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FILED: BRONX COUNTY CLERK 02/04/2022 03:37 PM INDEX NO. 27619/2018E
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/04/2022
NOTE OF ISSUE
Calendar no. (if any) …………………………. for use of clerk
Index No. …27619/2018E……………………….
……SUPREME…. Court……BRONX……………County, N.Y.
Hon. Andrew J. Cohen
Name of Judge Assigned
MUSHTAQ GRANT,
NOTICE FOR TRIAL
Trial by jury demanded
Plaintiff(s), of all issues
of issues specified below
- against - or attached hereto
Trial without jury
1137 E. 223RD CORP. d/b/a FAITH CHRISTIAN Filed by attorney for
...........Plaintiff(s)..........................
ACADEMY, ENVISION DESIGN & Date summons served. ….6/29/2018.............
CONTRUCTION LLC and ROBERT L. KNIGHT, Date service completed. ……7/3/2018………………..
Date issued joined ...... 10/15/2018...…….............
Defendant(s).
NATURE OF ACTION OR SPECIAL PROCEEDING
Tort: Motor vehicle negligence
Medical malpractice
Other tort
Contract
Contested matrimonial
Uncontested matrimonial
Tax certiorari
Condemnation
Other (not itemized above) specify.......................................
This action is brought as a class action
This is a medical malpractice action:
panel procedures prescribed by
court rules pursuant to Jud.
§ 148-a.
have been completed have not been completed
Amount Demanded $... Exceeds the jurisdictional…..................................
…limits of the lower courts which have jurisdiction…..………………….
Other relief...………………………………………………………………..................
Insurance carrier (s), if known:
Special preference claimed under COURT RULES
APPELLATE DIVISION FIRST DEPARTMENT
on the ground that PLAINTIFF SUSTAINED
SEVERE AND PERSONAL INJURIES................
...................................................................................
LESCH & LESCH, P.C.
Attorney(s) for Plaintiff(s)
MUSHTAQ GRANT
Office & P.O. Address:
860 Grand Concourse, Suite 2M
Bronx, New York 10451
Phone No.: 718-292-1131
STRONGIN ROTHMAN & ABRAMS, LLP
By: David Abrams, Esq.
Attorneys for Defendant(s)
1137 E. 223RD CORP. d/b/a
FAITH CHRISTIAN ACADEMY
80 Pine Street, 10th Floor
New York, New York 10005
(212) 931-8300
NOTE: Clerk will not accept this note of issue unless accompanied by a certificate of readiness, or, in a medical malpractice action, unless, where applicable,
the certificate of readiness previously has been filed and the panel procedures prescribed by court rules pursuant to section 148-a of the Judiciary Law have been completed.
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FILED: BRONX COUNTY CLERK 02/04/2022 03:37 PM INDEX NO. 27619/2018E
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/04/2022
CERTIFICATE OF READINESS FOR TRIAL
(Items 1-7 must be checked)
Completed Waived Not required For Clerk’s Use
1. All pleadings served ...................................
......X......... ............. ............. N.I. served
on
2. Bill of particulars served ............................
.......X....... ...........................
3. Physical examinations completed ....... ............... ......X.....................
4. Medical reports exchanged ........... ........X....... ..............
.............
5. Appraisal reports exchanged ......................
...............
...............
...X.......
6. Compliance with the rules in matrimonial actions ...............
..................X.......
(22 NYCRR 202.16)
7. Discovery proceedings now known to be necessary ...X........ ................
.............
8. There are no outstanding requests for discovery.
9. There has been a reasonable opportunity to complete the foregoing proceedings.
10. There has been compliance with any order issued pursuant to the Precalendar Rules (22 NYCRR 202.12).
11. If a medical malpractice action, there has been compliance with any order issued pursuant to 22 NYCRR 202.56.
12. The case is ready for trial.
Dated: February 4, 2022
Signature type name below
DAVID P. LESCH
LESCH & LESCH, P.C.
Attorneys (s) for Office & P.O. Address
860 Grand Concourse, Suite 2M
Bronx, New York 10451
State of New York, County of ss.: State of New York, County of Bronx ss.:
ASHLEY DIAZ
being duly sworn deposes and says: that deponent being duly sworn, and says, that deponent is not a
party to the action is over 18 years of age and resides atparty to the action, is over 18 years of age and resides at
BRONX, NEW YORK
That on the day of 2022 That on the 4th day of February 2022
deponent served the within note of issue and certificate of
deponent served the within note of issue and certificate of
readiness on readiness on the law office of STRONGIN ROTHMAN
& ABRAMS, LLP attorney(s) for Defendants 1137 E.
