Party Discovery: Crepini Llc v. Eugene Tulman, Boris Tulman, Mikhail Tulman, Cooltech Mechanical Corp., Cooltech Mechanical Group, Inc., Milmar Llc, Milmar Food Group, Llc, Milmar Food Group Ii, Llc, Mr Holding Company, Llc

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                                FILED:         KINGS       COUNTY         CLERK        02/17/2016             05:01       PM                        INDEX    NO.   509700/2015
   NYSCEF     DOC.   NO.   41                                                                                 RECEIVED      NYSCEF:     02/17/2016




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF KINGS
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                  CREPINI LLC,                                                                      Index No.:    509700/2015

                                                                                 Plaintiff,
                                                                                                    NOTICE OF
                                                    - against –                                     DEPOSITION

                  EUGENE TULMAN, BORRIS TULMAN, MIKHAIL
                  TULMAN, COOLTECH MECHANICAL CORP.,
                  COOLTECH MECHANICAL GROUP, INC.,
                  MILMAR LLC, MILMAR FOOD GROUP, LLC,
                  MILMAR FOOD GROUP II, LLC and
                  MR HOLDING COMPANY, LLC,

                                                                                 Defendants.
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                           PLEASE       TAKE     NOTICE,        that  pursuant   to  Article  31  of  the  Civil  Practice  Law    and

                  Rules, the testimony, upon oral examination of the plaintiff, Crepini LLC, by an individual having

                  personal knowledge of the facts pertaining to this litigation, as an adverse party, will be taken before

                  a Notary Public of the State of New York, 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 a juror

                  because of consanguinity or affinity to any party herein at the Law Office of Andrew Muchmore,

                  located at 217 Havemeyer Street, Brooklyn, New York                11211 on the 29th day of March, 2016 at

                  10:00   o'clock  in  the morning    of  that  day  with  respect   to evidence   material   and   necessary   in the

                  defense of this action.

                           PLEASE       TAKE     FURTHER        NOTICE,       that should   you  fail to  comply,   the  undersigned

                  will  move    this Court   pursuant    to CPLR     §  3126   for  such  relief, sanctions    and  penalties   as are

                  described therein.

                  Dated:   Brooklyn, New York
                           February 17, 2016
                                                                       LAW OFFICE OF ANDREW MUCHMORE
                                                                       Counsel for CoolTech Mechanical Corp.
                                                                       and CoolTech Mechanical Group, Inc.


                                                                       By:         /s/ Andrew Muchmore
                                                                                 Andrew Muchmore
                                                                       217 Havemeyer Street, 4th Floor
                                                                       Brooklyn, New York 11211
                                                                       (917) 932-0299