On June 13, 2019 a
Party Discovery
was filed
involving a dispute between
Kathleen Fayo Adm,
Marion Fayo Est Of,
and
Northern Riverview Health Care Center, Inc.,
for Torts - Other (Nursing Home)
in the District Court of Rockland County.
Preview
FILED: ROCKLAND COUNTY CLERK 09/27/2019 11:56 AM INDEX NO. 033087/2019
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 09/27/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
---------------..----------------------- X
MARION FAYO, Deceased, by and through : Index No.: 033087/2019
KATHLEEN FAYO, as Proposed Administrator of the ,
Estate of MARION FAYO, : NOTICE TO'TAKE
DEPOSITION UPON
Plaintiff, : ORAL EXAMINATION
-against- :
NORTHERN RIVERVIEW HEALTH CARE :
CENTER, INC.,
:
Defendant.
S I R S:
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and
Rules, the testimony, upon oral examination of Kathleen Fayo, will be taken before a Notary
Public who is not an attorney, or employee of an attorney, for any party or prospective party
herein and is not a person who would be disqualified to act as a juror because of interest or
because of consanguinity or affinity to any party herein, at a place to be determined on
December 16, 2019 at 10:00 o'clock in the forenoon of that day with respect to evidence and
material necessary in the defense of this action.
7930065v.1
1 of 2
FILED: ROCKLAND COUNTY CLERK 09/27/2019 11:56 AM INDEX NO. 033087/2019
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 09/27/2019
That the said person to be examined are required to produce at such examination any and
all documents relative to the claims in the plaintiff's Complaint.
Dated: White Plains, New York
September 27, 2019
Yours, etc.,
WILSON, ELSER, MOSKOWITZ, EDELMAN
& DICKEl P
Dena Operman, Esq.
Attorneys for Defendant,
NORTHERN RIVERVIEW HEALTHCARE
CENTER s/h/a NORTHERN RIVERVIEW
HEALTH CARE CENTER, INC.
1133 Westchester Avenue
White Plains, New York 10604
(914) 323-7000
File No.: 09824.00934
TO: FINKELSTEIN & PARTNERS, LLP
Mary Ellen Wright, Esq.
Attorneys for Plaintiff
1279 Route 300, PO Box 1111
Newburgh, New York 12551
(845) 563-9545
- 2 -
7930065v.1
2 of 2
Document Filed Date
September 27, 2019
Case Filing Date
June 13, 2019
Category
Torts - Other (Nursing Home)
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Preview
FILED: ROCKLAND COUNTY CLERK 09/27/2019 11:56 AM INDEX NO. 033087/2019 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 09/27/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND ---------------..----------------------- X MARION FAYO, Deceased, by and through : Index No.: 033087/2019 KATHLEEN FAYO, as Proposed Administrator of the , Estate of MARION FAYO, : NOTICE TO'TAKE DEPOSITION UPON Plaintiff, : ORAL EXAMINATION -against- : NORTHERN RIVERVIEW HEALTH CARE : CENTER, INC., : Defendant. S I R S: PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony, upon oral examination of Kathleen Fayo, will be taken before a Notary Public who is not an attorney, or employee of an attorney, for any party or prospective party herein and is not a person who would be disqualified to act as a juror because of interest or because of consanguinity or affinity to any party herein, at a place to be determined on December 16, 2019 at 10:00 o'clock in the forenoon of that day with respect to evidence and material necessary in the defense of this action. 7930065v.1 1 of 2 FILED: ROCKLAND COUNTY CLERK 09/27/2019 11:56 AM INDEX NO. 033087/2019 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 09/27/2019 That the said person to be examined are required to produce at such examination any and all documents relative to the claims in the plaintiff's Complaint. Dated: White Plains, New York September 27, 2019 Yours, etc., WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKEl P Dena Operman, Esq. Attorneys for Defendant, NORTHERN RIVERVIEW HEALTHCARE CENTER s/h/a NORTHERN RIVERVIEW HEALTH CARE CENTER, INC. 1133 Westchester Avenue White Plains, New York 10604 (914) 323-7000 File No.: 09824.00934 TO: FINKELSTEIN & PARTNERS, LLP Mary Ellen Wright, Esq. Attorneys for Plaintiff 1279 Route 300, PO Box 1111 Newburgh, New York 12551 (845) 563-9545 - 2 - 7930065v.1 2 of 2