UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
………………………………………………………………..X
Ashmeen Modikhan,
Plaintiff
Vs
Darrow Aronow, Esq., Hanin R. Shadood, Esq.,
Courtney R. Williams, Esq., Fay Servicing
LLC, Rushmore Loan Management Services,
Inc., Marianne Derosa, Chapter 13 Trustee
Defendant(s)
Case No: No: 22-cv-06434-EK
………………………………………………………………..X
PLAINTIFF’S INITIAL DISCLOSURES PURSUANT TO FRCP 26
COMES NOW, Plaintiff ASHMEEN MODIKHAN pursuant to F.R.C.P. 26, hereby
serves these Initial Disclosures to Defendants. Plaintiff states as follows:
1. Individuals likely to have discoverable information
Persons likely to have discoverable information may include, but may not be limited to
the following:
i. Darrow Aronow, Esq.,
ii. Hanin R. Shadood, Esq.,
iii. Courtney R. Williams, Esq.,
iv. Fay Servicing LLC,
v. Rushmore Loan Management Services, Inc.,
vi. Marianne Derosa; and
vii. Ashmeen Modikhan.
Additional parties having relevant information: At this time, Plaintiff is unaware of any
additional persons believed to have relevant information. Should such persons come to Plaintiff’s
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attention through the course of further discovery, Plaintiff will promptly supplement this
Disclosure Statement.
These disclosures do not include the names of any potential experts retained or consulted
by the Plaintiff. Plaintiff will produce information relating to experts as may be appropriate
under Federal Rule of Civil Procedure 26(a)(2) at the times provided by that Rule or any
supervening order of the Court. In addition, the disclosures do not include documents produced
by Plaintiff.
2. Documents, data compilations, and tangible things that may be relevant to disputed
facts alleged with particularity in the pleadings.
Plaintiff shall produce all documents in their possession relevant to the case including but
not limited to: notes, loan modification agreements, correspondence and emails with the Plaintiff
to the extent they are not privileged, assignment of notes, allonges and/or mortgages, transaction
histories, motions, pooling and servicing agreements, collateral files, investor guidelines, powers
of attorney, copy of any trusts, contracts between the trust and servicers and/or sub-servicers,
notarized affidavits, government issued identification, documents relating to the alleged
obligation at issue in this case. These discoverable documents shall be available for inspection
and copying by Defendants at a mutually agreeable date and time.
Plaintiff will also produce any and all responses to discovery that have been generated in
this matter and any responses generated in the future, including, but not limited to, Answers to
Interrogatories, Responses to Requests for Production of Documents, and Requests for
Admissions, and all documents gained through authorization or subpoena.
Without waiving objection, Plaintiff shall produce any and all exhibits listed by
Defendants in their Disclosure Statement and any supplements.
3. Computation of damages
Compensatory Damages (Emotional Pain, Suffering, Inconvenience, Mental Anguish,
Loss of Enjoyment of Life and Other Non-Pecuniary Losses): amount up to trier of fact after all
evidence presented.
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Pre-Judgment Interest: Interest at the highest lawful legal rate allowed by law.
Punitive Damages: amount up to trier of fact after all evidence presented.
Equitable Relief: As may be appropriate—amounts decided by court after all evidence
presented.
Court Costs: These costs will be the actual court costs incurred—amounts continue to
accrue.
Reasonable Expert Fees: Amount decided by trier of facts after all evidence presented.
4. Insurance information
Not Applicable to Plaintiff.
Defendant is required to disclose the liability policy limits that were available and in
force at the time of the subject accident.
Date: _________________
___________________________
Ashmeen Modikhan
94-22 Magnolia Court, Unit 1B
Ozone Park, NY 11417
Pro Se Debtor
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