Preview
FILED: KINGS COUNTY CLERK 10/15/2020 11:31 AM INDEX NO. 528159/2019
NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 10/15/2020
EXHIBIT “B”
FILED: KINGS COUNTY CLERK 09/10/2020
10/15/2020 10:36
11:31 AM INDEX NO. 528159/2019
NYSCEF DOC. NO. 19
34 RECEIVED NYSCEF: 09/10/2020
10/15/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------x Index No. 528159/19E
NADIA GRIFFITH
Plaintiff,
NOTICE FOR
-against- DISCOVERY AND
INSPECTION
LAGUARDIA CORPORATE CENTER ASSOCIATES,
BLUMENFELD DEVELOPMENT GROUP;
PROCLEAN MAINTENANCE SYSTEMS; and
CAPITAL CONTRACTORS, INC.,
Defendants.
----------------------------------------------------x
PLEASE TAKE NOTICE, that pursuant to the provisions of the CPLR the
undersigned demands that the co-defendant, PROCLEAN MAINTENANCE
SYSTEMS produce and permit the undersigned to inspect and to copy the
following documents within twenty (20) days:
1. Copies of all contracts between Capital Contractors, Inc. and
Proclean Maintenance Systems in effect on January 24, 2017 for the building
located at 75-20 Astoria Boulevard, Queens, New York.
2. All incident reports, accident reports, photographs, written
documents or communications regarding plaintiff’s alleged accident on
January 24, 2017.
3. Any and all sign in sheets and records for ProClean employees
from January 24, 2017 and one week before.
4. Names of managers/foremen on duty on January 24, 2017 and
last known address/contact information if he/she is no longer employed by
ProClean.
5. Any and all written communications from ProClean to any other
entity regarding the cleaning of the stairwell at 75-20 Astoria Boulevard,
Queens, New York from January 1, 2017 until January 24, 2017.
6. Any and all written schedules for ProClean Maintenance Systems
in effect on January 24, 2017 for the building located at 75-20 Astoria
Boulevard, Queens, New York.
1 of 3
FILED: KINGS COUNTY CLERK 09/10/2020
10/15/2020 10:36
11:31 AM INDEX NO. 528159/2019
NYSCEF DOC. NO. 19
34 RECEIVED NYSCEF: 09/10/2020
10/15/2020
7. List or documentation showing the equipment used for cleaning
the North stairs by ProClean at 75-20 Astoria Boulevard on January 24, 2017.
PLEASE TAKE FURTHER NOTICE, that in the event of your failure to
comply with this notice, that the undersigned may move to preclude you from
introducing into evidence and for otherwise using each aforementioned item
for any purpose whatsoever, upon the trial of this action.
Dated: New York, New York
September 8, 2020
Yours,
LAW OFFICES OF
MICHAEL E. PRESSMAN
Attorneys for Defendants
BLUMENFELD DEVELOPMENT
GROUP and LAGUARDIA
CORPORATE CENTER ASSOCIATES
th
125 Maiden Lane, 17 Floor
New York, New York 10038
(212) 480-3030
File No.: CAT 16311
MEP/adh/966767
TO:
G. WESLEY SIMPSON, P.C.
Attorneys for Plaintiff
NADIA GRIFFITH
1016 Ralph Avenue, 1st floor
Brooklyn, New York 11236
(718) 345-8213
CORREA, KING, MCGINNIS & LIFERIEDGE
Attorneys for Defendants
CAPITAL CONTRACTORS, INC.
One Battery Park Plaza, 29th floor
New York, N.Y. 10004-1437
(212) 709-3161
HAWORTH BARBER & GERSTMAN, LLC
BARRY GERSTMAN, ESQ.
Attorneys for Defendant
PROCLEAN MAINTENANCE SYSTEMS
45 Broadway, Suite 2110
2 of 3
FILED: KINGS COUNTY CLERK 09/10/2020
10/15/2020 10:36
11:31 AM INDEX NO. 528159/2019
NYSCEF DOC. NO. 19
34 RECEIVED NYSCEF: 09/10/2020
10/15/2020
New York, NY 10006
(212) 952-1100
Barry.Gerstman@hbandglaw.com
R I D E R
G. WESLEY SIMPSON, P.C.
Attorneys for Plaintiff
NADIA GRIFFITH
1016 Ralph Avenue, 1st floor
Brooklyn, New York 11236
(718) 345-8213
CORREA, KING, MCGINNIS & LIFERIEDGE
Attorneys for Defendants
CAPITAL CONTRACTORS, INC.
One Battery Park Plaza, 29th floor
New York, N.Y. 10004-1437
(212) 709-3161
HAWORTH BARBER & GERSTMAN, LLC
BARRY GERSTMAN, ESQ.