223RD CORP. d/b/a FAITH CHRISTIAN
ACADEMY
attorney (s) for herein at 80 Pine Street, 10th Floor, New York,
New York 10005
during his absence from said office the address designated by said attorneys(s) for that
purpose by
(a) by then and there leaving a true copy of the same withdepositing a true copy of same enclosed in a postpaid properly
addressed wrapper. in –a post office—official depository under
his clerk; partner; person having charge of said office. the exclusive care and custody of the United States Postal Serv-
(b) and said office being close. By depositing a true copy of ice within New York State.
same. enclosed in a sealed wrapper directed to said attorney(s)
Sworn to before me on February 4, 2022
==
Admission of Service Due service of a note of and certificate of readiness, of which the within is a copy,
Admitted………………………2022…….………………………………………………
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FILED: BRONX COUNTY CLERK 02/04/2022 03:37 PM INDEX NO. 27619/2018E
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/04/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
--------------------------------------------------------------------X
MUSHTAQ GRANT, AFFIRMATION OF
COMPLIANCE
Plaintiff(s), Index No.: 27619/2018E
- against -
1137 E. 223RD CORP. d/b/a FAITH CHRISTIAN
ACADEMY, ENVISION DESIGN &
CONTRUCTION LLC and ROBERT L. KNIGHT,
Defendant(s).
--------------------------------------------------------------------X
I, DAVID P. LESCH, ESQ., an attorney duly admitted to practice in the court of
the State of New York, affirm the following under the penalties of perjury:
1. I am the attorney representing Plaintiff(s) herein and as such am fully
familiar with the pleadings and proceedings had herein.
2. All discovery has been completed in this case and medical reports have been
exchanged.
3. As all pre-trial discovery has been completed in this case and the medical
reports have been exchanged, it is requested that the Plaintiff(s) be allowed to file his Note
of Issue/Certificate of Readiness for Trial in this case.
WHEREFORE, it is respectfully requested that this action be placed on the Trial
Calendar of this Court.
Dated: Bronx, New York
February 4, 2022
____________________________
DAVID P. LESCH, ESQ.
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FILED: BRONX COUNTY CLERK 02/04/2022 03:37 PM INDEX NO. 27619/2018E NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/04/2022 NOTE OF ISSUE Calendar no. (if any) …………………………. for use of clerk Index No. …27619/2018E………………………. ……SUPREME…. Court……BRONX……………County, N.Y. Hon. Andrew J. Cohen Name of Judge Assigned MUSHTAQ GRANT, NOTICE FOR TRIAL Trial by jury demanded Plaintiff(s), of all issues of issues specified below - against - or attached hereto Trial without jury 1137 E. 223RD CORP. d/b/a FAITH CHRISTIAN Filed by attorney for ...........Plaintiff(s).......................... ACADEMY, ENVISION DESIGN & Date summons served. ….6/29/2018............. CONTRUCTION LLC and ROBERT L. KNIGHT, Date service completed. ……7/3/2018……………….. Date issued joined ...... 10/15/2018...……............. Defendant(s). NATURE OF ACTION OR SPECIAL PROCEEDING Tort: Motor vehicle negligence Medical malpractice Other tort Contract Contested matrimonial Uncontested matrimonial Tax certiorari Condemnation Other (not itemized above) specify....................................... This action is brought as a class action This is a medical malpractice action: panel procedures prescribed by court rules pursuant to Jud. § 148-a. have been completed have not been completed Amount Demanded $... Exceeds the jurisdictional….................................. …limits of the lower courts which have jurisdiction…..…………………. Other relief...……………………………………………………………….................. Insurance carrier (s), if known: Special preference claimed under COURT RULES APPELLATE DIVISION FIRST DEPARTMENT on the ground that PLAINTIFF SUSTAINED SEVERE AND PERSONAL INJURIES................ ................................................................................... LESCH & LESCH, P.C. Attorney(s) for Plaintiff(s) MUSHTAQ GRANT Office & P.O. Address: 860 Grand Concourse, Suite 2M Bronx, New York 10451 Phone No.: 718-292-1131 STRONGIN ROTHMAN & ABRAMS, LLP By: David Abrams, Esq. Attorneys for Defendant(s) 1137 E. 223RD CORP. d/b/a FAITH CHRISTIAN ACADEMY 80 Pine Street, 10th Floor New York, New York 10005 (212) 931-8300 NOTE: Clerk will not accept this note of issue unless accompanied by a certificate of readiness, or, in a medical malpractice action, unless, where applicable, the certificate of readiness previously has been filed and the panel procedures prescribed by court rules pursuant to section 148-a of the Judiciary Law have been completed. 