Preview
FILED: NEW YORK COUNTY CLERK 06/22/2022 04:32 PM INDEX NO. 150436/2019
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/22/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
CARMEN ROMERO,
NOTICE TO ADMIT
Plaintiff,
-against. Index No.: 150436/2019
THE CITY OF NEW YORK, THE CITY OF
NEW YORK DEPARTMENT OF
TRANSPORTATION, THE NEW YORK CITY
DEPARTMENT OF EDUCATION,
CONSOLIDATED EDISON COMPANY OF
NEW YORK, INC. and CONSOLIDATED
EDISON, INC.,
Defendants.
PLEASE TAKE NOTICE that Defendants CONSOLIDATED EDISON COMPANY
OF NEW YORK, INC. and CONSOLIDATED EDISON, INC., are required within twenty (20)
days after the service of this Notice upon you, for the purpose of this action, to admit the
following information pursuant to CPLR 3122:
1. That on July 25, 2018 Defendant CONSOLIDATED EDISON COMPANY OF
NEW YORK, INC. owned the cover or grating located in front of The Professor
Juan Bosch School, PS 178, 12-18 Ellwood Street, New York, NY 10040, in the
County, City and State of New York, and further depicted within the attached
photo, Exhibit A.
Admit Deny
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NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/22/2022
2. That on July 25, 2018 Defendant CONSOLIDATED EDISON COMPANY OF
NEW YORK, INC. monitored the cover, grating and concrete pads installed
around the cover or grating and the area extending twelve inches outward from
the edge of the cover, grating or concrete pad, located in front of The Professor
Juan Bosch School, PS 178, 12-18 Ellwood Street, New York, NY 10040, in the
County, City and State of New York, and further depicted within the attached
photo, Exhibit A.
Admit Deny
3. That on July 25, 2018 Defendant CONSOLIDATED EDISON, INC. owned the
cover or located in front of The Professor Juan Bosch PS 12-
grating School, 178,
18 Ellwood Street, New York, NY 10040, in the County, City and State of New
York, and further depicted within the attached photo, Exhibit A.
Admit Deny
4. That on July 25, 2018 Defendant CONSOLIDATED EDISON, INC. monitored
the cover, grating and concrete pads installed around the cover or grating and the
area extending twelve inches outward from the edge of the cover, grating or
concrete pad, located in front of The Professor Juan Bosch School, PS 178, 12-18
Ellwood Street, New York, NY 10040, in the County, City and State of New
York, and further depicted within the attached photo, Exhibit A.
Admit Deny
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FILED: NEW YORK COUNTY CLERK 06/22/2022 04:32 PM INDEX NO. 150436/2019
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/22/2022
PLEASE TAKE FURTHER NOTICE that your failure to respond to this Notice to
Admit within twenty (20) days will be deemed to be an admission of the allegations set forth
herein.
Dated: New York, New York
June 22, 2022
Yours, etc.
S dam Rubin, Esq.
TEVEN ADAM RUBIN & ASSOCIATE ,
Attorneys for Plaintiff
CARMEN ROMERO
71 West 23rd Street, Suite 1623
New York, New York 10010
(212) 643-5402
TO: NADINE RIVERLLESE
Attorney for Defendants
CONSOLIDATED EDISON COMPANY
OF NEW YORK, INC. and
CONSOLIDATED EDISON, INC.
4 Irving Place, Room 1800
New York, NY 10003-3598
SYLVIA HINDS-RADIX
Acting Corporation Counsel for:
THE CITY OF NEW YORK,
THE NEW YORK CITY
DEPARTMENT OF TRANSPORTATION,
AND THE NEW YORK CITY
DEPARTMENT OF EDUCATION
100 Church Street
New York, NY 10007
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Exhibit A
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FILED: NEW YORK COUNTY CLERK INDEX NO.
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exuisit DOC.
NYSCEF NO. 33 RECEIVED NYSCEF: 06/22/2022
plf 3 4-26-22 SK
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Scanned with CamScanner
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Preview
FILED: NEW YORK COUNTY CLERK 06/22/2022 04:32 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/22/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK CARMEN ROMERO, NOTICE TO ADMIT Plaintiff, -against. Index No.: 150436/2019 THE CITY OF NEW YORK, THE CITY OF NEW YORK DEPARTMENT OF TRANSPORTATION, THE NEW YORK CITY DEPARTMENT OF EDUCATION, CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. and CONSOLIDATED EDISON, INC., Defendants. PLEASE TAKE NOTICE that Defendants CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. and CONSOLIDATED EDISON, INC., are required within twenty (20) days after the service of this Notice upon you, for the purpose of this action, to admit the following information pursuant to CPLR 3122: 1. That on July 25, 2018 Defendant CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. owned the cover or grating located in front of The Professor Juan Bosch School, PS 178, 12-18 Ellwood Street, New York, NY 10040, in the County, City and State of New York, and further depicted within the attached photo, Exhibit A. Admit Deny 1 of 5 FILED: NEW YORK COUNTY CLERK 06/22/2022 04:32 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/22/2022 2. That on July 25, 2018 Defendant CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. monitored the cover, grating and concrete pads installed around the cover or grating and the area extending twelve inches outward from the edge of the cover, grating or concrete pad, located in front of The Professor Juan Bosch School, PS 178, 12-18 Ellwood Street, New York, NY 10040, in the County, City and State of New York, and further depicted within the attached photo, Exhibit A. Admit Deny 3. That on July 25, 2018 Defendant CONSOLIDATED EDISON, INC. owned the cover or located in front of The Professor Juan Bosch PS 12- grating School, 178, 18 Ellwood Street, New York, NY 10040, in the County, City and State of New York, and further depicted within the attached photo, Exhibit A. Admit Deny 4. That on July 25, 2018 Defendant CONSOLIDATED EDISON, INC. monitored the cover, grating and concrete pads installed around the cover or grating and the area extending twelve inches outward from the edge of the cover, grating or concrete pad, located in front of The Professor Juan Bosch School, PS 178, 12-18 Ellwood Street, New York, NY 10040, in the County, City and State of New York, and further depicted within the attached photo, Exhibit A. Admit Deny 2 of 5 FILED: NEW YORK COUNTY CLERK 06/22/2022 04:32 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/22/2022 PLEASE TAKE FURTHER NOTICE that your failure to respond to this Notice to Admit within twenty (20) days will be deemed to be an admission of the allegations set forth herein. Dated: New York, New York June 22, 2022 Yours, etc. S dam Rubin, Esq. TEVEN ADAM RUBIN & ASSOCIATE , Attorneys for Plaintiff CARMEN ROMERO 71 West 23rd Street, Suite 1623 New York, New York 10010 (212) 643-5402 TO: NADINE RIVERLLESE Attorney for Defendants CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. and CONSOLIDATED EDISON, INC. 4 Irving Place, Room 1800 New York, NY 10003-3598 SYLVIA HINDS-RADIX Acting Corporation Counsel for: THE CITY OF NEW YORK, THE NEW YORK CITY DEPARTMENT OF TRANSPORTATION, AND THE NEW YORK CITY DEPARTMENT OF EDUCATION 100 Church Street New York, NY 10007 3 of 5 FILED: NEW YORK COUNTY CLERK 06/22/2022 04:32 PM INDEX NO. 150436/2019 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/22/2022 Exhibit A 4 of 5 FILED: NEW YORK COUNTY CLERK INDEX NO. 06/22/2022 150436/2019 04:32 exuisit DOC. NYSCEF NO. 33 RECEIVED NYSCEF: 06/22/2022 plf 3 4-26-22 SK . Scanned with CamScanner 5 of 5