Preview
FILED: KINGS COUNTY CLERK 08/31/2020 01:55 PM INDEX NO. 521850/2018
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 08/31/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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ANGEL CHASI,
Index No.: 521850/2018
Plaintiff,
-against- NOTICE TO TAKE
NON-PARTY DEPOSITION
8801 SHORE ROAD BUILDING CORPORATION,
AARON PORET REAL ESTATE and HOWARD
PO RET,
Defendants.
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PLEASE TAKE NOTICE that that, in accordance with the New York Civil Practice
Law and Rules, Defendants 8801 Shore Road Building Corporation and Howard Poret
("Defendants"), by and through their undersigned attorneys, Nicoletti Hornig & Sweeney, have
duly served or will cause to be served, the Subpoena Ad Testificandum ("Subpoena") annexed
hereto. The particulars set forth in the annexed Subpoena are incorporated by reference into this
Notice and made a part hereof.
Dated: New York, New York
August 31, 2020
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FILED: KINGS COUNTY CLERK 08/31/2020 01:55 PM INDEX NO. 521850/2018
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 08/31/2020
Yours, etc.,
NICOLETTI HORNIG & SWEENEY
Attorneys for Defendants
8801 SHORE ROAD BUILDING
CO TION and HOWARD PO RET
Barbar . Sheehan, Esq.
Dylan B. Weeks, Esq.
Wall Street Plaza
88 Pine Street, 7th Floor
New York, New York 10005
(212) 220-3830
Our File: 91000294 BAS/DBW
TO:
VIA EMAIL & NYSCEF
Carmine Goncalves, Esq.
WINGATE, RUSSOTTI, SHAPIRO & HALPERIN, LLP
Attorneys for Plaintiff
420 Lexington Avenue, Suite 2750
New York, New York 10170
(212) 986-7353
X: \Public Word Files\91 1294\LEGAL\Notice of Non-Party EBT -08-31-2020-s-mardocx
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FILED: KINGS COUNTY CLERK 08/31/2020 01:55 PM INDEX NO. 521850/2018
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 08/31/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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ANGEL CHASI,
Index No.: 521850/2018
Plaintiff,
-against- SUBPOENA AD
TESTIFICANDUM
8801 SHORE ROAD BUILDING CORPORATION,
AARON PORET REAL ESTATE and HOWARD
PO RET,
Defendants.
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THE PEOPLE OF THE STATE OF NEW YORK
TO: Alex De Leon
1852 67th Street
Brooklyn, NY 11204
GREETINGS:
WE COMMAND YOU, that all business and excuses being laid aside, that you appear
and attend before Nicoletti Hornig & Sweeney, attorneys for 8801 SHORE ROAD BUILDING
CORPORATION and HOWARD PORET, at their offices at Wall Street Plaza, 88 Pine Street,
7th Floor, New York, New York, on October 13, 2020 at 10:00 AM, and at any recessed or
adjourned date, to testify and give evidence as a witness before the trial of the above-entitled
action.
Your testimony is sought because you have been identified as a witness to the incident that
is the subject of the present litigation, in which plaintiff Angel Chasi ("Plaintiff') alleges he
sustained injuries while performing construction work on July 18, 2018, at or near 8801 Shore
Road, Brooklyn, New York. Demand is further made that you bring with you any documents or
photographs in your possession related to this incident.
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FILED: KINGS COUNTY CLERK 08/31/2020 01:55 PM INDEX NO. 521850/2018
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 08/31/2020
Failure to comply with this subpoena is punishable 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
($50.00) dollars and all damages sustained by reason of your failure to comply.
Dated: New York, New York
August 31, 2020
Yours, etc.,
NICOLETTI HORNIG & SWEENEY
Attorneys for Defendants
8801 SHORE ROAD BUILDING
CORPO ON and HOWARD PORET
arbara A. Sheehan, Esq.
Dy Ian B. Weeks, Esq.
