Preview
FILED: QUEENS COUNTY CLERK 11/14/2019 04:01 PM INDEX NO. 704591/2018
NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 11/14/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
--------------------------------------------- -----------X NOTICE FOR DISCOVERY
VINCENT GELZER, AND INSPECTION POST
EXAMINATION BEFORE
56™
Plaintiff, TRIAL OF DEFENDANT
REALTY LLC BY SANEL HOT
-against-
Index No.: 704591/2018
56TH REALTY, LLC, Individually, 56TH REALTY,
LLC, d/b/a MANHATTAN ART AND ANTIQUES
CENTER, and GLENWOOD MANAGEMENT
CORP.,
Defendants.
---------- -----------------------------------X
PLEASE TAKE NOTICE, that pursuant to CPLR 3101, demand is hereby made upon
you to serve upon and deliver to the undersigned within thirty (30) days of service of this
demand the following:
1. Production of the last name of the porter "Roberto (page 12), as requested at the
exañiination before trial of Sanel Hot taken on October 18, 2019;
2. Production of the last name of the porter "Able (page 13), as requested at the examination
before trialof Sanel Hot taken on October 18, 2019;
"Paul"
3. Production of the last name of the current property manager (page 19), as
requested at the examination before trialof Sanel Hot taken on October 18, 2019;
"Paul's"
4. Production of full name and title and the name and address of his employer
(page 24), as requested at the examination before trialof Sanel Hot taken on October 18,
2019;
5. A duplicate copy of surveillance footage, if there is any, either showing people coming in
and out prior to the incident and Mr. Gelzer leaving after the incident (page 37), as
requested at the examination before trialof Sanel Hot taken on October 18, 2019;
6. Production of the name of the security company as well as a copy of the contract with
them (page 37), as requested at the examination before trial of Sanel Hot taken on
October 18, 2019;
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FILED: QUEENS COUNTY CLERK 11/14/2019 04:01 PM INDEX NO. 704591/2018
NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 11/14/2019
7. Production of a more legible copy of the printout of the schematics of the second
concourse level (page 42), as requested at the examination before trial of Sanel Hot taken
on October 18, 2019.
PLEASE TAKE FURTHER NOTICE, that in the event you do not have one or more of the
above, itis demanded that you submit an Affidavit which so states.
PLEASE TAKE FURTHER NOTICE, that upon your failure to comply with this
Demand, a Motion shall be made to this Court for an Order directing compliance or in the
alternative preclusion, plus costs of the Motion.
Dated: Lake Success, New York
November 14, 2019
Yo , .
BY: STEPHEN B. TIGER, ESQ.
LAW OFFICE OF COHEN AND JAFFE, LLP
Attorneys for Plaintiff
2001 Marcus Avenue, Suite W295
Lake Success, New York 11042
(516) 358-6900
www.Cohenjaffe.com
TO: LAW OFFICES OF MARGARET G. KLEIN & ASSOCIATES
Attorneys for Defendants
200 Madison Avenue, Second Floor,
New York, New York 10016
(646) 392-9250
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FILED: QUEENS COUNTY CLERK 11/14/2019 04:01 PM INDEX NO. 704591/2018
NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 11/14/2019
AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
) SS.:
COUNTY OF NASSAU )
I, Debbie Wiener, being sworn, depose and say: I am not a party to the action, am over
18 years of age and reside in the State of New York.
On November l 9 , 2019 I served the within NOTICE FOR DISCOVERY AND
INSPECTION via regular mail, 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:
LAW OFFICES OF MARGARET G. KLEIN & ASSOCIATES
200 Madison Avenue, Second Floor,
New York, New York 10016
deNíie Wiener
Sworn to before me this
MARIA E. FlORE
ay of November, 2019
Notary Public, State of New York
No. 01Fl4982226
Qualified in Suffolk County
Commission Expires May 28,
NOTARY PUBLIC
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FILED: QUEENS COUNTY CLERK 11/14/2019 04:01 PM INDEX NO. 704591/2018
NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 11/14/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS Index No.: 704591/2018
VINCENT GELZER,
Plaintiff,
-against-
56TH REALTY, LLC, Individually, 56TH REALTY, LLC, d/b/a MANHATTAN ART AND
ANTIQUES CENTER, and GLENWOOD MANAGEMENT CORP,
Defendants.
