Preview
FILED: NEW YORK COUNTY CLERK 04/26/2021 04:26 PM INDEX NO. 155570/2016
NYSCEF DOC. NO. 175 RECEIVED NYSCEF: 04/26/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
x
ANTHONY MAGNI, Index No. 155570/2016 (ECF)
Plaintiff(s)
NOTICE TO PRODUCE
v.
THIRD AVENUE TOWER OWNER, LLC,
POLSINELLI PC, CLUNE CONSTRUCTION
COMPANY, L.P., CONCEPTS FOR BUSINESS,
LLC., and G&S CONCEPTS,
Defendant(s)
x
POLSINELLI PC, Index No. 595198/2017 (ECF)
Third-Party Plaintiff(s)
v.
CONCEPTS FOR BUSINESS, LLC. and G&S
CONCEPTS, INC.,
Third-Party Defendant(s)
x
PLEASE TAKE NOTICE, that pursuant to the applicable Rules of the CPLR,
DEFENDANTS/THIRD PARTY DEFENDANTS, CLUNE CONSTRUCTION,
CONCEPTS FOR BUSINESSS, LLC and G&S CONCEPTS, INC. are hereby required to
produce for discovery, inspection and photocopying, at the office Eustace, Prezioso &
Yapchanyk, 55 Water Street, 28th Floor, New York, New York 10041, twenty (20) days from
the date when this Notice to Produce is served on you, at 10:00 a.m. on that day, the following
documents:
1 of 4
FILED: NEW YORK COUNTY CLERK 04/26/2021 04:26 PM INDEX NO. 155570/2016
NYSCEF DOC. NO. 175 RECEIVED NYSCEF: 04/26/2021
1. Copies of all applicable primary and excess insurance policies in effect on the date of
the subject accident in this matter.
PLEASE TAKE FURTHER NOTICE that, in the event of failure to comply with this
Notice, the undersigned may move to preclude Defendants from introducing into evidence and
from otherwise using each aforementioned items for any purpose whatsoever, upon the trial of
this action.
DATED: April 26, 2021
New York, New York
EUSTACE, PREZIOSO & YAPCHANYK
Attorneys for Defendants,
POLSINELLI PC AND THIRD AVENUE
TOWER OWNER, LLC
55 Water Street, 28th Floor
New York, New York 10041
(212) 612-4200
By:
Robert M. Michell
2
2 of 4
FILED: NEW YORK COUNTY CLERK 04/26/2021 04:26 PM INDEX NO. 155570/2016
NYSCEF DOC. NO. 175 RECEIVED NYSCEF: 04/26/2021
TO:
Sackstein Sackstein & Lee
Attorneys for Plaintiff,
Anthony Magni
1140 Franklin Avenue
Garden City, New York 11530
Lewis Brisbois Bisgaard & Smith LLP
Attorneys for Defendants,
Clune Construction Company, L.P.
and G&S Concepts, Inc.
