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You are a paralegal working in the law office Chesney & Nicholas LLP representing Defendant Bright view Landscape LLC in the lawsuit attached. I have uploaded the Complaint, the defendant’s demands for discovery, and the plaintiff’s response to some of the discovery demands in the case of Richardson v. Westchester Medical Center Health Care Corporation and Bright view Landscape LLC.
You have been asked by one of the attorneys in our firm to:
1. Draft three Subpoena Duces Tecum for NYS Supreme Court requesting documents from
(A) Stand-up MRI of the Bronx ,
(B) Dr. Louis C. Rose and
(C) White Plains Bus Co.
The addresses are on the response letter and you need to read the Complaint and Demands to figure out the relevant time period for each document request – i.e., what documents you are requesting and from what date to what date. YOU have to list the documents being requested with details. Choose a date for the documents to be delivered in 2023 with time and place appropriate.
2. You also have the include a sample Business Record Certification with each Subpoena and again draft it for THIS case and for each of the three different businesses. You have to draft three Business Record Certifications -= one to correspond for each of the Subpoenas. Again, make sure you have the correct company where you are requesting documents for each Certification.
3. Finally, you have been asked to also draft a Notice of Deposition for the doctor as the attorneys want to ask him specific questions regarding the diagnosis and treatment of the plaintiff. Again I have uploaded an example but don’t just cut and paste. Choose a date for the Deposition for January 2023 with time and place appropriate.
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