Attorneys for Defendant
PROCLEAN MAINTENANCE SYSTEMS
45 Broadway, Suite 2110
New York, NY 10006
(212) 952-1100
Barry.Gerstman@hbandglaw.com
3 of 3
FILED: KINGS COUNTY CLERK 09/10/2020
10/15/2020 10:36
11:31 AM INDEX NO. 528159/2019
NYSCEF DOC. NO. 20
34 RECEIVED NYSCEF: 09/10/2020
10/15/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------x Index No. 528159/19E
NADIA GRIFFITH
Plaintiff,
NOTICE FOR
-against- DISCOVERY AND
INSPECTION
LAGUARDIA CORPORATE CENTER ASSOCIATES,
BLUMENFELD DEVELOPMENT GROUP;
PROCLEAN MAINTENANCE SYSTEMS; and
CAPITAL CONTRACTORS, INC.,
Defendants.
----------------------------------------------------x
PLEASE TAKE NOTICE, that pursuant to the provisions of the CPLR the
undersigned demands that the co-defendant, CAPITAL CONTRACTORS, INC.
produce and permit the undersigned to inspect and to copy the following
documents within twenty (20) days:
1. Copies of all contracts between Capital Contractors, Inc. and
Proclean Maintenance Systems in effect on January 24, 2017 for the building
located at 75-20 Astoria Boulevard, Queens, New York.
2. All incident reports, accident reports, photographs, written
documents or communications regarding plaintiff’s alleged accident on
January 24, 2017.
3. Any and all sign in sheets and records for ProClean employees
from January 24, 2017 and one week before.
4. Names of managers/foremen on duty on January 24, 2017 and
last known address/contact information if he/she is no longer employed by
ProClean.
5. Any and all written communications from ProClean to any other
entity regarding the cleaning of the stairwell at 75-20 Astoria Boulevard,
Queens, New York from January 1, 2017 until January 24, 2017.
6. Any and all written schedules for ProClean Maintenance Systems
in effect on January 24, 2017 for the building located at 75-20 Astoria
Boulevard, Queens, New York.
1 of 3
FILED: KINGS COUNTY CLERK 09/10/2020
10/15/2020 10:36
11:31 AM INDEX NO. 528159/2019
NYSCEF DOC. NO. 20
34 RECEIVED NYSCEF: 09/10/2020
10/15/2020
7. List or documentation showing the equipment used for cleaning
the North stairs by ProClean at 75-20 Astoria Boulevard on January 24, 2017.
PLEASE TAKE FURTHER NOTICE, that in the event of your failure to
comply with this notice, that the undersigned may move to preclude you from
introducing into evidence and for otherwise using each aforementioned item
for any purpose whatsoever, upon the trial of this action.
Dated: New York, New York
September 8, 2020
Yours,
LAW OFFICES OF
MICHAEL E. PRESSMAN
Attorneys for Defendants
BLUMENFELD DEVELOPMENT
GROUP and LAGUARDIA
CORPORATE CENTER ASSOCIATES
th
125 Maiden Lane, 17 Floor
New York, New York 10038
(212) 480-3030
File No.: CAT 16311
MEP/adh/966767
TO:
G. WESLEY SIMPSON, P.C.
Attorneys for Plaintiff
NADIA GRIFFITH
1016 Ralph Avenue, 1st floor
Brooklyn, New York 11236
(718) 345-8213
CORREA, KING, MCGINNIS & LIFERIEDGE
Attorneys for Defendants
CAPITAL CONTRACTORS, INC.
One Battery Park Plaza, 29th floor
New York, N.Y. 10004-1437
(212) 709-3161
HAWORTH BARBER & GERSTMAN, LLC
BARRY GERSTMAN, ESQ.
Attorneys for Defendant
PROCLEAN MAINTENANCE SYSTEMS
45 Broadway, Suite 2110
2 of 3
FILED: KINGS COUNTY CLERK 09/10/2020
10/15/2020 10:36
11:31 AM INDEX NO. 528159/2019
NYSCEF DOC. NO. 20
34 RECEIVED NYSCEF: 09/10/2020
10/15/2020
New York, NY 10006
(212) 952-1100
Barry.Gerstman@hbandglaw.com
R I D E R
G. WESLEY SIMPSON, P.C.
Attorneys for Plaintiff
NADIA GRIFFITH
1016 Ralph Avenue, 1st floor
Brooklyn, New York 11236
(718) 345-8213
CORREA, KING, MCGINNIS & LIFERIEDGE
Attorneys for Defendants
CAPITAL CONTRACTORS, INC.
One Battery Park Plaza, 29th floor
New York, N.Y. 10004-1437
(212) 709-3161
HAWORTH BARBER & GERSTMAN, LLC
BARRY GERSTMAN, ESQ.
