Preview
FILED: KINGS COUNTY CLERK 02/16/2021 09:11 AM INDEX NO. 520642/2017
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/16/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------X
BRAYAN TERRAZAS,
POST EBT DEMAND
Plainitff,
-against- Index No: 520642/17
THE CITY OF NEW YORK and
ARLENE HERSHBERG,
Defendants.
--------------------------------------------------------------X
C O U N S E L O R S:
PLEASE TAKE NOTICE, that pursuant to CPLR 3120, and the Rules of the Appellate
Division, demand is hereby made upon co-defendant, THE CITY OF NEW YORK, and/or its
attorneys to serve upon and deliver to the undersigned attorneys for the defendant, ARLENE
HERSHBERG, within twenty (20) days of receipt of this notice:
1. Copy of memo book for Officer Michael Genis;
2. Photos shown by Officer Genis during his deposition of February
5, 2021; and
3. Copy of aided card, witness statement and line of duty for
Officer Michael Genis regarding the accident of April 26, 2017.
PLEASE TAKE FURTHER NOTICE, that in the event plaintiffs should fail to comply
with this notice for discovery and inspection, a motion will be made seeking to impose sanctions
pursuant to CPLR 3126.
Dated: New York, New York
February 15, 2021
LAW OFFICES OF TOBIAS & KUHN
By: Alexa Rissoff
Attorneys for Defendant
1 of 4
FILED: KINGS COUNTY CLERK 02/16/2021 09:11 AM INDEX NO. 520642/2017
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/16/2021
ARLENE HERSHBERG
100 William Street, Suite 920
New York, NY 10038
(212) 553-8700
File No: Y81AL78404-001
TO: ZACHARY W. CARTER, ESQ.
Corporation Counsel
By: Jeffrey M. Murphy, Esq.
Attorneys for Defendant
CITY OF NEW YORK
350 Jay St., 8th Floor
Brooklyn, NY 11201
(718) 780-2566
DECOLATOR, COHEN & DiPRISCO, LLP
Attorneys for Plaintiff
BRAYAN TERRAZAS
1399 Franklin Ave, Suite 300
Garden City, NY 11530
(516) 742-6575
2 of 4
FILED: KINGS COUNTY CLERK 02/16/2021 09:11 AM INDEX NO. 520642/2017
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/16/2021
AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
) SS:
COUNTY OF NEW YORK )
MARIE SOUFFRANT-SANTIAGO, being duly sworn, deposes and says that she is employed in
the LAW OFFICES OF TOBIAS & KUHN, at 100 William Street, Suite 920, New York, New
York 10038, that on the 16th day of February, 2021, deponent, who is not a party to this action
and is over eighteen years of age, served the annexed – POST EBT DEMAND - upon:
ZACH ARY W. CARTER, ESQ. Attorneys for Defendant
Corporation Counsel CITY OF NEW YORK
By: Jeffrey M. Murphy, Esq. 350 Jay Street, 8th Floor
Brooklyn, NY 11201
jmmurphy@grsm.com
DECOLATOR, COHEN & DiPRISCO, LLP
Attorneys for Plaintiff- BRAYAN TERRAZAS
1399 Franklin Ave, Suite 300
Garden City, NY 11530
dcdlaw@yahoo.com
in this action, by the New York State Courts Electronic Filing Rules (NYSCEF) and pursuant to
CPLR 2214(b), herein directed to the email address(es) shown above, that being the email
address(es) consented and designated by said attorneys.
Sworn to before me this
16th day of February, 2021
File No.: Y81AL78404-001
3 of 4
FILED: KINGS COUNTY CLERK 02/16/2021 09:11 AM INDEX NO. 520642/2017
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/16/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
Index No.: 520642/17
BRAYAN TERRAZAS,
Plainitff,
-against-
THE CITY OF NEW YORK and
ARLENE HERSHBERG,
Defendants.
POST EBT DEMAND
LAW OFFICES OF TOBIAS & KUHN
Attorneys for Defendant
ARLENE HERSHBERG
Office and Post Office Address, Telephone
100 William Street, Suite 920
New York, NY 10038
(212) 553-8700
File No.: Y81AL78404-001
To:
Attorney(s) for
Service of a copy of the within
Is hereby admitted.
