Plaintiff reserves the right to claim additional items of special damages Plaintiff was incapacitated from employment for twelve weeks.Īt the time of the accident, plaintiff was earning $5,000 every two weeks.Īs a result of the accident, plaintiff missed twelve weeks from work incurring a wage loss of (c ) home for approximately two weeks following the accident.ĩ. (b) bed for approximately three days following the accident New York 10310, from Februthrough February 4, 2004. Vincent’s Medical Center, 355 Bard Avenue, Staten Island, As a result of the injuries sustained in the occurrence, plaintiff, was confined to: (a) St. Upon information and belief, all of the aforementioned injuries are permanent in nature.Ĩ. – tightness and swelling left knee joint – limited and restricted range of motion, left knee – received intravenous antibiotics during hospitalization

– large rents in the medial and lateral patellar retinaculae underwent excision of distal pole, left patella – underwent surgical repair of left patella tendon requiring general anesthesia comminuted, distal pole, left patella not amendable to repair comminuted, displaced intra-articular fracture, left patella Sustained the following serious personal injuries: As a result of the negligence of the defendant, plaintiff Not applicable, there were no vehicles involved in this incident.ħ. Generally negligent and careless under the circumstances.Ĥ-6. Graded land areas adjacent to the driveway which caused water to accumulate on the driveway To place posted signs, warnings, barricades, cones ropes or other devices to prevent pedestriansįrom using the walkway/driveway or from entering the unsafe area in causing, permitting and/orĪllowing said personal property to be and remain in an unsafe, improper, and dangerousĬondition for an unreasonable amount of time in failing to remedy said dangerous condition inįailing to correct the negligent construction of the driveway, in failing to correct the poorly In a dangerous, unsafe, and improper condition in allowing a single downspout at each home toĬollect and drain roof water from an extremely large area at each of defendant’s homes in failing The defendants were negligent and careless in that they failed to maintain the guttersĪnd drainpipe/downspouts and provide proper drainage, in causing, permitting and/or allowing aĭangerous condition to exist and be on the defendant’s premises, to be and become and remain The incident occurred on the driveway area in front of the premises ofġ23 MAIN STREET , Staten Island, New York.ģ. The incident occurred on Februat 5:30 p.m.Ģ. The demand of the defendant, DANIEL JONES for a Verified Bill of Particularsġ. Plaintiffs through their attorney, CHARLES C. Here is a sample of a “Bill of Particulars”: The defendants usually request further details of your claim in a legal pleading called the “Demand for Bill of Particulars.” The response to this legal pleading is called “Bill of Particulars.” Basically, this document provides all of the details of your claim, including pedigree information, accident dates, economic loss such as lost wages, out of pocket expenses, medical and hospital bills, and other information that is vital to proving your accident case. Photographs, videos, witness information, and other items that can help the plaintiff are generally requested. We (as plaintiffs) also have the right to request materials that will assist us at trial.

The goal is to reach the point where you can file a “Note of Issue” which allows you to join the list of other plaintiffs who want a jury trial. It is important to comply with these requests in order to move your client’s case forward and to avoid unnecessary court intervention. The requests usually ask for authorizations to obtain all medical records, employments records, diagnostic films, surgical records, tax records, etc.Īdditionally, requests for photographs, accident reports, and any other physical evidence are the norm in a Notice of Discovery and Inspection.

In my law firm ,we have a policy of responding to defendant’s discovery requests upon receipt.

Verified bill of particulars new york