On December 30, 2019 a
Party Discovery
was filed
involving a dispute between
Edgardo Hughes,
Yessenia Quezada-King,
and
New York City Health & Hospitals Corporation,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 01/21/2020 04:34 PM INDEX NO. 528184/2019
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/21/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--··------- ---·· ----··-- ---X
YESSENIA QUEZADA-KING and EDGARDO HUGHES,
Index No.: 528184/2019
Plaintiff,
NOTICE TO TAKE
-against- DEPOSITION UPON
ORAL EXAMINATION
NEW YORK CITY HEALTH & HOSPITALS
CORPORATION,
Defendant,
----.. ___.._ ..------··--------··---X
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules,
the testimony, upon oral examination of PLAINTIFFS, 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, at the office of KAUFMAN BORGEEST & RYAN
2nd
LLP located at 1205 Franklin Avenue, Floor, Garden City, New York, within thirty (30) days
of this notice at 10:00 o'clock in the forenoon of that day with respect to evideñce and material
necessary in the defense of this action.
That the said person to be examined is required to produce at such examination any and
alldocuments relative to the claims in the Plaintiff's Verified Complaint.
To the best of my knowledge, information and belief, formed after an inquiry reasonable under
the circumstances, the presentation of this paper or the contentions herein are not frivolous, as
that term is defined in Part 130 of the Court Rules.
6186144
1 of 2
FILED: KINGS COUNTY CLERK 01/21/2020 04:34 PM INDEX NO. 528184/2019
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/21/2020
Dated: Garden City, New York
January 21, 2020
Yours, etc.,
KAUFMAN BORGEEST & RYAN LLP
Of Counsel to Andrea Cohen,
General Counsel
NEW YORK CITY HEALTH AND HOSPITALS
CORPORATION
By:
Belinda Dodds-Marshall, Esq.
Attorneys for Defendant
NEW YORK CITY HEALTH AND HOSPITALS
CORPORATION, s/h/a NEW YORK CITY
HEALTH & HOSPITALS CORPORATION
2nd
1205 Franklin Avenue, Floor
Garden City, New York 11530
(516) 248-6000
KBR File No.: 961.057
TO: ROSENBERG, MINC, FALKOFF & WOLFF, LLP
Attorneys for Plaintiffs
42nd
122 East street, suite 3800
New York, New York 10168
(212) 697-9280
2
6186144
2 of 2
Preview
FILED: KINGS COUNTY CLERK 01/21/2020 04:34 PM INDEX NO. 528184/2019 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/21/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --··------- ---·· ----··-- ---X YESSENIA QUEZADA-KING and EDGARDO HUGHES, Index No.: 528184/2019 Plaintiff, NOTICE TO TAKE -against- DEPOSITION UPON ORAL EXAMINATION NEW YORK CITY HEALTH & HOSPITALS CORPORATION, Defendant, ----.. ___.._ ..------··--------··---X PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony, upon oral examination of PLAINTIFFS, 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, at the office of KAUFMAN BORGEEST & RYAN 2nd LLP located at 1205 Franklin Avenue, Floor, Garden City, New York, within thirty (30) days of this notice at 10:00 o'clock in the forenoon of that day with respect to evideñce and material necessary in the defense of this action. That the said person to be examined is required to produce at such examination any and alldocuments relative to the claims in the Plaintiff's Verified Complaint. To the best of my knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of this paper or the contentions herein are not frivolous, as that term is defined in Part 130 of the Court Rules. 6186144 1 of 2 FILED: KINGS COUNTY CLERK 01/21/2020 04:34 PM INDEX NO. 528184/2019 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/21/2020 Dated: Garden City, New York January 21, 2020 Yours, etc., KAUFMAN BORGEEST & RYAN LLP Of Counsel to Andrea Cohen, General Counsel NEW YORK CITY HEALTH AND HOSPITALS CORPORATION By: Belinda Dodds-Marshall, Esq. Attorneys for Defendant NEW YORK CITY HEALTH AND HOSPITALS CORPORATION, s/h/a NEW YORK CITY HEALTH & HOSPITALS CORPORATION 2nd 1205 Franklin Avenue, Floor Garden City, New York 11530 (516) 248-6000 KBR File No.: 961.057 TO: ROSENBERG, MINC, FALKOFF & WOLFF, LLP Attorneys for Plaintiffs 42nd 122 East street, suite 3800 New York, New York 10168 (212) 697-9280 2 6186144 2 of 2