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  • Debra Jeronimo v. City Of New York, Lutheran Medicalcenter, Nyu Langone Hospitals, Consolidated Edison, Inc.Torts - Other (Trip and Fall) document preview
  • Debra Jeronimo v. City Of New York, Lutheran Medicalcenter, Nyu Langone Hospitals, Consolidated Edison, Inc.Torts - Other (Trip and Fall) document preview
  • Debra Jeronimo v. City Of New York, Lutheran Medicalcenter, Nyu Langone Hospitals, Consolidated Edison, Inc.Torts - Other (Trip and Fall) document preview
  • Debra Jeronimo v. City Of New York, Lutheran Medicalcenter, Nyu Langone Hospitals, Consolidated Edison, Inc.Torts - Other (Trip and Fall) document preview
						
                                

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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