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FILED: KINGS COUNTY CLERK 04/21/2017 11:02 AM INDEX NO. 523101/2016
NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 04/21/2017
SUPREME COURT OF THE STATE OF NEW YORK
COI.INTY OF KINGS
MINEL JOHNSON and ANSEL JOHNSON, Index No.:
s2310v20r6
Plaintiffs,
-against- NOTICE TO TAKE
DEPOSITION UPON
BERNARD RIMPEL, UMESH MISHRA, JOSEPH ORAL EXAMINATION
DERGAN, SARINA CRANAGE, STACEY OF DEFENDANT
MARTINDALE, AMER HOMSI, DAVID UMESH MISHRA
SCHANER and THE BROOKLYN HOSPITAL
CENTER,
__ :_'.:_11ï'i______.
SIRS:
PLEASE TAKE NOTICE, that pursuant to Article 3l of the CPLR, the testimony, upon
oral examination of the defendant UMESH MISHRA. as an adverse party will be taken before a
Notary Public who is not an attorney, or 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 interest or
because of consanguinity or affinity to any party herein, on the 20tb day of June 2017, at l0
o'clock in the forenoon at the office of the attorney for plaintiff(s), GURFEIN DOUGLAS LLP,
located at 1l Park Place, Suite I 100, New York, N.Y. 10007, and continue from day to day until
completed with respect to evidence material and necessary in the prosecution of this action, and
said deposition shall be videotaped and the videotape operator will be an employee of GURFEIN
DOUGLAS LLP, I I Park Place, Suite I 100, New York, N.Y. 10007, and may be either RICHARD
A. GURFEIN, PRESTON J. DOUGLAS or KENNETH LO.
Defendants are required to produce at that examination the following records and papers
in its possession, custody, or control: All books, documents, papers, records, memoranda,
photographs, correspondence and/or any exhibit purporting to be a trustworthy and accurate
representation of information stored in a computer system as a business record, in the possession,
custody and control of the defendants regarding the incident in question and any exhibit in your
possession previously marked at an Examination Before Trial or previously provided by you in
the course of discovery.
Dated: New York, NY
April14,2017
1 of 3
FILED: KINGS COUNTY CLERK 04/21/2017 11:02 AM INDEX NO. 523101/2016
NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 04/21/2017
GURFEIN DOUGLAS LLP
Attorneys for Plaintiffs JOHNSON
1l Park - Suite l1
New Y
(212) 406-
BY:
LAS
TO:
ELLENBERG & PARTNERS LLP
Attorney for Defendant RIMPEL
494 Eighth Avenue - 7th fl.
New York NY 10001
(2r2) 629-8s8s
BENVENUTO & SLATTERY
Attorneys for Defendants SCHANER and CRANAGE
1800 Northem Boulevard
Roslyn NY I1576
(516) 77s-2236
DOPF, P.C.
Aftorneys for Defendants DERGAN, HOMSI,
MARTINDALE, MISHRA and THE BROOKLYN
HOSPITAL CENTER
440 Ninth Avenue - 16th fl.
New York NY 10001
(2r2)244-9090
2 of 3
FILED: KINGS COUNTY CLERK 04/21/2017 11:02 AM INDEX NO. 523101/2016
NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 04/21/2017
AFFIDAVIT OF SERVICE BY MAIL
STATEOFNEWYORK )
SS.
coUNTYoFNEWYORK )
REGINA COLONNA, being duly sworn, deposes and says: I am over the age of l8 years and not
a party to this action and reside in Staten Island, New York.
On April 21,2017, I served the NOTICE TO TAKE DEPOSITION UPON ORAL
EXAMINATION OF DEf,'ENDANT UMESH MISHRA in a sealed envelope, with postage
prepaid thereon, in a post-office or official depository of the United States Postal Service within
the St¿te of New York, addressed to the last known address of the addressee(s) as listed below,
and by electronic filing..
DOPF, P.C.
Attorneys for Defendants DERGAN, HOMSI,
MARTINDALE, MISHRA and THE BROOKLYN
HOSPITAL CENTER
440 Ninth Avenue - 16û'fl.
New YorkNY 10001
(2r2)244-9090
Electronic Filing Only On:
