Preview
FILED: PUTNAM COUNTY CLERK 09/17/2021 04:05 PM INDEX NO. 500754/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/17/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF PUTNAM
-----------------------------------------------------------------X
T.S., Index No.: 500754/2021
Plaintiff,
-against- NOTICE TO TAKE
DEPOSITION UPON ORAL
BREWSTER CENTRAL SCHOOL DISTRICT, EXAMINATION
Defendant.
-----------------------------------------------------------------X
PLEASE TAKE NOTICE, that pursuant to the Rules of the CPLR, attorneys for
Defendant, BREWSTER CENTRAL SCHOOL DISTRICT, will take the deposition of Plaintiff
before a Notary Public who is not an attorney, or an employee of an attorney, for any party or
prospective party herein and is not a person who would be disqualified to act as juror because of
interest or because of consanguinity or affinity to any party herein at a place TBD in Putnam
County, State of New York on Monday October 25, 2021 at 10:00 A.M., of that day with respect
to evidence material and necessary in the defense of this action, including negligence, contributory
negligence, liability and damages.
That said persons to be examined are required to produce at such examination the
following:
Any and all bills, books, diaries, writings, and other memoranda, in your possession
or that of your attorneys relating to the events in issue or any element of the claimed
damages.
PLEASE TAKE FURTHER NOTICE, pursuant to CPLR 202.15(c) and the deposition
shall be videotaped by Hall of Fame Deposition Services, Inc. located at 303 East 37th Street, Suite
# 2M, New York, New York 10016.
{F2308454-1}
1 of 3
FILED: PUTNAM COUNTY CLERK 09/17/2021 04:05 PM INDEX NO. 500754/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/17/2021
PLEASE TAKE FURTHER NOTICE, that service of the Notice to take Deposition
Upon Oral Examination is made for the purposes of preserving this Defendant’s right of priority,
and the date of the oral examination shall be determined between the parties and MUST be
confirmed between the parties prior to the oral examination.
Dated: New York, New York Yours, etc.,
September 17, 2021 McGIVNEY, KLUGER, CLARK &
INTOCCIA, P.C.
Danit L. Sibovits
Danit L. Sibovits, Esq.
Attorneys for Defendant, Brewster Central
School District
80 Broad Street, 23rd Floor
New York, New York 10004
(212) 509-3456
Our File No.: 4184G-0072
TO: SLATER SLATER SCHULMAN, LLP
Adam P. Slater, Esq.
Linc C. Leder, Esq.
488 Madison Avenue, 20th Floor
New York, NY 10022
(212)922-0906
Attorneys for Plaintiff
Via NYSCEF
{F2308454-1}
2 of 3
FILED: PUTNAM COUNTY CLERK 09/17/2021 04:05 PM INDEX NO. 500754/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/17/2021
ATTORNEY'S CERTIFICATION OF SERVICE
DANIT L. SIBOVITS, ESQ., hereby certifies that the within Notice to Take
Deposition Upon Oral Examination has been served Via NYSCEF to all Appearing Parties, on
this 17th day of September 2021.
Dated: New York, New York
September 17, 2021
Danit L. Sibovits
DANIT L. SIBOVITS, ESQ.
{F2308454-1}
3 of 3
Preview
FILED: PUTNAM COUNTY CLERK 09/17/2021 04:05 PM INDEX NO. 500754/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/17/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF PUTNAM -----------------------------------------------------------------X T.S., Index No.: 500754/2021 Plaintiff, -against- NOTICE TO TAKE DEPOSITION UPON ORAL BREWSTER CENTRAL SCHOOL DISTRICT, EXAMINATION Defendant. -----------------------------------------------------------------X PLEASE TAKE NOTICE, that pursuant to the Rules of the CPLR, attorneys for Defendant, BREWSTER CENTRAL SCHOOL DISTRICT, will take the deposition of Plaintiff before a Notary Public who is not an attorney, or an employee of an attorney, for any party or prospective party herein and is not a person who would be disqualified to act as juror because of interest or because of consanguinity or affinity to any party herein at a place TBD in Putnam County, State of New York on Monday October 25, 2021 at 10:00 A.M., of that day with respect to evidence material and necessary in the defense of this action, including negligence, contributory negligence, liability and damages. That said persons to be examined are required to produce at such examination the following: Any and all bills, books, diaries, writings, and other memoranda, in your possession or that of your attorneys relating to the events in issue or any element of the claimed damages. PLEASE TAKE FURTHER NOTICE, pursuant to CPLR 202.15(c) and the deposition shall be videotaped by Hall of Fame Deposition Services, Inc. located at 303 East 37th Street, Suite # 2M, New York, New York 10016. {F2308454-1} 1 of 3 FILED: PUTNAM COUNTY CLERK 09/17/2021 04:05 PM INDEX NO. 500754/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/17/2021 PLEASE TAKE FURTHER NOTICE, that service of the Notice to take Deposition Upon Oral Examination is made for the purposes of preserving this Defendant’s right of priority, and the date of the oral examination shall be determined between the parties and MUST be confirmed between the parties prior to the oral examination. Dated: New York, New York Yours, etc., September 17, 2021 McGIVNEY, KLUGER, CLARK & INTOCCIA, P.C. Danit L. Sibovits Danit L. Sibovits, Esq. Attorneys for Defendant, Brewster Central School District 80 Broad Street, 23rd Floor New York, New York 10004 (212) 509-3456 Our File No.: 4184G-0072 TO: SLATER SLATER SCHULMAN, LLP Adam P. Slater, Esq. Linc C. Leder, Esq. 488 Madison Avenue, 20th Floor New York, NY 10022 (212)922-0906 Attorneys for Plaintiff Via NYSCEF {F2308454-1} 2 of 3 FILED: PUTNAM COUNTY CLERK 09/17/2021 04:05 PM INDEX NO. 500754/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/17/2021 ATTORNEY'S CERTIFICATION OF SERVICE DANIT L. SIBOVITS, ESQ., hereby certifies that the within Notice to Take Deposition Upon Oral Examination has been served Via NYSCEF to all Appearing Parties, on this 17th day of September 2021. Dated: New York, New York September 17, 2021 Danit L. Sibovits DANIT L. SIBOVITS, ESQ. {F2308454-1} 3 of 3