On July 17, 2019 a
Proof of Service
was filed
involving a dispute between
David Marrero,
and
Captain John Thomas
Shield #1120,
City Of New York,
John Does
Correction Officers Whose Names Are Not Yet Known Or Identified,
The New York City Department Of Correction,
for Torts - Other (Assault)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 06/26/2020 02:15 PM INDEX NO. 156979/2019
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 06/26/2020
AFFIRMATION OF SERVICE
Pamela S. Roth, Esq., an attorney duly admitted to practice law before the
Courts of the State of New York, affirms the following under the penalty of
perjury pursuant to C.P.L.R. 2106.
1. I am the attorney of record for the Plaintiff, David Marrero.
2. That on June 26, 2020 your affirmant served the within Request for
Judicial Intervention, Request for a Preliminary Conference; Affirmation of Good
Faith, and Affirmation of Service, upon the parties listed below by mailing a true
copy of the attached papers, enclosed and properly sealed in a postpaid envelope,
which I deposited in an official depository under the exclusive care and custody of
the United States Postal Services within the State of New York addressed to the
following:
SERVED UPON:
ZACHARY W. CARTER
Corporation Counsel
Attorney for Defendants
THE CITY OF NEW YORK, THE CITY OF NEW YORK S/H/A NEW YORK
CITY DEPARTMENT OF CORRECTION
100 Church Street
New York, NY 10007
Law Dept. #2019-054365
"JOHN"
CAPTAIN THOMAS SHIELD #1120
New York City Department of Correction
19"'
Bellevue Prison Ward Floor
Bellevue Hospital Center
462 First Avenue
New York, New York 10016
1 of 3
FILED: NEW YORK COUNTY CLERK 06/26/2020 02:15 PM INDEX NO. 156979/2019
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 06/26/2020
CORRECTION OFFICERS JOHN DOES
New York City Department of Correction
198¹
Bellevue Prison Ward Floor
Bellevue Hospital Center
462 First Avenue
New York, New York 10016
Dated: Brooklyn, New York
June 26, 2020
P mela . Roth, Esq.
2 of 3
FILED: NEW YORK COUNTY CLERK 06/26/2020 02:15 PM INDEX NO. 156979/2019
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 06/26/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX Index No.: 156979/2019
DAVID MARRERO,
Plaintiff,
-against-
CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF
"JOHN" DOES"
CORRECTION, CAPTAIN THOMAS Shield #1120 and "JOHN
(Correction Officers whose names are not yet known or identified),
Defendants.
REQUEST FOR JUDICIAL INTERVENTION & REQUEST FOR A
PRELIMINARY CONFERENCE
LAW OFFICES OF PAMELA S. ROTH, ESQ. P.C.
Attorney for Plaintiff
DAVID MARRERO
Office and Post Office Address, Telephone
2747 Coney Island Avenue
Brooklyn, New York 235
_________
888-466-4884
CERTIFICATION: PAMELA S. ROTH, an attorney duly admitted to practice in
the Courts of the State of New York, states: That I am a member of LAW
OFFICES OF PAMELA S. ROTH, ESQ. P.C., attorneys of record for plaintiff in
the within action. I hereby certify, pursuant to 22 NYCRR 130-1.1(a) and after
forming an inquiry reasonable under the circumstances, that the within Ver éd
Bill of Particulars and its respective contentions, are volous as set rth in
and defined by 22 NYCRR 130-1.1(c).
Dated: June 26, 2020
3 of 3
Document Filed Date
June 26, 2020
Case Filing Date
July 17, 2019
Category
Torts - Other (Assault)
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Preview
FILED: NEW YORK COUNTY CLERK 06/26/2020 02:15 PM INDEX NO. 156979/2019 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 06/26/2020 AFFIRMATION OF SERVICE Pamela S. Roth, Esq., an attorney duly admitted to practice law before the Courts of the State of New York, affirms the following under the penalty of perjury pursuant to C.P.L.R. 2106. 1. I am the attorney of record for the Plaintiff, David Marrero. 2. That on June 26, 2020 your affirmant served the within Request for Judicial Intervention, Request for a Preliminary Conference; Affirmation of Good Faith, and Affirmation of Service, upon the parties listed below by mailing a true copy of the attached papers, enclosed and properly sealed in a postpaid envelope, which I deposited in an official depository under the exclusive care and custody of the United States Postal Services within the State of New York addressed to the following: SERVED UPON: ZACHARY W. CARTER Corporation Counsel Attorney for Defendants THE CITY OF NEW YORK, THE CITY OF NEW YORK S/H/A NEW YORK CITY DEPARTMENT OF CORRECTION 100 Church Street New York, NY 10007 Law Dept. #2019-054365 "JOHN" CAPTAIN THOMAS SHIELD #1120 New York City Department of Correction 19"' Bellevue Prison Ward Floor Bellevue Hospital Center 462 First Avenue New York, New York 10016 1 of 3 FILED: NEW YORK COUNTY CLERK 06/26/2020 02:15 PM INDEX NO. 156979/2019 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 06/26/2020 CORRECTION OFFICERS JOHN DOES New York City Department of Correction 198¹ Bellevue Prison Ward Floor Bellevue Hospital Center 462 First Avenue New York, New York 10016 Dated: Brooklyn, New York June 26, 2020 P mela . Roth, Esq. 2 of 3 FILED: NEW YORK COUNTY CLERK 06/26/2020 02:15 PM INDEX NO. 156979/2019 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 06/26/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX Index No.: 156979/2019 DAVID MARRERO, Plaintiff, -against- CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF "JOHN" DOES" CORRECTION, CAPTAIN THOMAS Shield #1120 and "JOHN (Correction Officers whose names are not yet known or identified), Defendants. REQUEST FOR JUDICIAL INTERVENTION & REQUEST FOR A PRELIMINARY CONFERENCE LAW OFFICES OF PAMELA S. ROTH, ESQ. P.C. Attorney for Plaintiff DAVID MARRERO Office and Post Office Address, Telephone 2747 Coney Island Avenue Brooklyn, New York 235 _________ 888-466-4884 CERTIFICATION: PAMELA S. ROTH, an attorney duly admitted to practice in the Courts of the State of New York, states: That I am a member of LAW OFFICES OF PAMELA S. ROTH, ESQ. P.C., attorneys of record for plaintiff in the within action. I hereby certify, pursuant to 22 NYCRR 130-1.1(a) and after forming an inquiry reasonable under the circumstances, that the within Ver éd Bill of Particulars and its respective contentions, are volous as set rth in and defined by 22 NYCRR 130-1.1(c). Dated: June 26, 2020 3 of 3