Attorneys for Defendant
PROCLEAN MAINTENANCE SYSTEMS
45 Broadway, Suite 2110
New York, NY 10006
(212) 952-1100
Barry.Gerstman@hbandglaw.com
3 of 3
Preview
FILED: KINGS COUNTY CLERK 10/15/2020 11:31 AM INDEX NO. 528159/2019 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 10/15/2020 EXHIBIT “B” FILED: KINGS COUNTY CLERK 09/10/2020 10/15/2020 10:36 11:31 AM INDEX NO. 528159/2019 NYSCEF DOC. NO. 19 34 RECEIVED NYSCEF: 09/10/2020 10/15/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------x Index No. 528159/19E NADIA GRIFFITH Plaintiff, NOTICE FOR -against- DISCOVERY AND INSPECTION LAGUARDIA CORPORATE CENTER ASSOCIATES, BLUMENFELD DEVELOPMENT GROUP; PROCLEAN MAINTENANCE SYSTEMS; and CAPITAL CONTRACTORS, INC., Defendants. ----------------------------------------------------x PLEASE TAKE NOTICE, that pursuant to the provisions of the CPLR the undersigned demands that the co-defendant, PROCLEAN MAINTENANCE SYSTEMS produce and permit the undersigned to inspect and to copy the following documents within twenty (20) days: 1. Copies of all contracts between Capital Contractors, Inc. and Proclean Maintenance Systems in effect on January 24, 2017 for the building located at 75-20 Astoria Boulevard, Queens, New York. 2. All incident reports, accident reports, photographs, written documents or communications regarding plaintiff’s alleged accident on January 24, 2017. 3. Any and all sign in sheets and records for ProClean employees from January 24, 2017 and one week before. 4. Names of managers/foremen on duty on January 24, 2017 and last known address/contact information if he/she is no longer employed by ProClean. 5. Any and all written communications from ProClean to any other entity regarding the cleaning of the stairwell at 75-20 Astoria Boulevard, Queens, New York from January 1, 2017 until January 24, 2017. 6. Any and all written schedules for ProClean Maintenance Systems in effect on January 24, 2017 for the building located at 75-20 Astoria Boulevard, Queens, New York. 1 of 3 FILED: KINGS COUNTY CLERK 09/10/2020 10/15/2020 10:36 11:31 AM INDEX NO. 528159/2019 NYSCEF DOC. NO. 19 34 RECEIVED NYSCEF: 09/10/2020 10/15/2020 7. List or documentation showing the equipment used for cleaning the North stairs by ProClean at 75-20 Astoria Boulevard on January 24, 2017. PLEASE TAKE FURTHER NOTICE, that in the event of your failure to comply with this notice, that the undersigned may move to preclude you from introducing into evidence and for otherwise using each aforementioned item for any purpose whatsoever, upon the trial of this action. Dated: New York, New York September 8, 2020 Yours, LAW OFFICES OF MICHAEL E. PRESSMAN Attorneys for Defendants BLUMENFELD DEVELOPMENT GROUP and LAGUARDIA CORPORATE CENTER ASSOCIATES th 125 Maiden Lane, 17 Floor New York, New York 10038 (212) 480-3030 File No.: CAT 16311 MEP/adh/966767 TO: G. WESLEY SIMPSON, P.C. Attorneys for Plaintiff NADIA GRIFFITH 1016 Ralph Avenue, 1st floor Brooklyn, New York 11236 (718) 345-8213 CORREA, KING, MCGINNIS & LIFERIEDGE Attorneys for Defendants CAPITAL CONTRACTORS, INC. One Battery Park Plaza, 29th floor New York, N.Y. 10004-1437 (212) 709-3161 HAWORTH BARBER & GERSTMAN, LLC BARRY GERSTMAN, ESQ. Attorneys for Defendant PROCLEAN MAINTENANCE SYSTEMS 45 Broadway, Suite 2110 2 of 3 FILED: KINGS COUNTY CLERK 09/10/2020 10/15/2020 10:36 11:31 AM INDEX NO. 528159/2019 NYSCEF DOC. NO. 19 34 RECEIVED NYSCEF: 09/10/2020 10/15/2020 New York, NY 10006 (212) 952-1100 Barry.Gerstman@hbandglaw.com R I D E R G. WESLEY SIMPSON, P.C. Attorneys for Plaintiff NADIA GRIFFITH 1016 Ralph Avenue, 1st floor Brooklyn, New York 11236 (718) 345-8213 CORREA, KING, MCGINNIS & LIFERIEDGE Attorneys for Defendants CAPITAL CONTRACTORS, INC. One Battery Park Plaza, 29th floor New York, N.Y. 10004-1437 (212) 709-3161 HAWORTH BARBER & GERSTMAN, LLC BARRY