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TexLaw, Attorney
Category: Legal
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Experience:  Lead trial/International commercial attorney licensed 11 yrs
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I have a case in the NYS Court of Claims, which I am doing

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I have a case in the NYS Court of Claims, which I am doing pro se. The claim is only for loss of costs ($10K) of an accident that was caused by Buffalo Maintenance. I have provided the office of asst attorney general several demands - verified bill of particulars, notice for discovery & inspection, demand for collateral sources, CPLR 3101(d) etc. My question: We have had 2 preliminary conferences & are scheduled for depositions on Monday. Should I be writing and requesting information from the defendents attorney (Asst Attorney General)? What should they be providing me?
Yes, you should seek discovery from the Defendants. You should ask for documents concerning:
1) any disciplinary procedures against the employees who caused the injury
2) copies of any special licenses held by the employees who caused the injury
3) any documents which give any guidelines or procedures for the activity conducted by the employees which caused the injury
4) any documents regarding you, such as medical records obtained by the defense.
5) all documents provided by the defense to any expert witnesses
6) photographs of the scene where the injury occurred
7) if it was equipment which caused the injury then you want all maintenance reports regarding the injury
8) all documents regarding investigations into the event underlying the claim conducted by the Maintenance Department.

You should also serve an interrogatory that asks questiosn about their defense and asks them to identify any and all people with knowledge of relevant facts.
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