., Index No.: 160102/2016
Plaintiff,
PLAINTIFF’S .FIRST
-against- REQUEST TO DEFENDANTS
FOR PRODUCTION
SUSAN L. SCHUMAN FAMILY TRUST, ILENE OF DOCUMENTS
OSHEROW, SUSAN SCHUMAN, and “JOHN DOE 1”
through “JOHN DOE 10,” said parties being lienors who
have yet to perfect their liens and being fictitious and
unknown to Plaintiff,
Defendants.
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TO THE ABOVE-NAMED DEFENDANTS:
PLEASE TAKE NOTICE that, CPLR 3120 and 3101, et seq., which is incorporated
herein by reference, plaintiff, INTEGRATED PROJECT DELIVERY PARTNERS, INC.
(“IPDP”), requests that the defendants SUSAN L. SCHUMAN FAMILY TRUST, ILENE
OSHEROW, SUSAN SCHUMAN (collectively, the “defendants”) produce for inspection and
copying, at the law offices of Wilson & Chan, LLP, 733 Third Avenue, 15th Floor, New York,
New York 10017, within thirty (30) days after service of this notice, all documents which are
responsive to the requests contained in the numbered paragraphs below.
PLEASE TAKE FURTHER NOTICE that if any of the records requested herein are
electronically filed, stored or recorded, plaintiff requests production of the program and data
bases used to effect the storage of said records or files.
PLEASE TAKE FURTHER NOTICE that plaintiff considers this a continuing demand
and hereby demands that you supplement your responses to these demands as additional
documents and/or information becomes available.
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PLEASE TAKE FURTHER NOTICE, documents not produced because of any claim of
privilege or otherwise must be listed by date, number of pages, document type, author, addresses,
recipients, custodian, subject matter and basis for privilege or other reason for non-production
(along with any identifying information such as Bates numbers).
DEFINITIONS AND INSTRUCTIONS
1. As used herein, the term “documents” means all writings of any kind, including the
originals and all non-identical copies, whether different from the originals by reason of any
notation made on such copies or otherwise, including without limitation correspondence,
memoranda, notes, diaries, statistics, letters, telegrams, minutes, contracts, reports, studies,
checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, certificates,
drawings, plans, interoffice and intraoffice communications, or offers, notations in any form
made of conversations, telephone calls, meetings or other communications, bulletins, printed
matter (including newspapers, magazines and other publications, and articles and clippings
therefrom), press releases, computer printouts, teletypes, telecopies, electronic mail, invoices,
ledgers, worksheets (and all drafts, alterations, modifications, changes and amendments), graphic
or aural records or representations of any kind (including without limitation photographs, charts,
graphs, and microfiche, microfilm, videotape, or film recordings) and electronic, mechanical or
electrical records or representations of any kind (including without limitation computer files,
tapes, cassettes, discs, recordings, or transcriptions thereof).
2. The term “all documents” means every document, as defined in paragraph 1, above,
which can be located, discovered or obtained by reasonably diligent efforts, including without
limitation all documents possessed by: (a) You or Your counsel; or (b) any other person or entity
from whom You can obtain such documents by request or which You have a legal right to bring
within Your possession by demand.
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3. If any request for document is deemed to call for the production of privileged or work
product materials and such privilege or work product is asserted, provide the following
information:
(a) the reason for withholding the document;
(b) a statement of the basis for the claim of privilege, work product or other ground of
nondisclosure; and
(c) a brief description of the document, including:
(i) the date of the document;
(ii) number of pages, attachments, and appendices;
(iii) the name of its author, authors or preparers and an identification by
employment and title of each such person;
(iv) the name of each person who was sent, shown or blind or carbon copied
the document, or has had access to or custody of the document, together
with an identification of each such person;
(v) the present custodian; and
(vi) the subject matter of the document, and in the case of any document
relating or referring to a meeting or conversation, identification of such
meeting or conversation.
