On December 24, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Debra Jeronimo,
and
City Of New York,
Consolidated Edison, Inc.,
Lutheran Medicalcenter,
Nyu Langone Hospitals,
for Torts - Other (Trip and Fall)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 09/06/2022 10:11 AM INDEX NO. 525864/2020
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 09/06/2022
LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC
Michael S. Lamonsoff,Esq.co Romina Tominovic, Esq.
Beth Kirschner,Esq.o Ryan Sharp,Esq. oo"
Esq.* *
Stacey Haskel, Jason Lesnevec, Esq.
Maya Kogan, Esq.*o Michael Zagala,Esq. as
Jazmine Kendrick,Esq.0 Ryan Charder, Esq. co
DanielleBates, Esq.o
Jacob S. Traub,Esq.oo-^oo-
Of Counsel
oS.D.N.Y. Darren T. Moore,Esq.
David Carr,Esq.
Deborah Eddy, Esq.
Sc re it Cou ofAppeals JessicaMassimÃ, Esq.
February 18, 2022
Ahimmel@law.nyc.gov
Mr. James E, Johnson
Corporation Counsel
100 Church Street
New York, NY 10007
Re: Debra Jeronimo
Index No: 525864/2020
D/A: May 19, 2020
Our File No. 30005
Dear Counselor:
I am reaching out to you regarding outstanding discovery in this matter. To date my office has not receive a
response to our Notice for Discovery and Inspection and Combined Demands served on Defendant May 24, 2021.
Pursuant to the Court Order dated July 19, 2021 your office was given 90 days to furnish responses as well as
additional information that was enumerated within the Court Order. My office has yet to receive any ofthis discovery,
Please accept this as a good faith attempt in obtaining this Court Ordered discovery.
If you should have any questions, please do not hesitate to contact our office.
tr - ur
Very ,
Document Filed Date
September 06, 2022
Case Filing Date
December 24, 2020
Category
Torts - Other (Trip and Fall)
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Preview
FILED: KINGS COUNTY CLERK 09/06/2022 10:11 AM INDEX NO. 525864/2020 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 09/06/2022 LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC Michael S. Lamonsoff,Esq.co Romina Tominovic, Esq. Beth Kirschner,Esq.o Ryan Sharp,Esq. oo" Esq.* * Stacey Haskel, Jason Lesnevec, Esq. Maya Kogan, Esq.*o Michael Zagala,Esq. as Jazmine Kendrick,Esq.0 Ryan Charder, Esq. co DanielleBates, Esq.o Jacob S. Traub,Esq.oo-^oo- Of Counsel oS.D.N.Y. Darren T. Moore,Esq. David Carr,Esq. Deborah Eddy, Esq. Sc re it Cou ofAppeals JessicaMassimÃ, Esq. February 18, 2022 Ahimmel@law.nyc.gov Mr. James E, Johnson Corporation Counsel 100 Church Street New York, NY 10007 Re: Debra Jeronimo Index No: 525864/2020 D/A: May 19, 2020 Our File No. 30005 Dear Counselor: I am reaching out to you regarding outstanding discovery in this matter. To date my office has not receive a response to our Notice for Discovery and Inspection and Combined Demands served on Defendant May 24, 2021. Pursuant to the Court Order dated July 19, 2021 your office was given 90 days to furnish responses as well as additional information that was enumerated within the Court Order. My office has yet to receive any ofthis discovery, Please accept this as a good faith attempt in obtaining this Court Ordered discovery. If you should have any questions, please do not hesitate to contact our office. tr - ur Very ,