GERSTMAN, ESQ. Attorneys for Defendant PROCLEAN MAINTENANCE SYSTEMS 45 Broadway, Suite 2110 New York, NY 10006 (212) 952-1100 Barry.Gerstman@hbandglaw.com 3 of 3 FILED: KINGS COUNTY CLERK 09/10/2020 10/15/2020 10:36 11:31 AM INDEX NO. 528159/2019 NYSCEF DOC. NO. 20 34 RECEIVED NYSCEF: 09/10/2020 10/15/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------x Index No. 528159/19E NADIA GRIFFITH Plaintiff, NOTICE FOR -against- DISCOVERY AND INSPECTION LAGUARDIA CORPORATE CENTER ASSOCIATES, BLUMENFELD DEVELOPMENT GROUP; PROCLEAN MAINTENANCE SYSTEMS; and CAPITAL CONTRACTORS, INC., Defendants. ----------------------------------------------------x PLEASE TAKE NOTICE, that pursuant to the provisions of the CPLR the undersigned demands that the co-defendant, CAPITAL CONTRACTORS, INC. produce and permit the undersigned to inspect and to copy the following documents within twenty (20) days: 1. Copies of all contracts between Capital Contractors, Inc. and Proclean Maintenance Systems in effect on January 24, 2017 for the building located at 75-20 Astoria Boulevard, Queens, New York. 2. All incident reports, accident reports, photographs, written documents or communications regarding plaintiff’s alleged accident on January 24, 2017. 3. Any and all sign in sheets and records for ProClean employees from January 24, 2017 and one week before. 4. Names of managers/foremen on duty on January 24, 2017 and last known address/contact information if he/she is no longer employed by ProClean. 5. Any and all written communications from ProClean to any other entity regarding the cleaning of the stairwell at 75-20 Astoria Boulevard, Queens, New York from January 1, 2017 until January 24, 2017. 6. Any and all written schedules for ProClean Maintenance Systems in effect on January 24, 2017 for the building located at 75-20 Astoria Boulevard, Queens, New York. 1 of 3 FILED: KINGS COUNTY CLERK 09/10/2020 10/15/2020 10:36 11:31 AM INDEX NO. 528159/2019 NYSCEF DOC. NO. 20 34 RECEIVED NYSCEF: 09/10/2020 10/15/2020 7. List or documentation showing the equipment used for cleaning the North stairs by ProClean at 75-20 Astoria Boulevard on January 24, 2017. PLEASE TAKE FURTHER NOTICE, that in the event of your failure to comply with this notice, that the undersigned may move to preclude you from introducing into evidence and for otherwise using each aforementioned item for any purpose whatsoever, upon the trial of this action. Dated: New York, New York September 8, 2020 Yours, LAW OFFICES OF MICHAEL E. PRESSMAN Attorneys for Defendants BLUMENFELD DEVELOPMENT GROUP and LAGUARDIA CORPORATE CENTER ASSOCIATES th 125 Maiden Lane, 17 Floor New York, New York 10038 (212) 480-3030 File No.: CAT 16311 MEP/adh/966767 TO: G. WESLEY SIMPSON, P.C. Attorneys for Plaintiff NADIA GRIFFITH 1016 Ralph Avenue, 1st floor Brooklyn, New York 11236 (718) 345-8213 CORREA, KING, MCGINNIS & LIFERIEDGE Attorneys for Defendants CAPITAL CONTRACTORS, INC. One Battery Park Plaza, 29th floor New York, N.Y. 10004-1437 (212) 709-3161 HAWORTH BARBER & GERSTMAN, LLC BARRY GERSTMAN, ESQ. Attorneys for Defendant PROCLEAN MAINTENANCE SYSTEMS 45 Broadway, Suite 2110 2 of 3 FILED: KINGS COUNTY CLERK 09/10/2020 10/15/2020 10:36 11:31 AM INDEX NO. 528159/2019 NYSCEF DOC. NO. 20 34 RECEIVED NYSCEF: 09/10/2020 10/15/2020 New York, NY 10006 (212) 952-1100 Barry.Gerstman@hbandglaw.com R I D E R G. WESLEY SIMPSON, P.C. Attorneys for Plaintiff NADIA GRIFFITH 1016 Ralph Avenue, 1st floor Brooklyn, New York 11236 (718) 345-8213 CORREA, KING, MCGINNIS & LIFERIEDGE Attorneys for Defendants CAPITAL CONTRACTORS, INC. One Battery Park Plaza, 29th floor New York, N.Y. 10004-1437 (212) 709-3161 HAWORTH BARBER & GERSTMAN, LLC BARRY GERSTMAN, ESQ. Attorneys for Defendant PROCLEAN MAINTENANCE SYSTEMS 45 Broadway, Suite 2110 New York, NY 10006 (212) 952-1100 Barry.Gerstman@hbandglaw.com 3 of 3