4. If any document requested herein was at one time in existence, but has been lost,
discarded or destroyed, identify each such document and provide the following information:
(a) The date or approximate date it was lost, discarded, or destroyed;
(b) the circumstances and manner in which it was lost, discarded or destroyed;
(c) the reason or reasons for disposing of the document (if discarded or destroyed);
(d) the identity of all persons authorizing or having knowledge of the circumstances
surrounding the disposal of the document;
(e) the identity of the person(s) who lost, discarded or destroyed the document; and
(f) the identity of all persons having knowledge of the contents thereof.
5. “Person” or “persons” means all natural persons, corporations, partnerships or other
business associations, and all other legal entities, including all members, offices, employees,
agents, representatives, attorneys, successors, predecessors, assigns, divisions, affiliates, and
subsidiaries.
6. Each request for the production of a document shall be deemed to call for the production
of the original document or documents, to the extent that they are in or subject to, directly or
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indirectly, Your control. In addition, each request should be considered as including all copies
and, to the extent applicable, preliminary drafts, of documents which, as to content, differ in any
respect from the original or final draft or from each other (e.g., by reason of handwritten notes or
comments having been added to one copy of a document but not on the original or other copies
thereto).
7. The term “communications” is used here in the broad sense and includes, but is not
limited to, any and all conversations, meetings, discussions and other occasion for verbal
exchange, whether in person or by telephone, as well as letters, memoranda, telegrams, cables,
and other writings or documents.
8. The term “relating to” (including any variant thereof) includes referring to, alluding, to,
responding to, concerning, in connection with, commenting on or in respect of, analyzing,
touching upon, and constituting the being, and is not limited to contemporaneous events, actions,
communications, or documents.
9. The use of the singular shall include the plural and the use of the plural shall include the
singular.
10. The term “third-party” as used herein refers to an individual or entity that is not a party to
this action.
11. As used herein, “IPDP” means INTEGRATED PROJECT DELIVERY PARTNERS,
INC., including any of its partners, members, employees, agents, representatives, attorneys, and
other persons acting (or who acted) or purporting to act (or who purported to act) on its behalf.
12. As used herein, the “Schuman Trust” means the SUSAN L. SCHUMAN FAMILY
TRUST and any of its partners, members, employees, agents, representatives, attorneys, and
other persons acting (or who acted) or purporting to act (or who purported to act) on its behalf.
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13. As used herein, “Osherow” means ILENE OSHEROW and any of its partners, members,
employees, agents, representatives, attorneys, and other persons acting (or who acted) or
purporting to act (or who purported to act) on its behalf.
14. As used herein, “S. Schuman” means SUSAN SCHUMAN and any of its partners,
members, employees, agents, representatives, attorneys, and other persons acting (or who acted)
or purporting to act (or who purported to act) on its behalf.
15. As used herein, the “Defendants” means collectively, SUSAN L. SCHUMAN FAMILY
TRUST, ILENE OSHEROW, SUSAN SCHUMAN and any of its partners, members,
employees, agents, representatives, attorneys, and other persons acting (or who acted) or
purporting to act (or who purported to act) on its behalf.
16. As used herein, the “Project” means the construction project located at 161 Hudson
Street, Apt. 4B, City of New York, County of New York, State of New York and identified by
the Tax Maps as New York County Block No. 215, Lot No. 1212.
17. As used herein, “You” or “Your” means the party to which these demands are directed.
18. As used herein, “Complaint” means the complaint filed in this action.
DOCUMENT DEMAND
1. All documents relating to any communications between IPDP and the Defendants
relating to the Project and/or the subject matter of this litigation.
2. All documents relating to any communications between the Defendants and any third-
party that pertain in any way to the Project and/or the subject matter of this litigation.
3. Any agreement(s), including any drafts thereof, between IPDP and the Defendants in
connection with the Project, including any addenda, riders, specifications, plans, modifications or
drawings thereto or the work to be performed thereunder.
