Preview
FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX NO. 520801/2017
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 07/23/2019
EXHIBIT G
FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX
INDEX NO.
NO. 520801/2017
520801/2017
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 22
11 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/23/2019
05/31/2019
BLUMBERG'S
1AWPRODUCFS B 537 - Note of issue and certificate of readiness: Unifonn
Rules, 22 NYCPR202.21(b), 9-95 JuliusBlumbcrg, Inc.
Publisher NYC 10013
NOTE OF ISSUE
For use of Clerk
Calendar No. (ifany)
Index No. 520801/2017
Supreme Court, KINGS County, N.Y.
JEAN T. JACQÜÈT and GRACE JACQUET, hiswife Hon. Landicino
Name of Judge assigned
NOTICE FOR TRIAL
lilTrialby jurydemanded
O of allissues
O of issuesspecifiad below
O or attached hereto
O Trialwithout jury
Plaintif(s)
Filed by attorney for Plaintiff
Date summons served 10/30/2017
Date service completed 11/06/2017 ___
-against- Date issue joined 11/28/2017
A & W IRON WORK, INC. and NATURE OF ACTION OR SPECIAL PROCEEDING
TAKSON H. CHAN
O Tort: EMotor vehicle negligence
O Medical malpractice
O Other tort
O Contract
O Contested matrimonial
O Uncontested matrimcñial
O Tax certiorari
O Condemnation
O Other (not itemized above) specify
O This action is brought as a classaction
Defendant(s)
Amount demanded $100,000.00
Other relief
Special preference claimed under Insurance carrier,ifknown:
Country Wide Insurance Company
on the ground that
DAVIS, SAPERSTEIN & SALOMON, P.C.
Attorney(s) for Plaintiff(s)
Office & P. O.Address 39 Broadway, Suite 520
New York, NY 10005
Phone No.: (212) 608-1917
Cheven, Keely & Hatzis, Esqs.
Attorney(s) for Defenden!(s) A&W Iron Work Inc, and Tarson H. Chan
Office & P.O. Address 40 Wall 12u' floor
St.,
New York, NY 10005
Phone No.: 212-809-7600
NOTE: Clerk will not accept this note of issueunless accempeMed by a certificate of readiness.
1 of 2
FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX
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NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 22
11 RECEIVED
RECEIVED NYSCEF:
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CERTIFICATE OF READINESS FOR TRIAL
For Clerk's Use
(Items I-7 must be checked) N. I.Served
on
Completed Waived Not rcÿüired
1. All pleadings served x
2. Billof particularsserved x
3. Physical examinM= completed x
4. Medical reportsexchanged x
5. Compliance with the Rules in matrimcñial actions (22 NYCRR 202.16) x
6. Appraisal reports exchanged x
7. Discovery proceedings now known to be necessary csmpk:êd x
8. There are no outstanding requestsfordisecvery.
9. There has been a reaceneble cpponunity to complete the foregaing proceedings.
10. There has been comp!!rce with order issued pursuant to thePrecakMar Rules (22 NYCRR 202.12).
any
1 1. Ifa medice! malpractice action,there has been cesp!ime with any order issued pursuant to 22 NYCRR 202.56.
12. The case is readyfortrial.
Dated: May 31, 2019 a a JZ AJL#7
Rachael Nass
DAVIS, SAPERSTEIN & SALOMON, P.C.
Attorney(s) for Plaintiff(s)
Office & P.O. Address
39 Broadway, Suite520
New York, NY 10006
(212) 608-1917
State of New York, County of ss: State of New York, County of ss:
being duly sworn, deposesand says; that deponent is not a party to the action
being duly sworn, deposes and says; that deponent is not a party to the action,
is over 18 years of age and resides at is over 18 years of age and resides at
That on the day of 200 That on the day of 200
deponent served the within
note of issue and ccriificate
of readiness on note of issue and certificate of readiness on
deponent served the within
attorney(s) for attorney(s) for
herein, at his office
at at
during his absence from said office the address de:;ig:::::ed by said attorney(s) for that purpose by depositing a true
(a) by then and there leaving a true copy of the same with copy of same enclosed in addressed wrapper,
a postpaid properly in a post
office
depository under the exclusive care and custody of the United States
official
Postal his clerk; partner; person having charge of said office. New York State.
Service within
(b) and said office
being closed, by depositing a true copy of same, enclosed in a
sealed wrapper directed to said attorney(s), in the office
letter drop or box.
