Preview
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022
EXHIBIT 7
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
_ ______..----------_____------------..x
KENNETH REMBERT,
Index No.: 303885/2016
Plaintiff,
-against-
FORCE SERVICES, LLC, LUIGI FALCIANO, NOTICE OF DEPOSITION
DAMON FAVILLO, DANIEL STOKES and UPON ORAL EXAMINATION
JOHN AND JANE DOES, said names being fictitious
and intended to represent individual employees of
Force Services, LLC,
Defendants.
._.___..---___________---_..__----________Ç
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 Defendant Daniel Stokes will be taken before a
notary public who is not an attorney, or employee of any attorney, for any party or prospective
party herein and is nota person who would be disqualified to act as a juror because of interest or
because of consanguinity or affinity to any party herein, at The Cochran Firm, One Exchange
Plaza, 55 Broadway, 23rd Floor, New York, NY 10006, on a date and time to be mutually
agreed upon, with respect to evidence material and necessary in the prosecution of this action.
Dated: New York, New York
February 14, 2017
Respectfully Submitted,
THE COCHRAN FIRM
Derek S. ells,Esq.
Stephanie R. Correa, Esq.
One Exchange Plaza
23'd
55 Broadway, Floor
New York, New York 10006
(Tel No.) (212) 553-9215
(Facsimile) (212) 227-8763
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022
CERTIFICATE OF SERVICE
14"'
On the day of February 2017, a true and accurate copy of NOTICE OF
DEPOSITION UPON ORAL EXAMINATION was served by FIRST CLASS MAIL to the
following attorneys:
Vincent Gelardi, Esq.
THE DEIORIO LAW GROUP, PLLC
Attorney for Defendants
800 Westchester Avenue, Suite S-608
Rye Brook, New York 10573
STEP IE R. ORREA
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
-------------------------------------X
KENNETH REMBERT,
Index No.: 303885/2016
Plaintiff,
-against-
FORCE SERVICES, LLC, LUIGI FALCIANO, NOTICE OF DEPOSITION
DAMON FAVILLO, DANIEL STOKES and UPON ORAL EXAMINATION
JOHN AND JANE DOES, said names being fictitious
and intended to represent individual employees of
Force Services, LLC,
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 Defendant Damon Favillo will be taken before a
notary public who is not an attorney, or employee of any attorney, for any party or prospective
party herein and isnot a person who would be disqualified to act as a juror because of interest or
because of consanguinity or affinity to any party herein, at The Cochran Firm, One Exchange
Plaza, 55 Broadway, 23rd Floor, New York, NY 10006, on a date and time to be mutually
agreed upon, with respect to evidence material and necessary in the prosecution of this action.
Dated: New York, New York
February 14, 2017
Respectfully Submitted,
TH COCHRAN FIRM
Derek S.Sells, Esq.
Stephanie R. Correa, Esq.
One Exchange Plaza
23'd
55 Broadway, Floor
New York, New York 10006
(Tel No.) (212) 553-9215
(Facsimile) (212) 227-8763
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022
CERTIFICATE OF SERVICE
14* accurate of NOTICE OF
On the day of February 2017, a true and copy
DEPOSITION UPON ORAL EXAMINATION was served by FIRST CLASS MAIL to the
following attorneys:
Vincent Gelardi, Esq.
THE DEIORIO LAW GROUP, PLLC
Attorney for Defendants
800 Westchester Avenue, Suite S-608
Rye Brook, New York 10573
STEP R. CORREA
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
..____x
KENNETH REMBERT,
Index No.: 303885/2016
Plaintiff,
-against-
FORCE SERVICES, LLC, LUIGI FALCIANO, NOTICE OF DEPOSITION
DAMON FAVILLO, DAN1EL STOKES and UPON ORAL EXAMINATION
JOHN AND JANE DOES, said names being fictitious
and intended to represent individual employees of
Force Services, LLC,
Defendants.
