On July 21, 2021 a
Party Notice
was filed
involving a dispute between
Virgen Torres,
and
Elant At Middlecrest Crossing Housing Development Fund Corp.,
Elant At Middlecrest Crossing Ii Housing Development Fund Corp.,
Middlecrest Crossing Senior Apartments Ii L.P.,
Middlecrest Crossing Senior Apartments Managers Ii Llc,
for Torts - Other Negligence (Trip and Fall)
in the District Court of Orange County.
Preview
FILED: ORANGE COUNTY CLERK 06/24/2022 09:50 AM INDEX NO. EF005129-2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/24/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
.......................... ............ ....... x
VIRGEN TORRES,
Index No: EF005129-2021
Plaintiff,
NOTICE TO PRODUCE
-against-
MIDDLECREST CROSSING SENIOR
APARTMENTS II L.P., MIDDLECREST
CROSSING SENIOR APARTMENTS MANAGERS
II LLC, ELANT AT MIDDLECREST CROSSING
HOUSING DEVELOPMENT FUND CORP. and
ELANT AT MIDDLECREST CROSSING
II HOUSING DEVELOPMENT FUND CORP.
Defendants.
X
PLEASE TAKE NOTICE, that pursuant to CPLR 3101, you are hereby demanded to
serve within twenty (20) days, the following information and material for discovery and inspection
at the ofHce of PATRICK S. OWEN, PLLC, 250 Crystal Run Road, Middletown, New York,
attomey for plaintiff(s):
Pursuant to the testimony of Witness Taja Dabbs:
(1) Photographs taken at or of the accident location by Supt Franciso Burgos.
(2) All estimates and related documents for paying of the parking lot obtained from all
vendors (including but not limited to Mead, Extreme and a Third vendor) for work
to be performed to the parking lot during the five (5) year period prior preceding
the date of the alleged accident.
Dated: Middletown, New York
June 24, 2022
Yours, etc.
PA , C
By:
O 6ULt)S, ES .
Attomey for Plaintiff(s)
250 Crystal Run Road
Middletown, New York 10941
Tel. No.: (845) 692-8000
1 of 3
FILED: ORANGE COUNTY CLERK 06/24/2022 09:50 AM INDEX NO. EF005129-2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/24/2022
TO: PILLINGER MILLER TARALLO, LLP
Attorneys for Defendants
55
555 Taxter Road, Floor
Elmsford, NY 10523
2 of 3
FILED: ORANGE COUNTY CLERK 06/24/2022 09:50 AM INDEX NO. EF005129-2021
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/24/2022
STATE OF NEW YORK )
) ss.:
COUNTY OF ORANGE )
JESSICA PACE, being duly sworn, not a party herein and over the age of eighteen years,
residing in Wappingers Falls, New York, deposes and states the following:
24*
That on the day of June 2022, deponent served a true, accurate and complete copy of
the within NOTICE TO PRODUCE in the following manner:
By mailing the same in a sealed envelope, with postage prepaid thereon, in a post office or
official depository of the U.S. Postal Service within the State of New York, addressed to the last
known address of the addressee(s) as indicated below:
PILLINGER MILLER TARALLO, LLP
Attorneys for Defendants
55
555 Taxter Road, Floor
Elmsford, NY 10523
&
A PACE
Sworn to before me this
24"
day of June 2022.
NOTARY PUBLIC
VEhDMCA M. WESLEY
Notcvy PacLc, State of New York
Ouahfied in Orange County
Regisuation No. 01WE6075427
Commission Expires June 3,20_
3 of 3
Document Filed Date
June 24, 2022
Case Filing Date
July 21, 2021
Category
Torts - Other Negligence (Trip and Fall)
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Preview
FILED: ORANGE COUNTY CLERK 06/24/2022 09:50 AM INDEX NO. EF005129-2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/24/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE .......................... ............ ....... x VIRGEN TORRES, Index No: EF005129-2021 Plaintiff, NOTICE TO PRODUCE -against- MIDDLECREST CROSSING SENIOR APARTMENTS II L.P., MIDDLECREST CROSSING SENIOR APARTMENTS MANAGERS II LLC, ELANT AT MIDDLECREST CROSSING HOUSING DEVELOPMENT FUND CORP. and ELANT AT MIDDLECREST CROSSING II HOUSING DEVELOPMENT FUND CORP. Defendants. X PLEASE TAKE NOTICE, that pursuant to CPLR 3101, you are hereby demanded to serve within twenty (20) days, the following information and material for discovery and inspection at the ofHce of PATRICK S. OWEN, PLLC, 250 Crystal Run Road, Middletown, New York, attomey for plaintiff(s): Pursuant to the testimony of Witness Taja Dabbs: (1) Photographs taken at or of the accident location by Supt Franciso Burgos. (2) All estimates and related documents for paying of the parking lot obtained from all vendors (including but not limited to Mead, Extreme and a Third vendor) for work to be performed to the parking lot during the five (5) year period prior preceding the date of the alleged accident. Dated: Middletown, New York June 24, 2022 Yours, etc. PA , C By: O 6ULt)S, ES . Attomey for Plaintiff(s) 250 Crystal Run Road Middletown, New York 10941 Tel. No.: (845) 692-8000 1 of 3 FILED: ORANGE COUNTY CLERK 06/24/2022 09:50 AM INDEX NO. EF005129-2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/24/2022 TO: PILLINGER MILLER TARALLO, LLP Attorneys for Defendants 55 555 Taxter Road, Floor Elmsford, NY 10523 2 of 3 FILED: ORANGE COUNTY CLERK 06/24/2022 09:50 AM INDEX NO. EF005129-2021 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 06/24/2022 STATE OF NEW YORK ) ) ss.: COUNTY OF ORANGE ) JESSICA PACE, being duly sworn, not a party herein and over the age of eighteen years, residing in Wappingers Falls, New York, deposes and states the following: 24* That on the day of June 2022, deponent served a true, accurate and complete copy of the within NOTICE TO PRODUCE in the following manner: By mailing the same in a sealed envelope, with postage prepaid thereon, in a post office or official depository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressee(s) as indicated below: PILLINGER MILLER TARALLO, LLP Attorneys for Defendants 55 555 Taxter Road, Floor Elmsford, NY 10523 & A PACE Sworn to before me this 24" day of June 2022. NOTARY PUBLIC VEhDMCA M. WESLEY Notcvy PacLc, State of New York Ouahfied in Orange County Regisuation No. 01WE6075427 Commission Expires June 3,20_ 3 of 3