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4. Any agreement(s), including any drafts thereof, between the Defendants and any third-
party in connection with the Project, including any addenda, riders, specifications, plans,
modifications or drawings thereto or the work to be performed thereunder.
5. All requisitions, invoices or other requests for payment submitted by IPDP to the
Defendants which relate to the Project.
6. All change orders or other modifications submitted by IPDP in connection with the
Project, whether or not approved and/or signed by the Defendants.
7. All documents relating to any request for payment submitted by IPDP to the Defendants
in connection with the Project.
8. All documents relating to payments IPDP received in connection with the Project.
9. All documents relating to any calculation of damages the Defendants seek in its first
counterclaim that is the subject of this litigation.
10. All documents relating to any calculation of damages the Defendants seek in its second
counterclaim that is the subject of this litigation.
11. All documents relating to any calculation of damages the Defendants seek in its third
counterclaim that is the subject of this litigation.
12. All daily reports prepared or maintained by the Defendants in connection with the
Project.
13. All payment records or reports prepared or maintained by the Defendants in connection
with the Project.
14. All documents relating to the first day that IPDP supplied labor and/or material in
connection with the Project.
15. All documents relating to the last day that IPDP supplied labor and/or material in
connection with the Project.
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16. All documents relating to any material or equipment supplied by IPDP in connection with
the Project, including, but not limited to any agreements, contracts, purchase orders, change
orders, delivery tickets, daily reports, checks, vouchers, journals, ledgers, logs, applications,
certifications, certificates, memoranda and correspondence.
17. All documents reflecting payments made by the Defendants to IPDP for labor and/or
material IPDP provided in connection with the Project.
18. All documents constituting or relating to any written oral report prepared by any person
who is expected to testify as an expert witness on the defendants’ behalf.
19. All documents constituting or relating to the qualifications or Curriculum Vitae for each
person who is expected to testify as an expert witness on the defendants’ behalf in this action.
20. All documents relating to plaintiff’s performance of work on the Project.
21. All documents relating to any bulletins or modifications to the plans issued for the
Project.
22. All documents relating to any inspection, observations, remediation, replacement or
repair of the work at the Project.
23. All releases or settlements entered into by the Defendants with any person or entity
concerning the Project and/or this Litigation.
24. All releases or settlements entered into by plaintiff with any person or entity concerning
the Project and/or this Litigation.
25. All documents which pertain to or relate to statements made by any party to this litigation
concerning the Project.
26. All documents which pertain to any notice(s) pertaining to plaintiff’s alleged breach of an
agreement as referenced in the defendants’ first counterclaim.
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27. All meeting agendas and minutes of meetings held between plaintiff and any other person
relating to the Project.
28. All meeting agendas and minutes of meetings held between the Defendants and any other
person relating to the Project.
29. Other than documents produced in response to a previous request, all documents upon
which the defendants may rely in support of any allegations or contentions in this matter.
30. Other than documents produced in response to a previous request, all documents which
refer or relate in any way to the Project or the subject matter of this litigation.
31. All documents which the defendants intend to rely upon at the time of trial, which haven
not heretofore been requested.
The plaintiff reserves its rights to demand additional document upon its receipt and
review of the above demanded documents from the Defendants.
Dated: New York, New York
February 14, 2017
WILSON & CHAN, LLP
By:
Henry C. Chan, Esq.
Attorneys for Plaintiff
INTEGRATED PROJECT DELIVERY
PARTNERS, INC.
733 Third Avenue, 15th Floor
New York, New York 10017
Tel: (646) 790-5848
Fax: (646) 417-7879
hchan@wilsonchanlaw.com
Our File No.: 00450.00002
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To:
Attn: Peter Moulinos, Esq.