Sworn to before me on 200 Sworn to before me on 200
Admission of Service Due serviceof a noteof issue and certificateof readiness,of which the withinis a copy,
admitted 200
Attorney(s) for
2 of 2
FILED:
FILED : KINGS
KINGS COUNTY
COUNTY CLERK
CLERK 07/23/2019
05/31/2019 01:57
11: 38 PM
AM|
INDEX
INDEX NO.
NO. 520801/2017
520801/2017
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 22
12 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/23/2019
05/31/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------____..------
____...--------------- ------X
JEAN T. JACQUET and GRACE JACQUET, his wife IndeX #520801/2017
Plaintiff(s)
ATTORNEY'S
-against- AFFIRMATION
A & W IRON WORK, INC. and TAKSON H. CHAN
Defendant(s)
-----------------..----------------------------____________________-X
RACHAEL NASS, an attorney duly admitted to practice law before the Courts of the
State of New York, affirms the following under the penalty of perjury:
1. I am of counsel to the law firm of DAVIS, SAPERSTE1N & SALOMON, P.C.,
attorneys of record for the Plaintiff herein.
2. I am fully familiar with the facts and circumstances hereinafter set forth and submits
the within affirmation in support of Plaintiffs Note of Issue and Certificate of
Readiness.
3. The within is an action for personal injuries arisiñg from a motor vehicle accident
which occurred on December 7, 2015 when plaintiff's motor vehicle was struck in the
rear by defêñdant.
4. A Svs.reens and Verified Complaint were served upon the defeñdañts on or about
October 30, 2017. An Answer was received on or about November 16, 2017.
5. All known discovery has been completed, all directives contained within
1 of 2
FILED:
FILED : KINGS
KINGS COUNTY
COUNTY CLERK
CLERK 07/23/2019
05/31/2019 01:57
11: 38 PM INDEX
INDEX NO.
NO. 520801/2017
520801/2017
AM)
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 22
12 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/23/2019
05/31/2019
the Preliminary Conference Order and the Compliance Conference Order have
been met and this matter is ready to be placed on the trial calendar.
Dated: New York, New York
May 31, 2019
CHAEL NASS
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FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX
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520801/2017
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 22
13 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/23/2019
05/31/2019
AFFIDAVIT OF SERVICE
STATE OF NEW YORK }
} ss.:
COUNTY OF NEW YORK }
Elizabeth Maruri-Haz, being duly sworn, deposes and says: I am not a party to this action,
am over the age of 18 years and reside in Bergen County, New Jersey.
On May 31, 2019, I served a true copy of NOTE OF ISSUE/AFFIRMATION OF
COMPLIANCE, by mailing same in a sealed envelope, with postage pre-paid thereon, and placing
it in a post-office or official depository of the U.S. Postal Service within the State of New York,
addressed to the last known address of the addressee(s) as indicated below:
TO: CHEVEN, KEELY & HATZIS, ESQS.
Attorneys for Defendant (s)
A&W IRON WORK INC and TARSON H CHAN
40 Wall Street - 12th Floor
New York, New York 10005
(212) 809-7600
Eli abeth Maruri-Haz
Sworn to before me on the
31S'
day of May 2019
NOTARY PUBLIC
RACHAEL NASS
Notary Public, State of New York
No. 02NA6306151
Qualified in County of New York
Comm!ss!en Expires October 24,2022
1 of 3
FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX NO. 520801/2017
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 07/23/2019
NYSCEF DOC. NO. 13 REC
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS INDEX NO.: 520801/2017
JEAN T. JACQUET and GRACE JACQUET, his wife
Plaintiff(s)
-against-
A & W IRON WORK, INC. AND TAKSON H. CHAN
Defendant(s)
NOTE OF ISSUE
AFFIRMATION OF COMPLIANCE
DAVIS, SAPERSTElN & SALOMON, P.C.
Attorneys for Plaintiff(s)
39 Broadway, Suite 520
New York, New York 10006
(212) 608-1917
To:
Service of a copy of the within papers is hereby adraitted:
Dated: October 25, 2017
Attorney(s) for
PLEASE TAKE NOTICE
O that the within is a (certified) true copy of a
NOTICE OF entered in the off'ice of the clerk of the within named
ENTRY Court on , 20 .
O that an Order of which the within is a true copy will
NOTICE OF be presented for settlement to the Honorable
SETTLEMENT one of the judges of the within named Court, at
on
Dated:
DAVIS, SAPERSTEIN & SALOMON, P.C.