1 of 3 FILED: BRONX COUNTY CLERK 02/04/2022 03:37 PM INDEX NO. 27619/2018E NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/04/2022 CERTIFICATE OF READINESS FOR TRIAL (Items 1-7 must be checked) Completed Waived Not required For Clerk’s Use 1. All pleadings served ................................... ......X......... ............. ............. N.I. served on 2. Bill of particulars served ............................ .......X....... ........................... 3. Physical examinations completed ....... ............... ......X..................... 4. Medical reports exchanged ........... ........X....... .............. ............. 5. Appraisal reports exchanged ...................... ............... ............... ...X....... 6. Compliance with the rules in matrimonial actions ............... ..................X....... (22 NYCRR 202.16) 7. Discovery proceedings now known to be necessary ...X........ ................ ............. 8. There are no outstanding requests for discovery. 9. There has been a reasonable opportunity to complete the foregoing proceedings. 10. There has been compliance with any order issued pursuant to the Precalendar Rules (22 NYCRR 202.12). 11. If a medical malpractice action, there has been compliance with any order issued pursuant to 22 NYCRR 202.56. 12. The case is ready for trial. Dated: February 4, 2022 Signature type name below DAVID P. LESCH LESCH & LESCH, P.C. Attorneys (s) for Office & P.O. Address 860 Grand Concourse, Suite 2M Bronx, New York 10451 State of New York, County of ss.: State of New York, County of Bronx ss.: ASHLEY DIAZ being duly sworn deposes and says: that deponent being duly sworn, and says, that deponent is not a party to the action is over 18 years of age and resides atparty to the action, is over 18 years of age and resides at BRONX, NEW YORK That on the day of 2022 That on the 4th day of February 2022 deponent served the within note of issue and certificate of deponent served the within note of issue and certificate of readiness on readiness on the law office of STRONGIN ROTHMAN & ABRAMS, LLP attorney(s) for Defendants 1137 E. 223RD CORP. d/b/a FAITH CHRISTIAN ACADEMY attorney (s) for herein at 80 Pine Street, 10th Floor, New York, New York 10005 during his absence from said office the address designated by said attorneys(s) for that purpose by (a) by then and there leaving a true copy of the same withdepositing a true copy of same enclosed in a postpaid properly addressed wrapper. in –a post office—official depository under his clerk; partner; person having charge of said office. the exclusive care and custody of the United States Postal Serv- (b) and said office being close. By depositing a true copy of ice within New York State. same. enclosed in a sealed wrapper directed to said attorney(s) Sworn to before me on February 4, 2022 == Admission of Service Due service of a note of and certificate of readiness, of which the within is a copy, Admitted………………………2022…….……………………………………………… 2 of 3 FILED: BRONX COUNTY CLERK 02/04/2022 03:37 PM INDEX NO. 27619/2018E NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/04/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX --------------------------------------------------------------------X MUSHTAQ GRANT, AFFIRMATION OF COMPLIANCE Plaintiff(s), Index No.: 27619/2018E - against - 1137 E. 223RD CORP. d/b/a FAITH CHRISTIAN ACADEMY, ENVISION DESIGN & CONTRUCTION LLC and ROBERT L. KNIGHT, Defendant(s). --------------------------------------------------------------------X I, DAVID P. LESCH, ESQ., an attorney duly admitted to practice in the court of the State of New York, affirm the following under the penalties of perjury: 1. I am the attorney representing Plaintiff(s) herein and as such am fully familiar with the pleadings and proceedings had herein. 2. All discovery has been completed in this case and medical reports have been exchanged. 3. As all pre-trial discovery has been completed in this case and the medical reports have been exchanged, it is requested that the Plaintiff(s) be allowed to file his Note of Issue/Certificate of Readiness for Trial in this case. WHEREFORE, it is respectfully requested that this action be placed on the Trial Calendar of this Court. Dated: Bronx, New York February 4, 2022 ____________________________ DAVID P. LESCH, ESQ. 3 of 3