You are now in the discovery phase of the Pelham case.  Mr. Dion's attorney, Thomas Brown, made an initial demand requesting, inter alia, all of the photographs taken of the minor plaintiff's injuries allegedly sustained from the January 15, 2019 incident with defendant Trivoli's dog.  All documents and information pursuant to this demand were due within 20 days of service of that demand.  The plaintiffs' attorney did not respond to demand 15 regarding photographs of the minor plaintiff's injuries.  On September 1, 2019,*, Attorney Brown sent a letter to the plaintiffs' attorney following up on the August 1, 2019 demand and reiterating the request for all of the photographs taken of the alleged injuries be forwarded within 10 days.  Once again, the plaintiff's attorneys did not respond.  Now defendant Dion will make a motion to compel the disclosure of photographs.
*The dates will not make sense in terms of the other parts of the project - we are squishing pleadings and discovery into a very short time for the sake of the project.  Normally these things would take months, maybe more than a year.
For this part of the project, you will draft a Notice of Motion, as well as an attorney affidavit or affirmation in support of the motion.  The motion is scheduled to be heard in front of Judge Jones on January 3, 2020, at the Erie County Supreme Court located at 25 Delaware Ave. Buffalo, N.Y. 14203.  For this part of the project, assume that the Summons and Complaint were filed on February 1, 2019.
See the copy of the defendant's original demand and follow-up letter below.
Use Lexis Advance to find a sample Notice of Motion and attorney affidavit in support of the motion.  

Answer rating: 100% (QA)

NOTICE OF MOTION TO The Hon John Jones Erie County Supreme Court 25 Delaware Avenue Buffalo NY 14203 FROM Thomas Brown Attorney for Defendant Dion 123 Main Street Buffalo NY 14201 DATE January 2 2020 ... View the full answer