Dated: _______________________
______________________________
Attorneys for
4 of 4
Preview
FILED: KINGS COUNTY CLERK 02/16/2021 09:11 AM INDEX NO. 520642/2017 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/16/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------X BRAYAN TERRAZAS, POST EBT DEMAND Plainitff, -against- Index No: 520642/17 THE CITY OF NEW YORK and ARLENE HERSHBERG, Defendants. --------------------------------------------------------------X C O U N S E L O R S: PLEASE TAKE NOTICE, that pursuant to CPLR 3120, and the Rules of the Appellate Division, demand is hereby made upon co-defendant, THE CITY OF NEW YORK, and/or its attorneys to serve upon and deliver to the undersigned attorneys for the defendant, ARLENE HERSHBERG, within twenty (20) days of receipt of this notice: 1. Copy of memo book for Officer Michael Genis; 2. Photos shown by Officer Genis during his deposition of February 5, 2021; and 3. Copy of aided card, witness statement and line of duty for Officer Michael Genis regarding the accident of April 26, 2017. PLEASE TAKE FURTHER NOTICE, that in the event plaintiffs should fail to comply with this notice for discovery and inspection, a motion will be made seeking to impose sanctions pursuant to CPLR 3126. Dated: New York, New York February 15, 2021 LAW OFFICES OF TOBIAS & KUHN By: Alexa Rissoff Attorneys for Defendant 1 of 4 FILED: KINGS COUNTY CLERK 02/16/2021 09:11 AM INDEX NO. 520642/2017 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/16/2021 ARLENE HERSHBERG 100 William Street, Suite 920 New York, NY 10038 (212) 553-8700 File No: Y81AL78404-001 TO: ZACHARY W. CARTER, ESQ. Corporation Counsel By: Jeffrey M. Murphy, Esq. Attorneys for Defendant CITY OF NEW YORK 350 Jay St., 8th Floor Brooklyn, NY 11201 (718) 780-2566 DECOLATOR, COHEN & DiPRISCO, LLP Attorneys for Plaintiff BRAYAN TERRAZAS 1399 Franklin Ave, Suite 300 Garden City, NY 11530 (516) 742-6575 2 of 4 FILED: KINGS COUNTY CLERK 02/16/2021 09:11 AM INDEX NO. 520642/2017 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/16/2021 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) ) SS: COUNTY OF NEW YORK ) MARIE SOUFFRANT-SANTIAGO, being duly sworn, deposes and says that she is employed in the LAW OFFICES OF TOBIAS & KUHN, at 100 William Street, Suite 920, New York, New York 10038, that on the 16th day of February, 2021, deponent, who is not a party to this action and is over eighteen years of age, served the annexed – POST EBT DEMAND - upon: ZACH ARY W. CARTER, ESQ. Attorneys for Defendant Corporation Counsel CITY OF NEW YORK By: Jeffrey M. Murphy, Esq. 350 Jay Street, 8th Floor Brooklyn, NY 11201 jmmurphy@grsm.com DECOLATOR, COHEN & DiPRISCO, LLP Attorneys for Plaintiff- BRAYAN TERRAZAS 1399 Franklin Ave, Suite 300 Garden City, NY 11530 dcdlaw@yahoo.com in this action, by the New York State Courts Electronic Filing Rules (NYSCEF) and pursuant to CPLR 2214(b), herein directed to the email address(es) shown above, that being the email address(es) consented and designated by said attorneys. Sworn to before me this 16th day of February, 2021 File No.: Y81AL78404-001 3 of 4 FILED: KINGS COUNTY CLERK 02/16/2021 09:11 AM INDEX NO. 520642/2017 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/16/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No.: 520642/17 BRAYAN TERRAZAS, Plainitff, -against- THE CITY OF NEW YORK and ARLENE HERSHBERG, Defendants. POST EBT DEMAND LAW OFFICES OF TOBIAS & KUHN Attorneys for Defendant ARLENE HERSHBERG Office and Post Office Address, Telephone 100 William Street, Suite 920 New York, NY 10038 (212) 553-8700 File No.: Y81AL78404-001 To: Attorney(s) for Service of a copy of the within Is hereby admitted. Dated: _______________________ ______________________________ Attorneys for 4 of 4