________________----,._____________________Ç
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 Defendant Luigi Falciano will be taken before a
notary public who is not an attorney, or employee of any 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 consanguinity or affmity to any party herein, at The Cochran Firm, One Exchange
Plaza, 55 Broadway, 23rd Floor, New York, NY 10006, on a date and time to be mutually
agreed upon, with respect to evidence material and necessary in the prosecution of thisaction.
Dated: New York, New York
February 14, 2017
Respectfully Submitted,
THE COCHRAN FIRM
Derek S Sells,hq
Stephanie R. Correa, Esq.
One Exchange Plaza
23d
55 Broadway, Floor
New York, New York 10006
(Tel No.) (212) 553-9215
(Facsimile) (212) 227-8763
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022
CERTIFICATE OF SERVICE
14*
On the day of February 2017, a tme and accurate copy of NOTICE OF
DEPOSITION UPON ORAL EXAMINATION was served by FIRST CLASS MAIL to the
following attorneys:
Vincent Gelardi, Esq.
THE DEIORIO LAW GROUP, PLLC
Attorney forDefendants
800 Westchester Avenue, Suite S-608
Rye Brook, New York 10573
STEP R. CO REA
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
_____.---------------------------------X
KENNETH REMBERT, Index No.: 303885/2016
Plaintiff,
-against-
JUDICIAL SUBPOENA
FORCE SERVICES, LLC, LUIGI FALCIANO,
DAMON FAVILLO, DANIEL STOKES, and JOHN
AND JANE DOES, said names being fictitious and
intended to represent individual employees of Force
Services, LLC,
Defendants.
---------------------------------X
THE PEOPLE OF THE STATE OF NEW YORK
TO: Daniel Stokes
3057 Randall Avenue
Bronx, New York 10465
YOU ARE HEREBY COMMANDED, that allbusiness and excuses being laid aside, to
25th at 10:00 upon
appear on the day of May, 2022 a.m., to testifyat deposition oral examination
in the above case which will be held via remote video deposition services (Zoom), and you are
further commanded to produce any and alldocuments and allother deeds, evidences and writings,
which you now have in your custody or power, conceming the events underlying the captioned
lawsuit.
Failure to comply with thissubpoena ispunishable as a contempt of Court and shallmake
you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty
dollars and at damages sustained by reason of your failure to comply.
WITNESS, one of the Honorable Justices of said Court, at the Supreme Court, Bronx
78'
County on the day day ofApril 2022.
***PLEASE CONTACT 212-553-9213
TO CONFIRM THIS HEARING***
By: Tracey L. Brown, Esq.
THE COCHRAN FIRM
Attorneys forPlaintiff
23d
55 Broadway, Floor
New York, NY 10006
Tel No.: (212) 553-9213
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E
NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
_______________..---.-----___________x
KENNETH REMBERT, Index No.: 303885/2016
Plaintiff,
-against-
JUDICIAL SUBPOENA
FORCE SERVICES, LLC, LUIGI FALCIANO,
DAMON FAVILLO, DANIEL STOKES, and JOHN
AND JANE DOES, said names being fictitious and
intended to represent individual employees of Force
Services, LLC,
Defendants.
___________________-----------------Ç
THE PEOPLE OF THE STATE OF NEW YORK
TO: Damon Favillo
37 E.Figurea Avenue
Staten Island, New York 10308
YOU ARE HEREBY COMMANDED, thatall business and excuses being laidaside, to
appear on the 258 of 2022
day May, at 1:00 p.m., to testify atdeposition upon oral examination
in the above case which will be held via remote video deposition services (Zoom), and you are
further commanded to produce any and all documents and allother deeds, evidences and writings,
which you now have in your custody or power, concerning the events underlying the captioned
lawsuit.
Failure to comply with thissubpoena ispunishable as a contempt of Court and shall make
you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty
dollars and at datnages sustained by reason of your failure to comply.
WITNESS, one of the Honorable Justices of said Court, at the Supreme Court, Bronx
78'
County on the day day ofApril 2022.
***PLEASE CONTACT 212-553-9213
TO CONFIRM THIS HEARING***
By: Tracey L. Brown, Esq.