Attorneys for Plaintiff(s)
Preview
FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX NO. 520801/2017 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 07/23/2019 EXHIBIT G FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX INDEX NO. NO. 520801/2017 520801/2017 NYSCEF NYSCEF DOC. DOC. NO. NO. 22 11 RECEIVED RECEIVED NYSCEF: NYSCEF: 07/23/2019 05/31/2019 BLUMBERG'S 1AWPRODUCFS B 537 - Note of issue and certificate of readiness: Unifonn Rules, 22 NYCPR202.21(b), 9-95 JuliusBlumbcrg, Inc. Publisher NYC 10013 NOTE OF ISSUE For use of Clerk Calendar No. (ifany) Index No. 520801/2017 Supreme Court, KINGS County, N.Y. JEAN T. JACQÜÈT and GRACE JACQUET, hiswife Hon. Landicino Name of Judge assigned NOTICE FOR TRIAL lilTrialby jurydemanded O of allissues O of issuesspecifiad below O or attached hereto O Trialwithout jury Plaintif(s) Filed by attorney for Plaintiff Date summons served 10/30/2017 Date service completed 11/06/2017 ___ -against- Date issue joined 11/28/2017 A & W IRON WORK, INC. and NATURE OF ACTION OR SPECIAL PROCEEDING TAKSON H. CHAN O Tort: EMotor vehicle negligence O Medical malpractice O Other tort O Contract O Contested matrimonial O Uncontested matrimcñial O Tax certiorari O Condemnation O Other (not itemized above) specify O This action is brought as a classaction Defendant(s) Amount demanded $100,000.00 Other relief Special preference claimed under Insurance carrier,ifknown: Country Wide Insurance Company on the ground that DAVIS, SAPERSTEIN & SALOMON, P.C. Attorney(s) for Plaintiff(s) Office & P. O.Address 39 Broadway, Suite 520 New York, NY 10005 Phone No.: (212) 608-1917 Cheven, Keely & Hatzis, Esqs. Attorney(s) for Defenden!(s) A&W Iron Work Inc, and Tarson H. Chan Office & P.O. Address 40 Wall 12u' floor St., New York, NY 10005 Phone No.: 212-809-7600 NOTE: Clerk will not accept this note of issueunless accempeMed by a certificate of readiness. 1 of 2 FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX INDEX NO. NO. 520801/2017 520801/2017 NYSCEF NYSCEF DOC. DOC. NO. NO. 22 11 RECEIVED RECEIVED NYSCEF: NYSCEF: 07/23/2019 05/31/2019 CERTIFICATE OF READINESS FOR TRIAL For Clerk's Use (Items I-7 must be checked) N. I.Served on Completed Waived Not rcÿüired 1. All pleadings served x 2. Billof particularsserved x 3. Physical examinM= completed x 4. Medical reportsexchanged x 5. Compliance with the Rules in matrimcñial actions (22 NYCRR 202.16) x 6. Appraisal reports exchanged x 7. Discovery proceedings now known to be necessary csmpk:êd x 8. There are no outstanding requestsfordisecvery. 9. There has been a reaceneble cpponunity to complete the foregaing proceedings. 10. There has been comp!!rce with order issued pursuant to thePrecakMar Rules (22 NYCRR 202.12). any 1 1. Ifa medice! malpractice action,there has been cesp!ime with any order issued pursuant to 22 NYCRR 202.56. 12. The case is readyfortrial. Dated: May 31, 2019 a a JZ AJL#7 Rachael Nass DAVIS, SAPERSTEIN & SALOMON, P.C. Attorney(s) for Plaintiff(s) Office & P.O. Address 39 Broadway, Suite520 New York, NY 10006 (212) 608-1917 State of New York, County of ss: State of New York, County of ss: being duly sworn, deposesand says; that deponent is not a party to the action being duly sworn, deposes and says; that deponent is not a party to the action, is over 18 years of age and resides at is over 18 years of age and resides at That on the day of 200 That on the day of 200 deponent served the within note of issue and ccriificate of readiness on note of issue and certificate of readiness on deponent served the within attorney(s) for attorney(s) for herein, at his office at at during his absence from said office the address de:;ig:::::ed by said attorney(s) for that purpose by depositing a true (a) by then and there leaving a true copy of the same with copy of same enclosed in addressed wrapper, a postpaid properly in a post office depository under the exclusive care and custody of the United States official Postal his clerk; partner; person having charge of said office. New York State. Service within (b) and said office being closed, by depositing a true copy of same, enclosed in a sealed wrapper directed to said attorney(s), in the office letter drop or box. Sworn to before me on 200 Sworn to before me on 200 Admission of Service Due serviceof a noteof issue and certificateof readiness,of which the withinis a copy, admitted 200 Attorney(s) for 2 of 2 FILED: FILED : KINGS KINGS COUNTY COUNTY CLERK CLERK 07/23/2019 05/31/2019 01:57 11: 38 PM AM| INDEX INDEX NO. NO. 520801/2017 520801/2017 NYSCEF NYSCEF DOC. DOC. NO. NO. 22 12 RECEIVED RECEIVED NYSCEF: NYSCEF: 07/23/2019 05/31/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------____..