Complaint and Discovery

Complaint and Discovery SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK VERIFIED Mike Turner, COMPLAINT Plaintiff, ~Against~ Index No: Daytime Bakery Company Defendants REQUEST FOR ANSWERS TO INTERROGATORIES. Plaintiff MIKE TURNER, by his attorneys, J.J. LEGAL & ASSOOCIATES complaining of the Defendants herein, upon information and belief respectfully alleges as follows: Plaintiff MIKE TURNER is a resident of the City, County and State of New York.

Plaintiff MIKE TURNER is an able bodied individual not prone to falling and fell because of the snow that had accumulated on the sidewalk. Plaintiff MIKE TURNER alleges that while walking in front of the Daytime Bakery on a cold December day, Mr. Turner slipped and fell because of the snow that had accumulated on the sidewalk. 4. The fall caused Plaintiff MIKE TURNER to break his left leg and left arm which required him to seek medical attention. 5.

The medical examination required a $5,000 outlay by Plaintiff MIKE TURNER and may require future medical follow up treatment. Defendant DAY TIME BAKERY left their sidewalk in front of their store covered in snow 7. Defendant DAY TIME BAKERY has a legal responsibility based on a city ordinance to keep the sidewalks in front of their stores reasonably clear from all hazards. 8. Defendant DAY TIME BAKERY had not shoveled their sidewalk for at least four days. 9.

Defendant DAY TIME BAKERY made an inadequate effort to remove the snow on the sidewalk by applying salt. 10. As a consequence, of the foregoing misconduct of Defendant DAY TIME BAKERY, Plaintiff MIKE TURNER has been damaged in an amount exceeding the requirements of this court. WHEREFORE, Plaintiff MIKE TURNER demands judgment against Defendant DAY TIME BAKERY for the amount of medic al fees, legal fees plus interest and for any other relief this courts deems just and proper. J.J.

LEGAL & ASSOOCIATES New York, New York SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK VERIFIED Mike Turner, COMPLAINT Plaintiff, ~Against~ Index No: Daytime Bakery Company Defendants REQUEST FOR ADMISSIONS Mike Turner appearing in proper person requests Daytime Bakery Company to admit the truth of the statements that appear in paragraphs numbered 1-10 below: 1 -- Do you concur that Plaintiff MIKE TURNER is an able bodied individual not prone to falling and because of the snow that had accumulated on the sidewalk of your business was the cause of his falling? 2.

Do you concur that Plaintiff MIKE TURNER fell in front of the Daytime Bakery which caused him to break his arm and leg? 3. Do you concur that the fall caused Plaintiff MIKE TURNER seek medical attention. 4. Do you concur that the medical examination required a $5,000 outlay by Plaintiff MIKE TURNER and may require future medical follow up treatment. 5 Do you concur that you the Defendant, DAY TIME BAKERY left their sidewalk in front of the store covered in snow? 6.

Do you concur that you the Defendant DAY TIME BAKERY have a legal responsibility based on a city ordinance to keep the sidewalks in front of your store reasonably clear from all hazards. 7. Do you concur that you the Defendant DAY TIME BAKERY had not shoveled your sidewalk for at least four days. 8. Do you concur that you the Defendant DAY TIME BAKERY made an inadequate effort to remove the snow on the sidewalk by applying salt. 9.

Do you concur that you the as a consequence of the foregoing misconduct the Plaintiff MIKE TURNER has been damaged in an amount exceeding $5,000. 10. Do you concur that you the Defendant DAY TIME BAKERY are responsible for the Plaintiff MIKE TURNER's incurred legal and medical bills with interest? J.J. LEGAL & ASSOOCIATES New York, New York SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK VERIFIED Mike Turner, COMPLAINT Plaintiff, ~Against~ Index No: Daytime Bakery Company Defendants PLANTIFF REQUEST FOR PRODUCTION OF DOCUMENTS: 1.

Document Discovery All non-privileged and otherwise non-objectionable documents responsive to MIKE TRURNER First Set Of Requests For DAYTIME BAKERY shall be produce.