THE COCHRAN FIRM
Attorneys forPlaintiff
23d
55 Broadway, Floor
New York, NY 10006
Tel No.: (212) 553-9213
Preview
FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022 EXHIBIT 7 FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX _ ______..----------_____------------..x KENNETH REMBERT, Index No.: 303885/2016 Plaintiff, -against- FORCE SERVICES, LLC, LUIGI FALCIANO, NOTICE OF DEPOSITION DAMON FAVILLO, DANIEL STOKES and UPON ORAL EXAMINATION JOHN AND JANE DOES, said names being fictitious and intended to represent individual employees of Force Services, LLC, Defendants. ._.___..---___________---_..__----________Ç 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 Defendant Daniel Stokes will be taken before a notary public who is not an attorney, or employee of any attorney, for any party or prospective party herein and is nota person who would be disqualified to act as a juror because of interest or because of consanguinity or affinity to any party herein, at The Cochran Firm, One Exchange Plaza, 55 Broadway, 23rd Floor, New York, NY 10006, on a date and time to be mutually agreed upon, with respect to evidence material and necessary in the prosecution of this action. Dated: New York, New York February 14, 2017 Respectfully Submitted, THE COCHRAN FIRM Derek S. ells,Esq. Stephanie R. Correa, Esq. One Exchange Plaza 23'd 55 Broadway, Floor New York, New York 10006 (Tel No.) (212) 553-9215 (Facsimile) (212) 227-8763 FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022 CERTIFICATE OF SERVICE 14"' On the day of February 2017, a true and accurate copy of NOTICE OF DEPOSITION UPON ORAL EXAMINATION was served by FIRST CLASS MAIL to the following attorneys: Vincent Gelardi, Esq. THE DEIORIO LAW GROUP, PLLC Attorney for Defendants 800 Westchester Avenue, Suite S-608 Rye Brook, New York 10573 STEP IE R. ORREA FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX -------------------------------------X KENNETH REMBERT, Index No.: 303885/2016 Plaintiff, -against- FORCE SERVICES, LLC, LUIGI FALCIANO, NOTICE OF DEPOSITION DAMON FAVILLO, DANIEL STOKES and UPON ORAL EXAMINATION JOHN AND JANE DOES, said names being fictitious and intended to represent individual employees of Force Services, LLC, 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 Defendant Damon Favillo will be taken before a notary public who is not an attorney, or employee of any attorney, for any party or prospective party herein and isnot a person who would be disqualified to act as a juror because of interest or because of consanguinity or affinity to any party herein, at The Cochran Firm, One Exchange Plaza, 55 Broadway, 23rd Floor, New York, NY 10006, on a date and time to be mutually agreed upon, with respect to evidence material and necessary in the prosecution of this action. Dated: New York, New York February 14, 2017 Respectfully Submitted, TH COCHRAN FIRM Derek S.Sells, Esq. Stephanie R. Correa, Esq. One Exchange Plaza 23'd 55 Broadway, Floor New York, New York 10006 (Tel No.) (212) 553-9215 (Facsimile) (212) 227-8763 FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022 CERTIFICATE OF SERVICE 14* accurate of NOTICE OF On the day of February 2017, a true and copy DEPOSITION UPON ORAL EXAMINATION was served by FIRST CLASS MAIL to the following attorneys: Vincent Gelardi, Esq. THE DEIORIO LAW GROUP, PLLC Attorney for Defendants 800 Westchester Avenue, Suite S-608 Rye Brook, New York 10573 STEP R. CORREA FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX ..