Party Discovery: Peter Vesce, Audrey Vesce v. Richmond Medical Center D/B/A Richmond Universtiy Medical Center

• 
• 

						
                                
Preview
                                FILED:         RICHMOND           COUNTY        CLERK        08/09/2022             10:17        AM                 INDEX    NO.   151760/2021
   NYSCEF     DOC.   NO.   16                                                                                 RECEIVED      NYSCEF:     08/09/2022




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF RICHMOND
                  -------------------------------------------------------------------X
                  PETER VESCE and AUDREY VESCE,                                            Index No. 151760/2021

                                                               Plaintiffs,                 NOTICE TO TAKE
                                                -against-                                  DEPOSITION

                  RICHMOND              MEDICAL             CENTER            d/b/a
                  RICHMOND UNIVERSITY MEDICAL CENTER,

                                                               Defendant.
                  -------------------------------------------------------------------X


                           PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and Rules,

                  the deposition upon oral examination of all adverse parties will be taken before a notary public

                  who is not a person who would be disqualified to act as a juror because of interest or because of

                  blood   relationship,   kinship   or  close   agreement    to  any  party   herein.  The   deposition(s)    will  be

                  conducted at a time and place mutually agreed-upon at the preliminary conference of this matter,

                  with respect to evidence and material necessary in the defense of this action, concerning all of the

                  relevant facts and circumstances in connection with the incident that is the subject of this action.


                  Dated:   August 9, 2022
                           Staten Island, New York
                                                                        Scamardella, Gervasi, & Kasegrande, P.C.
                                                                        Attorneys for Plaintiffs
                                                                        PETER VESCE and AUDREY VESCE
                                                                        1010 Forest Avenue
                                                                        Staten Island, New York 10310-2415
                                                                        (718) 442-0900
                  TO:
                  Vaslas Lepowsky & Hauss LLP
                  Attorneys for Defendant
                  RICHMOND MEDICAL CENTER d/b/a
                  RICHMOND UNIVERSITY MEDICAL CENTER
                  201 Edward Curry Avenue, Suite 100
                  Staten Island, New York 10314
                  (718) 761-9300
                                                                            1


                                                                        1  of   1