FAMILY COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS
_____________________________________________________
INDEX NO.
F-28901-08/10B

ELENA SVENSON,
Petitioner,
-againstMICHAEL KRICHEVSKY,

FIRST RESPONDENT'S
COMBINED DEMANDS
FOR DISCOVERY

Respondent.
_____________________________________________________

COUNSELORS:
PLEASE TAKE NOTICE, that pursuant to the demand of the respondent you produce
all pleadings heretofore served in this action.
TAKE FURTHER NOTICE, that pursuant to Sections 3101 et. seq. of the Civil Practice
Law and Rules and the demand of the respondent, you produce, at the time and place specified,
and permit the undersigned to discover, inspect and copy, any and all photographs taken in
regard to this proceeding which are now in your possession, custody or control, or in the
possession, custody or control of any person or entity associated with petitioner or you, if such
photographs bear in any manner upon the issues in this action and other actions involving parties.
TAKE FURTHER NOTICE, that pursuant to the demand of the respondent you
produce and allow the undersigned to inspect any written report concerning the respondent or
incident which is the subject matter of this lawsuit made by the petitioner.
TAKE FURTHER NOTICE, that respondent, hereby demands, pursuant to Section
3101(a), (d), (e), and (i) and Section 3120 of the Civil Practice Law and Rules, that you produce
at Staples store, 1949 Stillwell Ave in Brooklyn for inspection and copying, upon at least one full
business day's advance notice, any and all materials allegedly, purportedly, and/or actually
representing, constituting, consisting of or depicting surveillance of the respondent, which you
intend to use upon the trial of this action, including but not limited to audio tapes, films, video

tapes, video recordings, video laser discs, or photographs, including outtakes, memoranda, and
transcripts now in your possession, custody or control, or in the possession, custody or control of
any person or entity associated with petitioner or you in this action. Should any such material
come into your possession, custody or control, or into the possession, custody or control of any
person or entity associated with petitioner or you, at any time after the date of this demand, then
demand is made that you produce such material for inspection and copying, upon at least one full
business day's advance notice, within twenty (20) days after said materials come into your
possession, custody or control, or into the possession, custody or control of any person or entity
associated with petitioner or you.
TAKE FURTHER NOTICE that pursuant to Section 3101(d) of the Civil Practice Law
and Rules, you are hereby required to furnish the respondent, discovery as to each person whom
you expect to call as a witness or an expert regarding the following:
State the name and address of every witness or expert retained or employed by you in
anticipation of this litigation or preparation for trial whom you expect to call as a witness at the
trial. For each, state the following:
a. The subject matter on which the witness or expert is expected to testify.
b. The substance of the facts and opinions to which the witness or expert is
expected to testify.
c. A brief summary of the grounds for each such opinion.
d. A brief chronological resume of each witness' educational background and
professional background, including the associations or societies of which each witness or expert
is a member.
e. Whether each named expert will testify as an expert at the trial of this action.
f. The state or states in which this individual was licensed to practice his/her trade.
g. Each state in which this individual is actively engaged in the practice of said
trade.
h. Membership in any professional societies and the date of each such

membership.
i. The present board certifications and/or qualifications, if any, and the dates
thereof for each expert witness.
j. The subject matter of testimony for each expert.
k. The substance of the facts and opinions of the expert testimony, including a
summary of the grounds for each opinion.
TAKE FURTHER NOTICE, that pursuant to Section 3101(a) of the Civil Practice Law
and Rules and the demand of the respondent, you are requested to set forth in writing and under
oath, the name and address of each person claimed to be a witness to any of the following:
a. The occurrence alleged in the petition;
b. Any acts, omissions or conditions which allegedly caused the occurrence in the
petition;
c. Any actual notice allegedly given to the respondent of any condition which
allegedly caused the occurrence alleged in the petition;
d. The nature and duration of any alleged condition which allegedly caused the
occurrence alleged in the petition;
e. Any admissions of the respondent or any agent of the respondent.
f. Any actual notice allegedly given to the respondent or agent of the respondent
of any condition which allegedly caused the occurrence alleged in the petition;
g. Any admissions of the respondent or any agent of the respondent.
If no such witnesses are known to petitioner, so state in the sworn reply to this demand.
The undersigned will object upon trial to the testimony of any witness not so identified in this
demand.
TAKE FURTHER NOTICE, that a response to these combined demands is required by
October 13, 2010 at the offices of the undersigned.
TAKE FURTHER NOTICE, that the foregoing are continuing demands and that if the
above items are obtained after the date of the response to these demands, they are to be furnished

to the offices of the undersigned pursuant to these demands.

Dated: Brooklyn, New York
September 23, 2010

______________________________
Michael Krichevsky, Pro Se
4221 Atlantic Ave
Brooklyn, New York 11224
(718) 687-2300
LAW OFFICE OF YONATAN LEVORITZ, PC
Attorneys for Petitioner
2306 Coney Island Ave, 2nd Fl.
Brooklyn, New York 11223

FAMILY COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS
_____________________________________________________
INDEX NO.
F-28901-08/10B

ELENA SVENSON,
Petitioner,
-against-

AFFIDAVIT OF MAIL
SERVICE

MICHAEL KRICHEVSKY,,
Respondent.
_____________________________________________________

STATE OF NEW YORK

COUNTY OF KINGS
____________________, being duly sworn, says:
I am not a party to the action; I reside at ____________________, and I am over 18 years
of age.
On September 22, 2010, I served the within Combined Demands for Discovery by
depositing a true copy thereof, enclosed in a post-paid wrapper, in an official depository under
the exclusive care and custody of the United States Postal Service within New York State,
addressed to the following at the last known address set forth below:
LAW OFFICE OF YONATAN LEVORITZ, PC
2306 Coney Island Ave, 2nd Fl.
Brooklyn, New York 11223
______________________________
____________________
Sworn to before me
on September 22, 2010
_______________________
NOTARY PUBLIC

FAMILY COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS
Index No. F-28901-08/10B
----------------------------------------------------------------ELENA SVENSON,
Petitioner,

-againstMICHAEL KRICHEVSKY,
Respondent.
-----------------------------------------------------------------

___________________________________________________
RESPONDENT'S COMBINED DEMANDS FOR DISCOVERY
___________________________________________________

The documents herein are hereby certified pursuant to 25 NYCRR 130-1.1-A

By: ________________________________
Michael Krichevsky