____x KENNETH REMBERT, Index No.: 303885/2016 Plaintiff, -against- FORCE SERVICES, LLC, LUIGI FALCIANO, NOTICE OF DEPOSITION DAMON FAVILLO, DAN1EL STOKES and UPON ORAL EXAMINATION JOHN AND JANE DOES, said names being fictitious and intended to represent individual employees of Force Services, LLC, Defendants. ________________----,._____________________Ç 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 Defendant Luigi Falciano will be taken before a notary public who is not an attorney, or employee of any 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 consanguinity or affmity to any party herein, at The Cochran Firm, One Exchange Plaza, 55 Broadway, 23rd Floor, New York, NY 10006, on a date and time to be mutually agreed upon, with respect to evidence material and necessary in the prosecution of thisaction. Dated: New York, New York February 14, 2017 Respectfully Submitted, THE COCHRAN FIRM Derek S Sells,hq Stephanie R. Correa, Esq. One Exchange Plaza 23d 55 Broadway, Floor New York, New York 10006 (Tel No.) (212) 553-9215 (Facsimile) (212) 227-8763 FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022 CERTIFICATE OF SERVICE 14* On the day of February 2017, a tme and accurate copy of NOTICE OF DEPOSITION UPON ORAL EXAMINATION was served by FIRST CLASS MAIL to the following attorneys: Vincent Gelardi, Esq. THE DEIORIO LAW GROUP, PLLC Attorney forDefendants 800 Westchester Avenue, Suite S-608 Rye Brook, New York 10573 STEP R. CO REA FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX _____.---------------------------------X KENNETH REMBERT, Index No.: 303885/2016 Plaintiff, -against- JUDICIAL SUBPOENA FORCE SERVICES, LLC, LUIGI FALCIANO, DAMON FAVILLO, DANIEL STOKES, and JOHN AND JANE DOES, said names being fictitious and intended to represent individual employees of Force Services, LLC, Defendants. ---------------------------------X THE PEOPLE OF THE STATE OF NEW YORK TO: Daniel Stokes 3057 Randall Avenue Bronx, New York 10465 YOU ARE HEREBY COMMANDED, that allbusiness and excuses being laid aside, to 25th at 10:00 upon appear on the day of May, 2022 a.m., to testifyat deposition oral examination in the above case which will be held via remote video deposition services (Zoom), and you are further commanded to produce any and alldocuments and allother deeds, evidences and writings, which you now have in your custody or power, conceming the events underlying the captioned lawsuit. Failure to comply with thissubpoena ispunishable as a contempt of Court and shallmake you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and at damages sustained by reason of your failure to comply. WITNESS, one of the Honorable Justices of said Court, at the Supreme Court, Bronx 78' County on the day day ofApril 2022. ***PLEASE CONTACT 212-553-9213 TO CONFIRM THIS HEARING*** By: Tracey L. Brown, Esq. THE COCHRAN FIRM Attorneys forPlaintiff 23d 55 Broadway, Floor New York, NY 10006 Tel No.: (212) 553-9213 FILED: BRONX COUNTY CLERK 09/20/2022 12:25 PM INDEX NO. 303885/2016E NYSCEF DOC. NO. 46 RECEIVED NYSCEF: 09/20/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX _______________..---.-----___________x KENNETH REMBERT, Index No.: 303885/2016 Plaintiff, -against- JUDICIAL SUBPOENA FORCE SERVICES, LLC, LUIGI FALCIANO, DAMON FAVILLO, DANIEL STOKES, and JOHN AND JANE DOES, said names being fictitious and intended to represent individual employees of Force Services, LLC, Defendants. ___________________-----------------Ç THE PEOPLE OF THE STATE OF NEW YORK TO: Damon Favillo 37 E.Figurea Avenue Staten Island, New York 10308 YOU ARE HEREBY COMMANDED, thatall business and excuses being laidaside, to appear on the 258 of 2022 day May, at 1:00 p.m., to testify atdeposition upon oral examination in the above case which will be held via remote video deposition services (Zoom), and you are further commanded to produce any and all documents and allother deeds, evidences and writings, which you now have in your custody or power, concerning the events underlying the captioned lawsuit. Failure to comply with thissubpoena ispunishable as a contempt of Court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars and at datnages sustained by reason of your failure to comply. WITNESS, one of the Honorable Justices of said Court, at the Supreme Court, Bronx 78' County on the day day ofApril 2022. ***PLEASE CONTACT 212-553-9213 TO CONFIRM THIS HEARING*** By: Tracey L. Brown, Esq. THE COCHRAN FIRM Attorneys forPlaintiff 23d 55 Broadway, Floor New York, NY 10006 Tel No.: (212) 553-9213