On April 08, 2021 a
Party Notice
was filed
involving a dispute between
Mary Louise Balsamo,
Robert Gest,
and
Nexus Enterprises, Inc. Dba Southampton Sunoco,
Sunoco Gas Station,
for Torts - Other Negligence (Trip & Fall)
in the District Court of Suffolk County.
Preview
FILED: SUFFOLK COUNTY CLERK 12/20/2021 02:52 PM INDEX NO. 606267/2021
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 12/20/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
---------------------------------- --------------------------X Index No.: 606267/2021
MARY LOUISE BALSAMO and ROBERT GEST,
Plaintiff(s),
-against- NOTICE FOR DISCOVERY
NEXUS ENTERPRISES, INC. DBA SOUTHAMPTON AND INSPECTION
SUNOCO and SUNOCO, INC.,
Defendant(s).
-------------------------------------------------------- X
C O U N S E L O R S:
PLEASE TAKE NOTICE, that the undersigned hereby makes the following demands
upon Nexus Enterprises, Inc. DBA Southampton Sunoco and Sunoco, Inc.:
1. Copies of any and all maintenance and/or repair records pertaining to the hose and pump
gun at pump 7 for two (2) years prior to up to and including the date of accident.
PLEASE TAKE FURTHER NOTICE, that the above discovery and inspection shall take
place at the offices of the undersigned at 9:30 o'clock in the forenoon of January 24, 2022. In lieu
of appearing at the offices of the undersigned, the requested information can be furnished, by mail,
prior to the return date hereof.
PLEASE TAKE FURTHER NOTICE, that if defendant(s) has no information with
respect to a particular demand, a statement to that effect, in writing, is required.
PLEASE TAKE FURTHER NOTICE, that this demand is continuing and in the event
defendant(s) attempts to introduce, at the time of trial, any information requested herein without
having heretofore provided same to plaintiff(s)'s counsel, plaintiff(s) will object to the use thereof
on the grounds of surprise.
Dated: Ronkonkoma, New York
December 20, 2021
Yours, etc.
.
ÈNN AUI ET†A, ESQ.
Gruenberg Kelly Della
1 of 2
FILED: SUFFOLK COUNTY CLERK 12/20/2021 02:52 PM INDEX NO. 606267/2021
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 12/20/2021
700 Koehler Avenue
Ronkonkoma, New York 11779
631-737-4110
Our File No.: 210122
TO: John Materazo
Lewis, Johs, Avallone Aviles LLP
Attorney for Defendant(s)
Nexus Enterprises, Inc. DBA Southampton Sunoco
Sunoco, Inc.
1377 Motor Parkway
Suite 400
Islandia, NY 11749
(631) 755-0101
2 of 2
Document Filed Date
December 20, 2021
Case Filing Date
April 08, 2021
Category
Torts - Other Negligence (Trip & Fall)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: SUFFOLK COUNTY CLERK 12/20/2021 02:52 PM INDEX NO. 606267/2021 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 12/20/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ---------------------------------- --------------------------X Index No.: 606267/2021 MARY LOUISE BALSAMO and ROBERT GEST, Plaintiff(s), -against- NOTICE FOR DISCOVERY NEXUS ENTERPRISES, INC. DBA SOUTHAMPTON AND INSPECTION SUNOCO and SUNOCO, INC., Defendant(s). -------------------------------------------------------- X C O U N S E L O R S: PLEASE TAKE NOTICE, that the undersigned hereby makes the following demands upon Nexus Enterprises, Inc. DBA Southampton Sunoco and Sunoco, Inc.: 1. Copies of any and all maintenance and/or repair records pertaining to the hose and pump gun at pump 7 for two (2) years prior to up to and including the date of accident. PLEASE TAKE FURTHER NOTICE, that the above discovery and inspection shall take place at the offices of the undersigned at 9:30 o'clock in the forenoon of January 24, 2022. In lieu of appearing at the offices of the undersigned, the requested information can be furnished, by mail, prior to the return date hereof. PLEASE TAKE FURTHER NOTICE, that if defendant(s) has no information with respect to a particular demand, a statement to that effect, in writing, is required. PLEASE TAKE FURTHER NOTICE, that this demand is continuing and in the event defendant(s) attempts to introduce, at the time of trial, any information requested herein without having heretofore provided same to plaintiff(s)'s counsel, plaintiff(s) will object to the use thereof on the grounds of surprise. Dated: Ronkonkoma, New York December 20, 2021 Yours, etc. . ÈNN AUI ET†A, ESQ. Gruenberg Kelly Della 1 of 2 FILED: SUFFOLK COUNTY CLERK 12/20/2021 02:52 PM INDEX NO. 606267/2021 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 12/20/2021 700 Koehler Avenue Ronkonkoma, New York 11779 631-737-4110 Our File No.: 210122 TO: John Materazo Lewis, Johs, Avallone Aviles LLP Attorney for Defendant(s) Nexus Enterprises, Inc. DBA Southampton Sunoco Sunoco, Inc. 1377 Motor Parkway Suite 400 Islandia, NY 11749 (631) 755-0101 2 of 2