------ ____...--------------- ------X JEAN T. JACQUET and GRACE JACQUET, his wife IndeX #520801/2017 Plaintiff(s) ATTORNEY'S -against- AFFIRMATION A & W IRON WORK, INC. and TAKSON H. CHAN Defendant(s) -----------------..----------------------------____________________-X RACHAEL NASS, an attorney duly admitted to practice law before the Courts of the State of New York, affirms the following under the penalty of perjury: 1. I am of counsel to the law firm of DAVIS, SAPERSTE1N & SALOMON, P.C., attorneys of record for the Plaintiff herein. 2. I am fully familiar with the facts and circumstances hereinafter set forth and submits the within affirmation in support of Plaintiffs Note of Issue and Certificate of Readiness. 3. The within is an action for personal injuries arisiñg from a motor vehicle accident which occurred on December 7, 2015 when plaintiff's motor vehicle was struck in the rear by defêñdant. 4. A Svs.reens and Verified Complaint were served upon the defeñdañts on or about October 30, 2017. An Answer was received on or about November 16, 2017. 5. All known discovery has been completed, all directives contained within 1 of 2 FILED: FILED : KINGS KINGS COUNTY COUNTY CLERK CLERK 07/23/2019 05/31/2019 01:57 11: 38 PM INDEX INDEX NO. NO. 520801/2017 520801/2017 AM) NYSCEF NYSCEF DOC. DOC. NO. NO. 22 12 RECEIVED RECEIVED NYSCEF: NYSCEF: 07/23/2019 05/31/2019 the Preliminary Conference Order and the Compliance Conference Order have been met and this matter is ready to be placed on the trial calendar. Dated: New York, New York May 31, 2019 CHAEL NASS 2 of 2 FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX INDEX NO. NO. 520801/2017 520801/2017 NYSCEF NYSCEF DOC. DOC. NO. NO. 22 13 RECEIVED RECEIVED NYSCEF: NYSCEF: 07/23/2019 05/31/2019 AFFIDAVIT OF SERVICE STATE OF NEW YORK } } ss.: COUNTY OF NEW YORK } Elizabeth Maruri-Haz, being duly sworn, deposes and says: I am not a party to this action, am over the age of 18 years and reside in Bergen County, New Jersey. On May 31, 2019, I served a true copy of NOTE OF ISSUE/AFFIRMATION OF COMPLIANCE, by mailing same in a sealed envelope, with postage pre-paid thereon, and placing it in a post-office or official depository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressee(s) as indicated below: TO: CHEVEN, KEELY & HATZIS, ESQS. Attorneys for Defendant (s) A&W IRON WORK INC and TARSON H CHAN 40 Wall Street - 12th Floor New York, New York 10005 (212) 809-7600 Eli abeth Maruri-Haz Sworn to before me on the 31S' day of May 2019 NOTARY PUBLIC RACHAEL NASS Notary Public, State of New York No. 02NA6306151 Qualified in County of New York Comm!ss!en Expires October 24,2022 1 of 3 FILED: KINGS COUNTY CLERK 07/23/2019 01:57 PM INDEX NO. 520801/2017 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 07/23/2019 NYSCEF DOC. NO. 13 REC SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS INDEX NO.: 520801/2017 JEAN T. JACQUET and GRACE JACQUET, his wife Plaintiff(s) -against- A & W IRON WORK, INC. AND TAKSON H. CHAN Defendant(s) NOTE OF ISSUE AFFIRMATION OF COMPLIANCE DAVIS, SAPERSTElN & SALOMON, P.C. Attorneys for Plaintiff(s) 39 Broadway, Suite 520 New York, New York 10006 (212) 608-1917 To: Service of a copy of the within papers is hereby adraitted: Dated: October 25, 2017 Attorney(s) for PLEASE TAKE NOTICE O that the within is a (certified) true copy of a NOTICE OF entered in the off'ice of the clerk of the within named ENTRY Court on , 20 . O that an Order of which the within is a true copy will NOTICE OF be presented for settlement to the Honorable SETTLEMENT one of the judges of the within named Court, at on Dated: DAVIS, SAPERSTEIN & SALOMON, P.C. Attorneys for Plaintiff(s)