77 Water Street, Suite 2100
New York, New York 10005
Law Offices of Tobias & Kuhn
Attorneys for Defendant,
Concepts for Business, LLC
100 William Street-Suite 920
New York, New York 10038
3 of 4
FILED: NEW YORK COUNTY CLERK 04/26/2021 04:26 PM INDEX NO. 155570/2016
NYSCEF DOC. NO. 175 RECEIVED NYSCEF: 04/26/2021
Index No. 155570/2016 (ECF)
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
ANTHONY MAGNI,
Plaintiff(s)
-against-
THIRD AVENUE TOWER OWNER, LLC, POLSINELLI PC, CLUNE CONSTRUCTION
COMPANY, L.P.,CONCEPTS FOR BUSINESS, LLC., and G&S CONCEPTS,
Defendant(s)
NOTICE TO PRODUCE
EUSTACE, PREZIOSO & YAPCHANYK
Attorneys for Defendants,
POLSINELLI PC AND THIRD AVENUE TOWER OWNER, LLC
55 Water Street, 28th Floor
New York, New York 10041
(212) 612-4200
4 of 4
Preview
FILED: NEW YORK COUNTY CLERK 04/26/2021 04:26 PM INDEX NO. 155570/2016 NYSCEF DOC. NO. 175 RECEIVED NYSCEF: 04/26/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK x ANTHONY MAGNI, Index No. 155570/2016 (ECF) Plaintiff(s) NOTICE TO PRODUCE v. THIRD AVENUE TOWER OWNER, LLC, POLSINELLI PC, CLUNE CONSTRUCTION COMPANY, L.P., CONCEPTS FOR BUSINESS, LLC., and G&S CONCEPTS, Defendant(s) x POLSINELLI PC, Index No. 595198/2017 (ECF) Third-Party Plaintiff(s) v. CONCEPTS FOR BUSINESS, LLC. and G&S CONCEPTS, INC., Third-Party Defendant(s) x PLEASE TAKE NOTICE, that pursuant to the applicable Rules of the CPLR, DEFENDANTS/THIRD PARTY DEFENDANTS, CLUNE CONSTRUCTION, CONCEPTS FOR BUSINESSS, LLC and G&S CONCEPTS, INC. are hereby required to produce for discovery, inspection and photocopying, at the office Eustace, Prezioso & Yapchanyk, 55 Water Street, 28th Floor, New York, New York 10041, twenty (20) days from the date when this Notice to Produce is served on you, at 10:00 a.m. on that day, the following documents: 1 of 4 FILED: NEW YORK COUNTY CLERK 04/26/2021 04:26 PM INDEX NO. 155570/2016 NYSCEF DOC. NO. 175 RECEIVED NYSCEF: 04/26/2021 1. Copies of all applicable primary and excess insurance policies in effect on the date of the subject accident in this matter. PLEASE TAKE FURTHER NOTICE that, in the event of failure to comply with this Notice, the undersigned may move to preclude Defendants from introducing into evidence and from otherwise using each aforementioned items for any purpose whatsoever, upon the trial of this action. DATED: April 26, 2021 New York, New York EUSTACE, PREZIOSO & YAPCHANYK Attorneys for Defendants, POLSINELLI PC AND THIRD AVENUE TOWER OWNER, LLC 55 Water Street, 28th Floor New York, New York 10041 (212) 612-4200 By: Robert M. Michell 2 2 of 4 FILED: NEW YORK COUNTY CLERK 04/26/2021 04:26 PM INDEX NO. 155570/2016 NYSCEF DOC. NO. 175 RECEIVED NYSCEF: 04/26/2021 TO: Sackstein Sackstein & Lee Attorneys for Plaintiff, Anthony Magni 1140 Franklin Avenue Garden City, New York 11530 Lewis Brisbois Bisgaard & Smith LLP Attorneys for Defendants, Clune Construction Company, L.P. and G&S Concepts, Inc. 77 Water Street, Suite 2100 New York, New York 10005 Law Offices of Tobias & Kuhn Attorneys for Defendant, Concepts for Business, LLC 100 William Street-Suite 920 New York, New York 10038 3 of 4 FILED: NEW YORK COUNTY CLERK 04/26/2021 04:26 PM INDEX NO. 155570/2016 NYSCEF DOC. NO. 175 RECEIVED NYSCEF: 04/26/2021 Index No. 155570/2016 (ECF) SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ANTHONY MAGNI, Plaintiff(s) -against- THIRD AVENUE TOWER OWNER, LLC, POLSINELLI PC, CLUNE CONSTRUCTION COMPANY, L.P.,CONCEPTS FOR BUSINESS, LLC., and G&S CONCEPTS, Defendant(s) NOTICE TO PRODUCE EUSTACE, PREZIOSO & YAPCHANYK Attorneys for Defendants, POLSINELLI PC AND THIRD AVENUE TOWER OWNER, LLC 55 Water Street, 28th Floor New York, New York 10041 (212) 612-4200 4 of 4