MOULINOS & ASSOCIATES LLC
Attorneys for Defendants
150 East 58th Street, 25th Floor
New York, New York 10155
Tel: (212) 832-5981
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FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------- x INTEGRATED PROJECT DELIVERY PARTNERS, INC., Index No.: 160102/2016 Plaintiff, PLAINTIFF’S .FIRST -against- REQUEST TO DEFENDANTS FOR PRODUCTION SUSAN L. SCHUMAN FAMILY TRUST, ILENE OF DOCUMENTS OSHEROW, SUSAN SCHUMAN, and “JOHN DOE 1” through “JOHN DOE 10,” said parties being lienors who have yet to perfect their liens and being fictitious and unknown to Plaintiff, Defendants. ---------------------------------------- x TO THE ABOVE-NAMED DEFENDANTS: PLEASE TAKE NOTICE that, CPLR 3120 and 3101, et seq., which is incorporated herein by reference, plaintiff, INTEGRATED PROJECT DELIVERY PARTNERS, INC. (“IPDP”), requests that the defendants SUSAN L. SCHUMAN FAMILY TRUST, ILENE OSHEROW, SUSAN SCHUMAN (collectively, the “defendants”) produce for inspection and copying, at the law offices of Wilson & Chan, LLP, 733 Third Avenue, 15th Floor, New York, New York 10017, within thirty (30) days after service of this notice, all documents which are responsive to the requests contained in the numbered paragraphs below. PLEASE TAKE FURTHER NOTICE that if any of the records requested herein are electronically filed, stored or recorded, plaintiff requests production of the program and data bases used to effect the storage of said records or files. PLEASE TAKE FURTHER NOTICE that plaintiff considers this a continuing demand and hereby demands that you supplement your responses to these demands as additional documents and/or information becomes available. 1 1 of 9 FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017 PLEASE TAKE FURTHER NOTICE, documents not produced because of any claim of privilege or otherwise must be listed by date, number of pages, document type, author, addresses, recipients, custodian, subject matter and basis for privilege or other reason for non-production (along with any identifying information such as Bates numbers). DEFINITIONS AND INSTRUCTIONS 1. As used herein, the term “documents” means all writings of any kind, including the originals and all non-identical copies, whether different from the originals by reason of any notation made on such copies or otherwise, including without limitation correspondence, memoranda, notes, diaries, statistics, letters, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, certificates, drawings, plans, interoffice and intraoffice communications, or offers, notations in any form made of conversations, telephone calls, meetings or other communications, bulletins, printed matter (including newspapers, magazines and other publications, and articles and clippings therefrom), press releases, computer printouts, teletypes, telecopies, electronic mail, invoices, ledgers, worksheets (and all drafts, alterations, modifications, changes and amendments), graphic or aural records or representations of any kind (including without limitation photographs, charts, graphs, and microfiche, microfilm, videotape, or film recordings) and electronic, mechanical or electrical records or representations of any kind (including without limitation computer files, tapes, cassettes, discs, recordings, or transcriptions thereof). 2. The term “all documents” means every document, as defined in paragraph 1, above, which can be located, discovered or obtained by reasonably diligent efforts, including without limitation all documents possessed by: (a) You or Your counsel; or (b) any other person or entity from whom You can obtain such documents by request or which You have a legal right to bring within Your possession by demand. 2 2 of 9 FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017 3. If any request for document is deemed to call for the production of privileged or work product materials and such privilege or work product is asserted, provide the following information: (a) the reason for withholding the document; (b) a statement of the basis for the claim of privilege, work product or other ground of nondisclosure; and (c) a brief description of the document, including: (i) the date of the document; (ii) number of pages, attachments, and appendices; (iii) the name of its author, authors or preparers and an identification by employment and title of each such person; (iv) the name of each person who was sent, shown or blind or carbon copied the document, or has had access to or custody of the document, together with an identification of each such person; (v) the present custodian; and (vi) the subject matter of the document, and in the case of any document relating or referring to a meeting or conversation, identification of such meeting or conversation. 