On May 24, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Daj Realty, Llc,
and
37 Crosby Realty Llc,
Aleksander Levin,
Brent M. Porter Architect, Pllc,
Brent M. Porter Architects And Associates,
Brent Porter,
Engineering Group Associates, P.C.,
Gennady Saratovsky,
Integrity Consulting Service, Inc.,
New York Construction & Renovation, Inc.,
for Torts - Other Negligence (Negligence/Malpractice)
in the District Court of New York County.
Preview
. . .....
FILED: NEW YORK COUNTY CLERK 07/25/2018 09:23 AM INDEX NO. 154824/2017
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 07/25/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
——————————
-------------------------------------------------------------X —- —
DAJ REALTY, LLC,
NOTICE OF MOTION
Plaintiff,
Index 0 154824/17
-against-
37 CROSBY REALTY LLC, NEW YORK
CONSTRUCTION & RENOVATION, INC.,
ENGINEERING GROUP ASSOCIATES, P.C.,
GENNADY SARATOVSKY, P.E., INTEGRITY
CONSULTING SERVICE, INC., ALEKSANDER
LEVIN, P.E., BRENT M. PORTER ARCHITECTS
AND ASSOCIATES, BRENT M. PORTER
ARCHITECT, PLLC and BRENT PORTER, R.A.,
Defendants.
----··-------------··----------------------------------------------··---X
PLEASE TAKE NOTICE, that upon the annexed affirmation of JONATHAN PIROG,
dated, July 24, 2018 and upon all the pleadings and proceedings heretofore had herein, the
undersigned will move this Court before the assigned Justice of the Court thereof, to be held at
24d'
the courthouse located at 60 Center Street, Room 130, New York, NY, on the day of
o'
August 2018, at 9:30 clock in the forenoon of that day or as soon thereafter as counsel can be
heard for an Order pursuant to CPLR 3124 directing the Plaintiff and Defendants to comply with
the Discovery Demands that was served on said attorney and for such other and further relief as
to the Court may seem just and proper.
A Note ofhas not yet been filed in this action.
An affirmation that a good faith effort has been made to resolve the issues raised in this
motion is annexed hereto,
1 of 2
. . . ..
FILED: NEW YORK COUNTY CLERK 07/25/2018 09:23 AM INDEX NO. 154824/2017
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 07/25/2018
PLEASE TAKE FURTHER NOTICE, that any and all answering affidavits must be
served within seven (7) days prior to the return date of this motion.
Dated: Melville, NY
July 24, 2018
Yours, etc.
LAW OFFICE OF MICHAEL C. TROMELLO
Attorneys for Defendants
BRENT PORTER, R.A., BRENT M. PORTER
ARCHITECT, PLLC and BRENT M. PORTER
ARCHITECTS AND ASSOCIATES
395 North Service Road
P.O. Box 9038
Melville, NY 11747
631-577 0
By:
J . THAN PIlf€fG
To:
ZETLIN & DE CHIARA, LLP
Attorney for Plaintiff
DAJ REALTY, LLC
801 Second Avenue
New York, NY 10017
212-682-6800
BYRNE & O'NEILL, LLP
Attorney for INTEGRITY CONSULTING SERVICE, INC. ALEKSANDER LEVIN, P.E.
11 Broadway, Suite 910
NY, NY 10004-1314
212-422-9424
CLARK & FOX
Attorney for 37 CROSBY REALTY, LLC
404 5th Avenue, 3rd floor
New York, New York 10018
646 506 3048
2 of 2
Preview
. . ..... FILED: NEW YORK COUNTY CLERK 07/25/2018 09:23 AM INDEX NO. 154824/2017 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 07/25/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK —————————— -------------------------------------------------------------X —- — DAJ REALTY, LLC, NOTICE OF MOTION Plaintiff, Index 0 154824/17 -against- 37 CROSBY REALTY LLC, NEW YORK CONSTRUCTION & RENOVATION, INC., ENGINEERING GROUP ASSOCIATES, P.C., GENNADY SARATOVSKY, P.E., INTEGRITY CONSULTING SERVICE, INC., ALEKSANDER LEVIN, P.E., BRENT M. PORTER ARCHITECTS AND ASSOCIATES, BRENT M. PORTER ARCHITECT, PLLC and BRENT PORTER, R.A., Defendants. ----··-------------··----------------------------------------------··---X PLEASE TAKE NOTICE, that upon the annexed affirmation of JONATHAN PIROG, dated, July 24, 2018 and upon all the pleadings and proceedings heretofore had herein, the undersigned will move this Court before the assigned Justice of the Court thereof, to be held at 24d' the courthouse located at 60 Center Street, Room 130, New York, NY, on the day of o' August 2018, at 9:30 clock in the forenoon of that day or as soon thereafter as counsel can be heard for an Order pursuant to CPLR 3124 directing the Plaintiff and Defendants to comply with the Discovery Demands that was served on said attorney and for such other and further relief as to the Court may seem just and proper. A Note ofhas not yet been filed in this action. An affirmation that a good faith effort has been made to resolve the issues raised in this motion is annexed hereto, 1 of 2 . . . .. FILED: NEW YORK COUNTY CLERK 07/25/2018 09:23 AM INDEX NO. 154824/2017 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 07/25/2018 PLEASE TAKE FURTHER NOTICE, that any and all answering affidavits must be served within seven (7) days prior to the return date of this motion. Dated: Melville, NY July 24, 2018 Yours, etc. LAW OFFICE OF MICHAEL C. TROMELLO Attorneys for Defendants BRENT PORTER, R.A., BRENT M. PORTER ARCHITECT, PLLC and BRENT M. PORTER ARCHITECTS AND ASSOCIATES 395 North Service Road P.O. Box 9038 Melville, NY 11747 631-577 0 By: J . THAN PIlf€fG To: ZETLIN & DE CHIARA, LLP Attorney for Plaintiff DAJ REALTY, LLC 801 Second Avenue New York, NY 10017 212-682-6800 BYRNE & O'NEILL, LLP Attorney for INTEGRITY CONSULTING SERVICE, INC. ALEKSANDER LEVIN, P.E. 11 Broadway, Suite 910 NY, NY 10004-1314 212-422-9424 CLARK & FOX Attorney for 37 CROSBY REALTY, LLC 404 5th Avenue, 3rd floor New York, New York 10018 646 506 3048 2 of 2