Preview
FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
___-------------------------------- ---------------------------X
DEBORAH SPRUYT,
Plaintiff, REQUEST FOR
PRELIMINARY
CONFERENCE
Index No.: 612146/2021
-against-
JOAQUIM GONCALVES and MARIA GONCALVES,
Defendants.
______________________________--______.._______..-----------------------X
The undersigned requests a Preliminary Conference.
The nature of the action is PERSONAL INJURY.
The names, addresses and telephone numbers of all attorneys appearing in the action are as follows:
Lawrence Trogel
Law Offices of Karen Lawrence
Attorney for Defendant
1225 Franklin Avenue, Suite 100
Garden City, NY 11530
Email: ltro0@allstate.con)
Mobile: (516) 830-1697
File No.: 0544838584.1-
Dated: Garden City, New York
February 23, 2022
Yours, etc.
GREG-PATR RTELLO, ESQ.
MARTELLO LAMAGNA P.C.
Attorneys for Plaintiff(s),
EVELYN PALADINO
100 Quentin Roosevelt Blvd., Ste. 511
Garden City, New York 11530
1 of 6
FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022
(516) 228-3333
Email: grnartello@mlfirm_.__ne_t
TO:
Lawrence Trogel
Law Offices of Karen Lawrence
Attorney for Defendant
1225 Franklin Avenue, Suite 100
Garden City, NY 11530
Email: ltro0@allstate.com
Mobile: (516) 830-1697
File No.: 0544838584.1-
2 of 6
FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
-------------------------------------------------------------X
DEBORAH SPRUYT, AFFIRMATION
IN GOOD FAITH
Plaintiff,
Index No.: 612146/2021
-against-
JOAQUIM GONCALVES and MARIA GONCALVES,
Defendants.
-------------------------------------------------- ¬-X
GREG-PATRIC MARTELLO, ESQ., an attorney admitted to practice before the Courts
of this State affirms the truth of the following under the peñãlty of perjury and pursuant to CPLR
Rule 2106 that the following facts are true:
1. I am the attorney for the plaintiff(s) herein and as such I am fully familiar with the
facts and circumstances of this action based upon a review of the case fileand the investigation
materials contained therein.
2. This affirmation is submitted in connection with the filing of a Request for Judicial
Intervention requesting a Preliming Conference.
3. This is a negligence action to recover damages for serious permanent injuries
sustained by plaintiff DEBORAH SPRUYT as a result of an accident which occurred on May 9,
2019.
4. A Summons and Complaint was served on the defendants and issue was joined shortly
thereafter by Defendant(s) service of Answer.
5. Discovery has not been completed.
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FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022
WHEREFORE, plaintiff requests a conference be scheduled at
respectfully preliminary
the Court's earliest convenience.
Dated: Garden City, New York
February 23, 2022
C MARTELLO, ESQ.
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FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022
AFFIDAVIT OF SERVICE
STATE OF NEW YORK)
COUNTY OF NASSAU ) ss.:
LISA FRASCA, being duly sworn, deposes and says:
I am over 18 years of age, I am not a party to the action, and I reside in Merrick, New
York.
I served a true copy of the annexed REQUEST FOR JUDICIAL INTERVENTION,
REQUEST FOR PRELIMINARY CONFERENCE AND AFFIRMATION IN GOOD
FAITH, on February 23, 2022, by mailing the same in a sealed envelope, with postage prepaid
thereon, in a post office or official depository of the U.S. Postal Service within the State of New
York, addressed to the last known address of the addressees as indicated below:
TO:
Lawrence Trogel
Law Offices of Karen Lawrence
Attorney for Defendant
1225 Franklin Avenue, Suite 100
Garden City, NY 11530
Email: ltro0@allstate.com
Mobile: (516) 830-1697
File No.: 0544838584.1-
L S
Sworn to before me this
February 23, 2022
Notary Publi
GREG-PATRIC MARTELLO
NotaryPublic,Stateof New York
Reg.No. 02MA63275c9
Qudified in NassauCounty
Comraission ExpiresJuly6. 2021
5 of 6
FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022
Index Number: 612146/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
DEBORAH SPRUYT,
Plaintiff,
-against-
JOAQUIM GONCALVES and MARIA GONCALVES,
Defendants.
...
REQUEST FOR JUDICIAL INTERVENTION, REQUEST FOR PRELIMINARY CONFERENCE
AND AFFIRMATION IN GOOD FAITH
..
MARTELLO & LAMAGNA P.C.
Attorneys for Plaintiff,Deborah Spruyt
100 Quentin Roosevelt Boulevard,Ste. 511
Garden City, New York 11530
(516) 228-3333
Pursuant to 22 NYCRR 130-1.1,the undersigned, an attorney admitted to practicein theCourts of New York State,
certifiesthat, upon information and belief and ressóñãble inquiry, the contentions ce:::ined in the annexed
document are not frivalcus.
- ATRIC MARTELLO, ESQ.
Sir:Please take notice
O NOTICE OF ENTRY
that thewithin isa (certified)true copy of a duly entered in theoffice of theclerk of the
within named court on 2022
O NQTICE OF SETTLEMENT
thatan order of which the withinisa truecopy willbe presented for
settlement to theHON. one of the judges
of thewithin named Court, at on the day of 202 at M.
Dated: February 23, 2022
Yours, etc.
To: MARTELLO & LAMAGNA P.C.