Wall Street Plaza
88 Pine Street, 7th Floor
New York, New York 10005
(212) 220-3830
Our File: 91000294 BAS/DBW
*PLEASE CONTACT DYLAN B. WEEKS, ESQ. AT (646) 306-7866 IN ADVANCE OF
OCTOBER 13, 2020 TO DISCUSS ARRANGEMENTS FOR THE DEPOSITION.*
X:\Public Word Files\91\294\LEGAL\Non-Pa11y Subpoena to Alex De Leon-08-31-2020.docx
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Preview
FILED: KINGS COUNTY CLERK 08/31/2020 01:55 PM INDEX NO. 521850/2018 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 08/31/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------)( ANGEL CHASI, Index No.: 521850/2018 Plaintiff, -against- NOTICE TO TAKE NON-PARTY DEPOSITION 8801 SHORE ROAD BUILDING CORPORATION, AARON PORET REAL ESTATE and HOWARD PO RET, Defendants. -------------------------------------------------------------------)( PLEASE TAKE NOTICE that that, in accordance with the New York Civil Practice Law and Rules, Defendants 8801 Shore Road Building Corporation and Howard Poret ("Defendants"), by and through their undersigned attorneys, Nicoletti Hornig & Sweeney, have duly served or will cause to be served, the Subpoena Ad Testificandum ("Subpoena") annexed hereto. The particulars set forth in the annexed Subpoena are incorporated by reference into this Notice and made a part hereof. Dated: New York, New York August 31, 2020 1 of 4 FILED: KINGS COUNTY CLERK 08/31/2020 01:55 PM INDEX NO. 521850/2018 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 08/31/2020 Yours, etc., NICOLETTI HORNIG & SWEENEY Attorneys for Defendants 8801 SHORE ROAD BUILDING CO TION and HOWARD PO RET Barbar . Sheehan, Esq. Dylan B. Weeks, Esq. Wall Street Plaza 88 Pine Street, 7th Floor New York, New York 10005 (212) 220-3830 Our File: 91000294 BAS/DBW TO: VIA EMAIL & NYSCEF Carmine Goncalves, Esq. WINGATE, RUSSOTTI, SHAPIRO & HALPERIN, LLP Attorneys for Plaintiff 420 Lexington Avenue, Suite 2750 New York, New York 10170 (212) 986-7353 X: \Public Word Files\91 1294\LEGAL\Notice of Non-Party EBT -08-31-2020-s-mardocx 2 2 of 4 FILED: KINGS COUNTY CLERK 08/31/2020 01:55 PM INDEX NO. 521850/2018 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 08/31/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------)( ANGEL CHASI, Index No.: 521850/2018 Plaintiff, -against- SUBPOENA AD TESTIFICANDUM 8801 SHORE ROAD BUILDING CORPORATION, AARON PORET REAL ESTATE and HOWARD PO RET, Defendants. -------------------------------------------------------------------)( THE PEOPLE OF THE STATE OF NEW YORK TO: Alex De Leon 1852 67th Street Brooklyn, NY 11204 GREETINGS: WE COMMAND YOU, that all business and excuses being laid aside, that you appear and attend before Nicoletti Hornig & Sweeney, attorneys for 8801 SHORE ROAD BUILDING CORPORATION and HOWARD PORET, at their offices at Wall Street Plaza, 88 Pine Street, 7th Floor, New York, New York, on October 13, 2020 at 10:00 AM, and at any recessed or adjourned date, to testify and give evidence as a witness before the trial of the above-entitled action. Your testimony is sought because you have been identified as a witness to the incident that is the subject of the present litigation, in which plaintiff Angel Chasi ("Plaintiff') alleges he sustained injuries while performing construction work on July 18, 2018, at or near 8801 Shore Road, Brooklyn, New York. Demand is further made that you bring with you any documents or photographs in your possession related to this incident. 3 of 4 FILED: KINGS COUNTY CLERK 08/31/2020 01:55 PM INDEX NO. 521850/2018 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 08/31/2020 Failure to comply with this subpoena is punishable 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 ($50.00) dollars and all damages sustained by reason of your failure to comply. Dated: New York, New York August 31, 2020 Yours, etc., NICOLETTI HORNIG & SWEENEY Attorneys for Defendants 8801 SHORE ROAD BUILDING CORPO ON and HOWARD PORET arbara A. Sheehan, Esq. Dy Ian B. Weeks, Esq. Wall Street Plaza 88 Pine Street, 7th Floor New York, New York 10005 (212) 220-3830 Our File: 91000294 BAS/DBW *PLEASE CONTACT DYLAN B. WEEKS, ESQ. AT (646) 306-7866 IN ADVANCE OF OCTOBER 13, 2020 TO DISCUSS ARRANGEMENTS FOR THE DEPOSITION.* X:\Public Word Files\91\294\LEGAL\Non-Pa11y Subpoena to Alex De Leon-08-31-2020.docx 2 4 of 4