On March 12, 2018 a
Motion-Secondary
was filed
involving a dispute between
Luis Corvacho,
and
Marjorie Alacqua,
Mary Tom,
for Torts - Other (Trip and Fall)
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 11/21/2018 05:41 PM INDEX NO. 703720/2018
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 11/21/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
-------------------- ---- ¬----------X
LUIS CORVACHO, Index No.: 703720/2018
Plaintiff(s), AF FIRMATION IN
OPPOSITION
-against-
MARJORIE ALACQUA and MARY TOM,
Defendant(s).
----------------- ¬-------------X
ENRIQUE GUERRERO, an attorney, duly admitted to practice law in the State of New York,
affirms under penalty and perjury as follows:
1. I am a partner in the law firm of GUERRERO & ROSENGARTEN, and as such I am fully
fam!!!ar with the facts and circumstances surrounding this action.
2. This affirmation is submitted in opposition to the within motion for an Order pursuant to
CPLR § 3042 precluding the Plaintiff from giving evidence with respect to each and every
particular demanded.
3. I respectfully bring this Court's attention to Exhibit "A", specifically where Plaintiffhave
compiled with the Defendants demand and served on November 21'', 2018 a Vêrifiêd Bill of
Particulars as well as Responses and various discovery demands.
4. in light of the above, Defendants motion seeking to preclude Plaintiff pursuant CPLR
§3042 is moot, as allthe responses have been provided.
5. In the interest of all parties, Plaintiff respectfully requests that a Preliminary Conferêñce is
held in lieu of the within motion for the purpose of scheduling dates for depcsiticñs and all
other outstanding discovery accordingly.
1 of 3
FILED: QUEENS COUNTY CLERK 11/21/2018 05:41 PM INDEX NO. 703720/2018
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 11/21/2018
WHEREFORE, Plaintiff, respectfully requests that Defendants motion be denied in its entirety,
together with such other and further relief as this Court deems just and proper.
Dated: New York, New York
November 21, 2018
You s etc.,
Enriq Guerrero E .
GUE ERO & ROSE GARTEN
Atto ys for Plain
LUIS CORVACHO
363 7th Avenue 7th Floor
New York, New York 10001
Telephone: (212) 533-2606
Paul Robertson, Esq.
RICHARD T. LAU & ASSOCIATES
Attorneysfor Defendant(s)
MARIORIE ALACQUA and MARY TOM
300 Jericho Quadrangle, Suite 260
Jericho, New York 11753-9040
Phone #: (516) 229-6000
File Number: 18newy11651
2 of 3
FILED: QUEENS COUNTY CLERK 11/21/2018 05:41 PM INDEX NO. 703720/2018
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 11/21/2018
UIS CORVACHOe . O
P amtiff(9
MAR)0R E At CQWA and A I T
™ I
MARIQR(EA4ACQUA appi A‡ASV TOM
FReh 8 Y 165
emce df NOpyo e W us reb¶ ad0 .
ated
ÈRRÃ#6 &1 NGAR E of hseM to s ic 6fny
att ewW6t a ( d p of a dutyzmged a theiffice ofthe tierkof WehithinheÄind cou n
3 of 3
Document Filed Date
November 21, 2018
Case Filing Date
March 12, 2018
Category
Torts - Other (Trip and Fall)
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FILED: QUEENS COUNTY CLERK 11/21/2018 05:41 PM INDEX NO. 703720/2018 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 11/21/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS -------------------- ---- ¬----------X LUIS CORVACHO, Index No.: 703720/2018 Plaintiff(s), AF FIRMATION IN OPPOSITION -against- MARJORIE ALACQUA and MARY TOM, Defendant(s). ----------------- ¬-------------X ENRIQUE GUERRERO, an attorney, duly admitted to practice law in the State of New York, affirms under penalty and perjury as follows: 1. I am a partner in the law firm of GUERRERO & ROSENGARTEN, and as such I am fully fam!!!ar with the facts and circumstances surrounding this action. 2. This affirmation is submitted in opposition to the within motion for an Order pursuant to CPLR § 3042 precluding the Plaintiff from giving evidence with respect to each and every particular demanded. 3. I respectfully bring this Court's attention to Exhibit "A", specifically where Plaintiffhave compiled with the Defendants demand and served on November 21'', 2018 a Vêrifiêd Bill of Particulars as well as Responses and various discovery demands. 4. in light of the above, Defendants motion seeking to preclude Plaintiff pursuant CPLR §3042 is moot, as allthe responses have been provided. 5. In the interest of all parties, Plaintiff respectfully requests that a Preliminary Conferêñce is held in lieu of the within motion for the purpose of scheduling dates for depcsiticñs and all other outstanding discovery accordingly. 1 of 3 FILED: QUEENS COUNTY CLERK 11/21/2018 05:41 PM INDEX NO. 703720/2018 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 11/21/2018 WHEREFORE, Plaintiff, respectfully requests that Defendants motion be denied in its entirety, together with such other and further relief as this Court deems just and proper. Dated: New York, New York November 21, 2018 You s etc., Enriq Guerrero E . GUE ERO & ROSE GARTEN Atto ys for Plain LUIS CORVACHO 363 7th Avenue 7th Floor New York, New York 10001 Telephone: (212) 533-2606 Paul Robertson, Esq. RICHARD T. LAU & ASSOCIATES Attorneysfor Defendant(s) MARIORIE ALACQUA and MARY TOM 300 Jericho Quadrangle, Suite 260 Jericho, New York 11753-9040 Phone #: (516) 229-6000 File Number: 18newy11651 2 of 3 FILED: QUEENS COUNTY CLERK 11/21/2018 05:41 PM INDEX NO. 703720/2018 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 11/21/2018 UIS CORVACHOe . O P amtiff(9 MAR)0R E At CQWA and A I T ™ I MARIQR(EA4ACQUA appi A‡ASV TOM FReh 8 Y 165 emce df NOpyo e W us reb¶ ad0 . ated ÈRRÃ#6 &1 NGAR E of hseM to s ic 6fny att ewW6t a ( d p of a dutyzmged a theiffice ofthe tierkof WehithinheÄind cou n 3 of 3