Lawrence Trogel Attorneys forPlaintiff
LAW OFFICES OF KAREN LAWRENCE DEBORAH SPRUYT
100 QUENTIN ROOSEVELT BLvD., STE.511
GARDEN CITY, NEW YORK 11530
TELEPHONE: (516) 228-3333
6 of 6
Preview
FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ___-------------------------------- ---------------------------X DEBORAH SPRUYT, Plaintiff, REQUEST FOR PRELIMINARY CONFERENCE Index No.: 612146/2021 -against- JOAQUIM GONCALVES and MARIA GONCALVES, Defendants. ______________________________--______.._______..-----------------------X The undersigned requests a Preliminary Conference. The nature of the action is PERSONAL INJURY. The names, addresses and telephone numbers of all attorneys appearing in the action are as follows: Lawrence Trogel Law Offices of Karen Lawrence Attorney for Defendant 1225 Franklin Avenue, Suite 100 Garden City, NY 11530 Email: ltro0@allstate.con) Mobile: (516) 830-1697 File No.: 0544838584.1- Dated: Garden City, New York February 23, 2022 Yours, etc. GREG-PATR RTELLO, ESQ. MARTELLO LAMAGNA P.C. Attorneys for Plaintiff(s), EVELYN PALADINO 100 Quentin Roosevelt Blvd., Ste. 511 Garden City, New York 11530 1 of 6 FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022 (516) 228-3333 Email: grnartello@mlfirm_.__ne_t TO: Lawrence Trogel Law Offices of Karen Lawrence Attorney for Defendant 1225 Franklin Avenue, Suite 100 Garden City, NY 11530 Email: ltro0@allstate.com Mobile: (516) 830-1697 File No.: 0544838584.1- 2 of 6 FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU -------------------------------------------------------------X DEBORAH SPRUYT, AFFIRMATION IN GOOD FAITH Plaintiff, Index No.: 612146/2021 -against- JOAQUIM GONCALVES and MARIA GONCALVES, Defendants. -------------------------------------------------- ¬-X GREG-PATRIC MARTELLO, ESQ., an attorney admitted to practice before the Courts of this State affirms the truth of the following under the peñãlty of perjury and pursuant to CPLR Rule 2106 that the following facts are true: 1. I am the attorney for the plaintiff(s) herein and as such I am fully familiar with the facts and circumstances of this action based upon a review of the case fileand the investigation materials contained therein. 2. This affirmation is submitted in connection with the filing of a Request for Judicial Intervention requesting a Preliming Conference. 3. This is a negligence action to recover damages for serious permanent injuries sustained by plaintiff DEBORAH SPRUYT as a result of an accident which occurred on May 9, 2019. 4. A Summons and Complaint was served on the defendants and issue was joined shortly thereafter by Defendant(s) service of Answer. 5. Discovery has not been completed. 3 of 6 FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022 WHEREFORE, plaintiff requests a conference be scheduled at respectfully preliminary the Court's earliest convenience. Dated: Garden City, New York February 23, 2022 C MARTELLO, ESQ. 4 of 6 FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022 AFFIDAVIT OF SERVICE STATE OF NEW YORK) COUNTY OF NASSAU ) ss.: LISA FRASCA, being duly sworn, deposes and says: I am over 18 years of age, I am not a party to the action, and I reside in Merrick, New York. I served a true copy of the annexed REQUEST FOR JUDICIAL INTERVENTION, REQUEST FOR PRELIMINARY CONFERENCE AND AFFIRMATION IN GOOD FAITH, on February 23, 2022, by mailing the same in a sealed envelope, with postage prepaid thereon, in a post office or official depository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressees as indicated below: TO: Lawrence Trogel Law Offices of Karen Lawrence Attorney for Defendant 1225 Franklin Avenue, Suite 100 Garden City, NY 11530 Email: ltro0@allstate.com Mobile: (516) 830-1697 File No.: 0544838584.1- L S Sworn to before me this February 23, 2022 Notary Publi GREG-PATRIC MARTELLO NotaryPublic,Stateof New York Reg.No. 02MA63275c9 Qudified in NassauCounty Comraission ExpiresJuly6. 2021 5 of 6 FILED: NASSAU COUNTY CLERK 02/24/2022 10:34 AM INDEX NO. 612146/2021 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 02/24/2022 Index Number: 612146/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU DEBORAH SPRUYT, Plaintiff, -against- JOAQUIM GONCALVES and MARIA GONCALVES, Defendants. ... REQUEST FOR JUDICIAL INTERVENTION, REQUEST FOR PRELIMINARY CONFERENCE AND AFFIRMATION IN GOOD FAITH .. MARTELLO & LAMAGNA P.C. Attorneys for Plaintiff,Deborah Spruyt 100 Quentin Roosevelt Boulevard,Ste. 511 Garden City, New York 11530 (516) 228-3333 Pursuant to 22 NYCRR 130-1.1,the undersigned, an attorney admitted to practicein theCourts of New York State, certifiesthat, upon information and belief and ressóñãble inquiry, the contentions ce:::ined in the annexed document are not frivalcus. - ATRIC MARTELLO, ESQ. Sir:Please take notice O NOTICE OF ENTRY that thewithin isa (certified)true copy of a duly entered in theoffice of theclerk of the within named court on 2022 O NQTICE OF SETTLEMENT thatan order of which the withinisa truecopy willbe presented for settlement to theHON. one of the judges of thewithin named Court, at on the day of 202 at M. Dated: February 23, 2022 Yours, etc. To: MARTELLO & LAMAGNA P.C. Lawrence Trogel Attorneys forPlaintiff LAW OFFICES OF KAREN LAWRENCE DEBORAH SPRUYT 100 QUENTIN ROOSEVELT BLvD., STE.511 GARDEN CITY, NEW YORK 11530 TELEPHONE: (516) 228-3333 6 of 6