4. If any document requested herein was at one time in existence, but has been lost, discarded or destroyed, identify each such document and provide the following information: (a) The date or approximate date it was lost, discarded, or destroyed; (b) the circumstances and manner in which it was lost, discarded or destroyed; (c) the reason or reasons for disposing of the document (if discarded or destroyed); (d) the identity of all persons authorizing or having knowledge of the circumstances surrounding the disposal of the document; (e) the identity of the person(s) who lost, discarded or destroyed the document; and (f) the identity of all persons having knowledge of the contents thereof. 5. “Person” or “persons” means all natural persons, corporations, partnerships or other business associations, and all other legal entities, including all members, offices, employees, agents, representatives, attorneys, successors, predecessors, assigns, divisions, affiliates, and subsidiaries. 6. Each request for the production of a document shall be deemed to call for the production of the original document or documents, to the extent that they are in or subject to, directly or 3 3 of 9 FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017 indirectly, Your control. In addition, each request should be considered as including all copies and, to the extent applicable, preliminary drafts, of documents which, as to content, differ in any respect from the original or final draft or from each other (e.g., by reason of handwritten notes or comments having been added to one copy of a document but not on the original or other copies thereto). 7. The term “communications” is used here in the broad sense and includes, but is not limited to, any and all conversations, meetings, discussions and other occasion for verbal exchange, whether in person or by telephone, as well as letters, memoranda, telegrams, cables, and other writings or documents. 8. The term “relating to” (including any variant thereof) includes referring to, alluding, to, responding to, concerning, in connection with, commenting on or in respect of, analyzing, touching upon, and constituting the being, and is not limited to contemporaneous events, actions, communications, or documents. 9. The use of the singular shall include the plural and the use of the plural shall include the singular. 10. The term “third-party” as used herein refers to an individual or entity that is not a party to this action. 11. As used herein, “IPDP” means INTEGRATED PROJECT DELIVERY PARTNERS, INC., including any of its partners, members, employees, agents, representatives, attorneys, and other persons acting (or who acted) or purporting to act (or who purported to act) on its behalf. 12. As used herein, the “Schuman Trust” means the SUSAN L. SCHUMAN FAMILY TRUST and any of its partners, members, employees, agents, representatives, attorneys, and other persons acting (or who acted) or purporting to act (or who purported to act) on its behalf. 4 4 of 9 FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017 13. As used herein, “Osherow” means ILENE OSHEROW and any of its partners, members, employees, agents, representatives, attorneys, and other persons acting (or who acted) or purporting to act (or who purported to act) on its behalf. 14. As used herein, “S. Schuman” means SUSAN SCHUMAN and any of its partners, members, employees, agents, representatives, attorneys, and other persons acting (or who acted) or purporting to act (or who purported to act) on its behalf. 15. As used herein, the “Defendants” means collectively, SUSAN L. SCHUMAN FAMILY TRUST, ILENE OSHEROW, SUSAN SCHUMAN and any of its partners, members, employees, agents, representatives, attorneys, and other persons acting (or who acted) or purporting to act (or who purported to act) on its behalf. 16. As used herein, the “Project” means the construction project located at 161 Hudson Street, Apt. 4B, City of New York, County of New York, State of New York and identified by the Tax Maps as New York County Block No. 215, Lot No. 1212. 17. As used herein, “You” or “Your” means the party to which these demands are directed. 18. As used herein, “Complaint” means the complaint filed in this action. DOCUMENT DEMAND 1. All documents relating to any communications between IPDP and the Defendants relating to the Project and/or the subject matter of this litigation. 2. All documents relating to any communications between the Defendants and any third- party that pertain in any way to the Project and/or the subject matter of this litigation. 3. Any agreement(s), including any drafts thereof, between IPDP and the Defendants in connection with the Project, including any addenda, riders, specifications, plans, modifications or drawings thereto or the work to be performed thereunder. 