On December 24, 2020 a
Summons
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.
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FILED: KINGS COUNTY CLERK 08/16/2022 04:26 PM INDEX NO. 525864/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 08/16/2022
SUPPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_____________________________________Ç
DEBRA JERONIMO, Index No.: 525864/2020
Plaintiff,
- against - NOTICE OF MOTION TO
SUPPLEMENT SUMMONS
CITY OF NEW LUTHERAN MEDICAL
AND AMEND CAPTION
YORK,
CENTER, AND NYU LANGONE HOSPITALS,
Defendants.
___________.------_________________Ç
PLEASE TAKE NOTICE, that upon the annexed affirmation of WILLIAM J.
THONUS, ESQ., duly affirmed on August 8, 2022, together with the exhibits annexed thereto,
and upon all the pleadings and proceedings heretofore had herein, the undersigned will move this
Court at the IAS Motion Submission Part of the Courthouse located at 360 Adams Street,
Brooldyn, New York on the September 7, 2022, at 9:30 AM, in the forenoon of that day or as
soon thereafter as counsel can be heard for an Order:
a) Pursuant to CPLR §3025(b) granting Plaintiff leave to file a
Supplemental Summons and Amended Complaint to include
CONSOLIDATED EDISON, INC. as an additional Defendant in
this action.
b) Amending the complaint to reflect the additional allegations against
CONSOLIDATED EDISON, INC., and
c) For such other and further relief as this Court seems just and proper.
PLEASE TAKE FURTHER NOTICE, pursuant to CPLR § 2214(b), answering
affidavits, if any, must be served upon the undersigned at least seven (7) days prior to the return
date of this motion.
1 of 2
FILED: KINGS COUNTY CLERK 08/16/2022 04:26 PM INDEX NO. 525864/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 08/16/2022
Dated: New York, New York
August 12, 2022
Yours, etc.
WILLIAM J. THONUS, ESQ.
LAW OFFICES OF
MICHAEL S. LAMONSOFF, PLLC
Attorneys for Plaintiff
DEBRA JERONIMO
80'
Financial Square at 32 Old Slip, Floor
New York, New York 10005
(212) 962-1020
File No.: 30005
TO:
HEIDELL, PITTONI, MURPHY & BACH, LLP
Attorneys for Defendant
NYU LANGONE HOSPITAL and
LUTHERAN MEDICAL CENTER
99 Park Avenue
New York, NY 10005
JAMES E. JOHNSON
Corporation Counsel
Attorneys for Defendant
CITY OF NEW YORK
100 Church Street
New York, NY 10007
2 of 2
Document Filed Date
August 16, 2022
Case Filing Date
December 24, 2020
Category
Torts - Other (Trip and Fall)
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FILED: KINGS COUNTY CLERK 08/16/2022 04:26 PM INDEX NO. 525864/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 08/16/2022 SUPPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS _____________________________________Ç DEBRA JERONIMO, Index No.: 525864/2020 Plaintiff, - against - NOTICE OF MOTION TO SUPPLEMENT SUMMONS CITY OF NEW LUTHERAN MEDICAL AND AMEND CAPTION YORK, CENTER, AND NYU LANGONE HOSPITALS, Defendants. ___________.------_________________Ç PLEASE TAKE NOTICE, that upon the annexed affirmation of WILLIAM J. THONUS, ESQ., duly affirmed on August 8, 2022, together with the exhibits annexed thereto, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move this Court at the IAS Motion Submission Part of the Courthouse located at 360 Adams Street, Brooldyn, New York on the September 7, 2022, at 9:30 AM, in the forenoon of that day or as soon thereafter as counsel can be heard for an Order: a) Pursuant to CPLR §3025(b) granting Plaintiff leave to file a Supplemental Summons and Amended Complaint to include CONSOLIDATED EDISON, INC. as an additional Defendant in this action. b) Amending the complaint to reflect the additional allegations against CONSOLIDATED EDISON, INC., and c) For such other and further relief as this Court seems just and proper. PLEASE TAKE FURTHER NOTICE, pursuant to CPLR § 2214(b), answering affidavits, if any, must be served upon the undersigned at least seven (7) days prior to the return date of this motion. 1 of 2 FILED: KINGS COUNTY CLERK 08/16/2022 04:26 PM INDEX NO. 525864/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 08/16/2022 Dated: New York, New York August 12, 2022 Yours, etc. WILLIAM J. THONUS, ESQ. LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC Attorneys for Plaintiff DEBRA JERONIMO 80' Financial Square at 32 Old Slip, Floor New York, New York 10005 (212) 962-1020 File No.: 30005 TO: HEIDELL, PITTONI, MURPHY & BACH, LLP Attorneys for Defendant NYU LANGONE HOSPITAL and LUTHERAN MEDICAL CENTER 99 Park Avenue New York, NY 10005 JAMES E. JOHNSON Corporation Counsel Attorneys for Defendant CITY OF NEW YORK 100 Church Street New York, NY 10007 2 of 2