_____________________________________ _____________________________________
NOTICE FOR DISCOVERY AND INSPECTION
____________________________________
LAW OFFICE OF COHEN & JAFFE, LLP
Attorneys for Plaintiff
2001 Marcus Avenue
Lake Success, N.Y. 11042
(516) 358-6900
www.CohenJaffe.com
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Preview
FILED: QUEENS COUNTY CLERK 11/14/2019 04:01 PM INDEX NO. 704591/2018 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 11/14/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS --------------------------------------------- -----------X NOTICE FOR DISCOVERY VINCENT GELZER, AND INSPECTION POST EXAMINATION BEFORE 56™ Plaintiff, TRIAL OF DEFENDANT REALTY LLC BY SANEL HOT -against- Index No.: 704591/2018 56TH REALTY, LLC, Individually, 56TH REALTY, LLC, d/b/a MANHATTAN ART AND ANTIQUES CENTER, and GLENWOOD MANAGEMENT CORP., Defendants. ---------- -----------------------------------X PLEASE TAKE NOTICE, that pursuant to CPLR 3101, demand is hereby made upon you to serve upon and deliver to the undersigned within thirty (30) days of service of this demand the following: 1. Production of the last name of the porter "Roberto (page 12), as requested at the exañiination before trial of Sanel Hot taken on October 18, 2019; 2. Production of the last name of the porter "Able (page 13), as requested at the examination before trialof Sanel Hot taken on October 18, 2019; "Paul" 3. Production of the last name of the current property manager (page 19), as requested at the examination before trialof Sanel Hot taken on October 18, 2019; "Paul's" 4. Production of full name and title and the name and address of his employer (page 24), as requested at the examination before trialof Sanel Hot taken on October 18, 2019; 5. A duplicate copy of surveillance footage, if there is any, either showing people coming in and out prior to the incident and Mr. Gelzer leaving after the incident (page 37), as requested at the examination before trialof Sanel Hot taken on October 18, 2019; 6. Production of the name of the security company as well as a copy of the contract with them (page 37), as requested at the examination before trial of Sanel Hot taken on October 18, 2019; 1 of 4 FILED: QUEENS COUNTY CLERK 11/14/2019 04:01 PM INDEX NO. 704591/2018 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 11/14/2019 7. Production of a more legible copy of the printout of the schematics of the second concourse level (page 42), as requested at the examination before trial of Sanel Hot taken on October 18, 2019. PLEASE TAKE FURTHER NOTICE, that in the event you do not have one or more of the above, itis demanded that you submit an Affidavit which so states. PLEASE TAKE FURTHER NOTICE, that upon your failure to comply with this Demand, a Motion shall be made to this Court for an Order directing compliance or in the alternative preclusion, plus costs of the Motion. Dated: Lake Success, New York November 14, 2019 Yo , . BY: STEPHEN B. TIGER, ESQ. LAW OFFICE OF COHEN AND JAFFE, LLP Attorneys for Plaintiff 2001 Marcus Avenue, Suite W295 Lake Success, New York 11042 (516) 358-6900 www.Cohenjaffe.com TO: LAW OFFICES OF MARGARET G. KLEIN & ASSOCIATES Attorneys for Defendants 200 Madison Avenue, Second Floor, New York, New York 10016 (646) 392-9250 2 of 4 FILED: QUEENS COUNTY CLERK 11/14/2019 04:01 PM INDEX NO. 704591/2018 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 11/14/2019 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) ) SS.: COUNTY OF NASSAU ) I, Debbie Wiener, being sworn, depose and say: I am not a party to the action, am over 18 years of age and reside in the State of New York. On November l 9 , 2019 I served the within NOTICE FOR DISCOVERY AND INSPECTION via regular mail, 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: LAW OFFICES OF MARGARET G. KLEIN & ASSOCIATES 200 Madison Avenue, Second Floor, New York, New York 10016 deNíie Wiener Sworn to before me this MARIA E. FlORE ay of November, 2019 Notary Public, State of New York No. 01Fl4982226 Qualified in Suffolk County Commission Expires May 28, NOTARY PUBLIC 3 of 4 FILED: QUEENS COUNTY CLERK 11/14/2019 04:01 PM INDEX NO. 704591/2018 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 11/14/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No.: 704591/2018 VINCENT GELZER, Plaintiff, -against- 56TH REALTY, LLC, Individually, 56TH REALTY, LLC, d/b/a MANHATTAN ART AND ANTIQUES CENTER, and GLENWOOD MANAGEMENT CORP, Defendants. _____________________________________ _____________________________________ NOTICE FOR DISCOVERY AND INSPECTION ____________________________________ LAW OFFICE OF COHEN & JAFFE, LLP Attorneys for Plaintiff 2001 Marcus Avenue Lake Success, N.Y. 11042 (516) 358-6900 www.CohenJaffe.com 4 of 4