5 5 of 9 FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017 4. Any agreement(s), including any drafts thereof, between the Defendants and any third- party in connection with the Project, including any addenda, riders, specifications, plans, modifications or drawings thereto or the work to be performed thereunder. 5. All requisitions, invoices or other requests for payment submitted by IPDP to the Defendants which relate to the Project. 6. All change orders or other modifications submitted by IPDP in connection with the Project, whether or not approved and/or signed by the Defendants. 7. All documents relating to any request for payment submitted by IPDP to the Defendants in connection with the Project. 8. All documents relating to payments IPDP received in connection with the Project. 9. All documents relating to any calculation of damages the Defendants seek in its first counterclaim that is the subject of this litigation. 10. All documents relating to any calculation of damages the Defendants seek in its second counterclaim that is the subject of this litigation. 11. All documents relating to any calculation of damages the Defendants seek in its third counterclaim that is the subject of this litigation. 12. All daily reports prepared or maintained by the Defendants in connection with the Project. 13. All payment records or reports prepared or maintained by the Defendants in connection with the Project. 14. All documents relating to the first day that IPDP supplied labor and/or material in connection with the Project. 15. All documents relating to the last day that IPDP supplied labor and/or material in connection with the Project. 6 6 of 9 FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017 16. All documents relating to any material or equipment supplied by IPDP in connection with the Project, including, but not limited to any agreements, contracts, purchase orders, change orders, delivery tickets, daily reports, checks, vouchers, journals, ledgers, logs, applications, certifications, certificates, memoranda and correspondence. 17. All documents reflecting payments made by the Defendants to IPDP for labor and/or material IPDP provided in connection with the Project. 18. All documents constituting or relating to any written oral report prepared by any person who is expected to testify as an expert witness on the defendants’ behalf. 19. All documents constituting or relating to the qualifications or Curriculum Vitae for each person who is expected to testify as an expert witness on the defendants’ behalf in this action. 20. All documents relating to plaintiff’s performance of work on the Project. 21. All documents relating to any bulletins or modifications to the plans issued for the Project. 22. All documents relating to any inspection, observations, remediation, replacement or repair of the work at the Project. 23. All releases or settlements entered into by the Defendants with any person or entity concerning the Project and/or this Litigation. 24. All releases or settlements entered into by plaintiff with any person or entity concerning the Project and/or this Litigation. 25. All documents which pertain to or relate to statements made by any party to this litigation concerning the Project. 26. All documents which pertain to any notice(s) pertaining to plaintiff’s alleged breach of an agreement as referenced in the defendants’ first counterclaim. 7 7 of 9 FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017 27. All meeting agendas and minutes of meetings held between plaintiff and any other person relating to the Project. 28. All meeting agendas and minutes of meetings held between the Defendants and any other person relating to the Project. 29. Other than documents produced in response to a previous request, all documents upon which the defendants may rely in support of any allegations or contentions in this matter. 30. Other than documents produced in response to a previous request, all documents which refer or relate in any way to the Project or the subject matter of this litigation. 31. All documents which the defendants intend to rely upon at the time of trial, which haven not heretofore been requested. The plaintiff reserves its rights to demand additional document upon its receipt and review of the above demanded documents from the Defendants. Dated: New York, New York February 14, 2017 WILSON & CHAN, LLP By: Henry C. Chan, Esq. Attorneys for Plaintiff INTEGRATED PROJECT DELIVERY PARTNERS, INC. 733 Third Avenue, 15th Floor New York, New York 10017 Tel: (646) 790-5848 Fax: (646) 417-7879 hchan@wilsonchanlaw.com Our File No.: 00450.00002 8 8 of 9 FILED: NEW YORK COUNTY CLERK 02/14/2017 04:55 PM INDEX NO. 160102/2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 02/14/2017 To: Attn: Peter Moulinos, Esq. MOULINOS & ASSOCIATES LLC Attorneys for Defendants 150 East 58th Street, 25th Floor New York, New York 10155 Tel: (212) 832-5981 9 9 of 9