Preview
FILED: QUEENS COUNTY CLERK 12/10/2019 10:18 AM INDEX NO. 704591/2018
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 12/10/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
------- ----------------------------X PLAINTIFF'S FURTHER
VINCENT GELZER, POST EBT
DEMAND FOR DISCOVERY
Plaintiff, & INSPECTION
-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 the plaintiff, by his attorneys, LAW OFFICE OF COHEN
& JAFFE, LLP, hereby demands that defendant GLENWOOD MANAGEMENT, is required to
provide the following materials pursuant to the applicable provisions of the Civil Practice Law
and Rules and the Rules of this Court, returnable at the LAW OFFICE OF COHEN & JAFFE,
LLP, 2001 Marcus Avenue, Suite W295, Lake Success, New York 11042, at 10:00 a.m., within
thirty (30)days of receipt of this notice, as per the enumerated subdivisions below:
1. Please provide any and all insurance policies that would cover the type of work that was
being done on the date of the subject accident in the gallery at the MAAC (page 42 of
Lisa Guida's deposition transcript).
56*
2. Please provide copies of any policies obtained by outside entities that name Realty or
Glenwood Management as additional insureds (page 42 of Lisa Guida's deposition
transcript).
3. Please provide copies of any follow-up correspondence, emails or anything else getween
anyone from Glenwood, Mike KcHenry or any of the potential witnesses (page 66 ofLisa
Guida's deposition transcript).
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FILED: QUEENS COUNTY CLERK 12/10/2019 10:18 AM INDEX NO. 704591/2018
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 12/10/2019
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
December 9, 2019
Your e .
BY TEPHEN 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 12/10/2019 10:18 AM INDEX NO. 704591/2018
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 12/10/2019
AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
) SS.:
COUNTY OF NASSAU )
I,Carola Sanchez, 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 Decemberp,
2019 I served the within PLAINTIFF'S FURTHER POST EBT
DEMAND FOR DISCOVERY & 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
CAR S CHEZ
Sworn to before me this
ay of December, 2019
P A
NOTARY PÙBLIC New York
No, 018H6351225
in Nassau
Q ualified
County
Commisalon EMPk•8 11
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FILED: QUEENS COUNTY CLERK 12/10/2019 10:18 AM INDEX NO. 704591/2018
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 12/10/2019
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.
_________________________ _______________________________________
PLAINTIFF'S FURTHER POST EBT DEMAND FOR DISCOVERY & INSPECTION
_________ ________________________ ____________
LAW OFFICE OF COHEN & JAFFE, LLP
Attorneys for Plaintiff
VINCENT GELZER
2001 Marcus Avenue
Lake Success, N.Y. 11042
(516) 358-6900
www.CohenJaffe.com
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Preview
FILED: QUEENS COUNTY CLERK 12/10/2019 10:18 AM INDEX NO. 704591/2018 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 12/10/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ------- ----------------------------X PLAINTIFF'S FURTHER VINCENT GELZER, POST EBT DEMAND FOR DISCOVERY Plaintiff, & INSPECTION -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 the plaintiff, by his attorneys, LAW OFFICE OF COHEN & JAFFE, LLP, hereby demands that defendant GLENWOOD MANAGEMENT, is required to provide the following materials pursuant to the applicable provisions of the Civil Practice Law and Rules and the Rules of this Court, returnable at the LAW OFFICE OF COHEN & JAFFE, LLP, 2001 Marcus Avenue, Suite W295, Lake Success, New York 11042, at 10:00 a.m., within thirty (30)days of receipt of this notice, as per the enumerated subdivisions below: 1. Please provide any and all insurance policies that would cover the type of work that was being done on the date of the subject accident in the gallery at the MAAC (page 42 of Lisa Guida's deposition transcript). 56* 2. Please provide copies of any policies obtained by outside entities that name Realty or Glenwood Management as additional insureds (page 42 of Lisa Guida's deposition transcript). 3. Please provide copies of any follow-up correspondence, emails or anything else getween anyone from Glenwood, Mike KcHenry or any of the potential witnesses (page 66 ofLisa Guida's deposition transcript). 1 of 4 FILED: QUEENS COUNTY CLERK 12/10/2019 10:18 AM INDEX NO. 704591/2018 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 12/10/2019 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 December 9, 2019 Your e . BY TEPHEN 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 12/10/2019 10:18 AM INDEX NO. 704591/2018 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 12/10/2019 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) ) SS.: COUNTY OF NASSAU ) I,Carola Sanchez, 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 Decemberp, 2019 I served the within PLAINTIFF'S FURTHER POST EBT DEMAND FOR DISCOVERY & 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 CAR S CHEZ Sworn to before me this ay of December, 2019 P A NOTARY PÙBLIC New York No, 018H6351225 in Nassau Q ualified County Commisalon EMPk•8 11 3 of 4 FILED: QUEENS COUNTY CLERK 12/10/2019 10:18 AM INDEX NO. 704591/2018 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 12/10/2019 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. _________________________ _______________________________________ PLAINTIFF'S FURTHER POST EBT DEMAND FOR DISCOVERY & INSPECTION _________ ________________________ ____________ LAW OFFICE OF COHEN & JAFFE, LLP Attorneys for Plaintiff VINCENT GELZER 2001 Marcus Avenue Lake Success, N.Y. 11042 (516) 358-6900 www.CohenJaffe.com 4 of 4