On September 30, 2019 a
Party Discovery
was filed
involving a dispute between
All Metro Valet Parking Inc.
D B A Executive Parking,
and
Open Road Of Manhattan, Llc
D B A Audi Manhattan,
Open Road Of New York City, Llc
D B A Open Road Volkswagen Of Manhattan,
for Commercial - Contract
in the District Court of Nassau County.
Preview
FILED: NASSAU COUNTY CLERK 01/23/2020 12:15 PM INDEX NO. 613584/2019
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 01/23/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
---- --¬-- -- ------- ----------------------------X Index # 613584/2019
ALL METRO VALET PARKING INC.
D/B/A EXECUTIVE PARKING,
Plaintiff, NOTICE TO TAKE
DEPOSITION UPON
-against- ORAL EXAMINATION
OPEN ROAD OF MANHATTAN, LLC
D/B/A AUDI MANHATTAN AND OPEN
ROAD OF NEW YORK CITY, LLC
D/B/A OPEN ROAD VOLKSWAGEN
OF MANHATTAN,
Defendants.
--------- ------ -------------------------------X
S I R S:
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and
Rules the testimony, upon oral examination of the Defendañt, OPEN ROAD OF NEW YORK
CITY, LLC D/B/A OPEN ROAD VOLKSWAGEN OF MANHATTAN, by an agent servant or
employee familiar with the facts as an adverse will be taken before a Public who is
party Notary
not an attorney, or employee of an attorney, for any party or prospective party herein and is not a
person who would be disqualified to act as a juror because of interest or because of
coñsanguinity or affinity to any party herein, on March 5, 2020 at the offices of JOSEPH,
TERRACCIANO & LYNAM, LLP, 2 Roosevelt Avenue, Suite 200, Syosset, New York
11791 at 10:00 a.m. in the morning of that day with respect to evidence material and necessary
in the pursuit and/or defense of this action.
That said person to be examined is required to produce at such examination, the
following:
1 of 3
FILED: NASSAU COUNTY CLERK 01/23/2020 12:15 PM INDEX NO. 613584/2019
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 01/23/2020
1. All documentation regarding the within dispute and claims concerning the Plaintiff
herein.
Dated: Syosset, New York
January 23, 2020
By: e T. ynam, Esq.
JOSEPH, TERRACCIANO & LYNAM, LLP
Attorneys for Plaintiff
2 Roosevelt Avenue, Suite 200
Syosset, New York 11791
(516) 496-0202
TO: METHFESSEL & WERBEL, ESQS.
By: Brent R. Pohlman, Esq.
Attorneys for Defendants
34th
112 W. Street
17th
Floor, Room 17089
New York, New York 10120
(212) 947-1999
2 of 3
FILED: NASSAU COUNTY CLERK 01/23/2020 12:15 PM INDEX NO. 613584/2019
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 01/23/2020
Index No.: 613584/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
-------.------.,------------------------------------------------------------------_--------
ALL METRO VALET PARKING INC.
D/B/A EXECUTIVE PARKING,
Plaintiff,
-against-
OPEN ROAD OF MANHATTAN, LLC
D/B/A AUDI MANHATTAN AND OPEN
ROAD OF NEW YORK CITY, LLC
D/B/A OPEN ROAD VOLKSWAGEN
OF MANHATTAN,
Defendants.
NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION
JOSEPH, TERRACCIANO & LYNAM, LLP
Attorneys for Plaintiff
2 Roosevelt Avenue, Suite 200
Syosset, New York 11791
(516) 496-0202
This document is signed pursuant
to 22 NYCRR 130- .1-a
Dated: Janu ry 2 , 20
J 1 e n , Esq.
3 of 3
Document Filed Date
January 23, 2020
Case Filing Date
September 30, 2019
Category
Commercial - Contract
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FILED: NASSAU COUNTY CLERK 01/23/2020 12:15 PM INDEX NO. 613584/2019 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 01/23/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ---- --¬-- -- ------- ----------------------------X Index # 613584/2019 ALL METRO VALET PARKING INC. D/B/A EXECUTIVE PARKING, Plaintiff, NOTICE TO TAKE DEPOSITION UPON -against- ORAL EXAMINATION OPEN ROAD OF MANHATTAN, LLC D/B/A AUDI MANHATTAN AND OPEN ROAD OF NEW YORK CITY, LLC D/B/A OPEN ROAD VOLKSWAGEN OF MANHATTAN, Defendants. --------- ------ -------------------------------X S I R S: PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules the testimony, upon oral examination of the Defendañt, OPEN ROAD OF NEW YORK CITY, LLC D/B/A OPEN ROAD VOLKSWAGEN OF MANHATTAN, by an agent servant or employee familiar with the facts as an adverse will be taken before a Public who is party Notary not an attorney, or employee of an attorney, for any party or prospective party herein and is not a person who would be disqualified to act as a juror because of interest or because of coñsanguinity or affinity to any party herein, on March 5, 2020 at the offices of JOSEPH, TERRACCIANO & LYNAM, LLP, 2 Roosevelt Avenue, Suite 200, Syosset, New York 11791 at 10:00 a.m. in the morning of that day with respect to evidence material and necessary in the pursuit and/or defense of this action. That said person to be examined is required to produce at such examination, the following: 1 of 3 FILED: NASSAU COUNTY CLERK 01/23/2020 12:15 PM INDEX NO. 613584/2019 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 01/23/2020 1. All documentation regarding the within dispute and claims concerning the Plaintiff herein. Dated: Syosset, New York January 23, 2020 By: e T. ynam, Esq. JOSEPH, TERRACCIANO & LYNAM, LLP Attorneys for Plaintiff 2 Roosevelt Avenue, Suite 200 Syosset, New York 11791 (516) 496-0202 TO: METHFESSEL & WERBEL, ESQS. By: Brent R. Pohlman, Esq. Attorneys for Defendants 34th 112 W. Street 17th Floor, Room 17089 New York, New York 10120 (212) 947-1999 2 of 3 FILED: NASSAU COUNTY CLERK 01/23/2020 12:15 PM INDEX NO. 613584/2019 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 01/23/2020 Index No.: 613584/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU -------.------.,------------------------------------------------------------------_-------- ALL METRO VALET PARKING INC. D/B/A EXECUTIVE PARKING, Plaintiff, -against- OPEN ROAD OF MANHATTAN, LLC D/B/A AUDI MANHATTAN AND OPEN ROAD OF NEW YORK CITY, LLC D/B/A OPEN ROAD VOLKSWAGEN OF MANHATTAN, Defendants. NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION JOSEPH, TERRACCIANO & LYNAM, LLP Attorneys for Plaintiff 2 Roosevelt Avenue, Suite 200 Syosset, New York 11791 (516) 496-0202 This document is signed pursuant to 22 NYCRR 130- .1-a Dated: Janu ry 2 , 20 J 1 e n , Esq. 3 of 3