BENVENUTO & SLATTERY
Attorneys for Defendants SCHANER and CRANAGE
I 800 Northern Boulevard
RoslynNY 11576
(st6)77s-2236
ELLENBERG & PARTNERS LLP
Attorney for Defendant RIMPEL
494 Eighth Avenue - 7th fl.
NewYorkNY 10001
(2t2) 629-8s8s
Colonna
Sworn to before me on
The 2lst day of Aprilz0l7
SHARYN cohttN
Non'y Pñbr'.*i$ïlå€yå/ ¿,,ibo? a kâ a
in Kings
N Qualitiäd
ËlPirø
? ¿) /7
3 of 3
Preview
FILED: KINGS COUNTY CLERK 04/21/2017 11:02 AM INDEX NO. 523101/2016 NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 04/21/2017 SUPREME COURT OF THE STATE OF NEW YORK COI.INTY OF KINGS MINEL JOHNSON and ANSEL JOHNSON, Index No.: s2310v20r6 Plaintiffs, -against- NOTICE TO TAKE DEPOSITION UPON BERNARD RIMPEL, UMESH MISHRA, JOSEPH ORAL EXAMINATION DERGAN, SARINA CRANAGE, STACEY OF DEFENDANT MARTINDALE, AMER HOMSI, DAVID UMESH MISHRA SCHANER and THE BROOKLYN HOSPITAL CENTER, __ :_'.:_11ï'i______. SIRS: PLEASE TAKE NOTICE, that pursuant to Article 3l of the CPLR, the testimony, upon oral examination of the defendant UMESH MISHRA. as an adverse party will be taken before a Notary Public who is not an attorney, or 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 interest or because of consanguinity or affinity to any party herein, on the 20tb day of June 2017, at l0 o'clock in the forenoon at the office of the attorney for plaintiff(s), GURFEIN DOUGLAS LLP, located at 1l Park Place, Suite I 100, New York, N.Y. 10007, and continue from day to day until completed with respect to evidence material and necessary in the prosecution of this action, and said deposition shall be videotaped and the videotape operator will be an employee of GURFEIN DOUGLAS LLP, I I Park Place, Suite I 100, New York, N.Y. 10007, and may be either RICHARD A. GURFEIN, PRESTON J. DOUGLAS or KENNETH LO. Defendants are required to produce at that examination the following records and papers in its possession, custody, or control: All books, documents, papers, records, memoranda, photographs, correspondence and/or any exhibit purporting to be a trustworthy and accurate representation of information stored in a computer system as a business record, in the possession, custody and control of the defendants regarding the incident in question and any exhibit in your possession previously marked at an Examination Before Trial or previously provided by you in the course of discovery. Dated: New York, NY April14,2017 1 of 3 FILED: KINGS COUNTY CLERK 04/21/2017 11:02 AM INDEX NO. 523101/2016 NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 04/21/2017 GURFEIN DOUGLAS LLP Attorneys for Plaintiffs JOHNSON 1l Park - Suite l1 New Y (212) 406- BY: LAS TO: ELLENBERG & PARTNERS LLP Attorney for Defendant RIMPEL 494 Eighth Avenue - 7th fl. New York NY 10001 (2r2) 629-8s8s BENVENUTO & SLATTERY Attorneys for Defendants SCHANER and CRANAGE 1800 Northem Boulevard Roslyn NY I1576 (516) 77s-2236 DOPF, P.C. Aftorneys for Defendants DERGAN, HOMSI, MARTINDALE, MISHRA and THE BROOKLYN HOSPITAL CENTER 440 Ninth Avenue - 16th fl. New York NY 10001 (2r2)244-9090 2 of 3 FILED: KINGS COUNTY CLERK 04/21/2017 11:02 AM INDEX NO. 523101/2016 NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 04/21/2017 AFFIDAVIT OF SERVICE BY MAIL STATEOFNEWYORK ) SS. coUNTYoFNEWYORK ) REGINA COLONNA, being duly sworn, deposes and says: I am over the age of l8 years and not a party to this action and reside in Staten Island, New York. On April 21,2017, I served the NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION OF DEf,'ENDANT UMESH MISHRA in a sealed envelope, with postage prepaid thereon, in a post-office or official depository of the United States Postal Service within the St¿te of New York, addressed to the last known address of the addressee(s) as listed below, and by electronic filing.. DOPF, P.C. Attorneys for Defendants DERGAN, HOMSI, MARTINDALE, MISHRA and THE BROOKLYN HOSPITAL CENTER 440 Ninth Avenue - 16û'fl. New YorkNY 10001 (2r2)244-9090 Electronic Filing Only On: BENVENUTO & SLATTERY Attorneys for Defendants SCHANER and CRANAGE I 800 Northern Boulevard RoslynNY 11576 (st6)77s-2236 ELLENBERG & PARTNERS LLP Attorney for Defendant RIMPEL 494 Eighth Avenue - 7th fl. NewYorkNY 10001 (2t2) 629-8s8s Colonna Sworn to before me on The 2lst day of Aprilz0l7 SHARYN cohttN Non'y Pñbr'.*i$ïlå€yå/ ¿,,ibo? a kâ a in Kings N Qualitiäd ËlPirø ? ¿) /7 3 of 3