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 02/08/2022 04:21 PM INDEX NO. 606267/2021
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 02/08/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF. SUFFOLK
----------------------------------------------------X Index No.: 606267/2021
MARY LOUfSE BALSAMO and ROBERT GEST,
Plaintiff(s), NOTICE FOR DISCOVERY
AND INSPECTION
-against-
NEXUS ENTERPRISES, INC. DBA SOUTHAMPTON
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 Gas Station and Sunoco,
Inc.:
1. Please identify the Make, model and length of video retention for the surveillance system
at the gas station in effect at the time of the subject incident;
2. Please p ovide an copy of all video footage for the date of the subject incident. If the video
was not preserved, please provide an affidavit indicating the settings on the system for the
length of retention of the video before it is recorded over with new data from the video
camera(s).
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 March 8, 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.
1 of 2
FILED: SUFFOLK COUNTY CLERK 02/08/2022 04:21 PM INDEX NO. 606267/2021
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 02/08/2022
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
February 8, 2022
Yours, etc.
GLENN AULETTA, ESQ.
Gruenberg Kelly Della
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
February 08, 2022
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 02/08/2022 04:21 PM INDEX NO. 606267/2021 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 02/08/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF. SUFFOLK ----------------------------------------------------X Index No.: 606267/2021 MARY LOUfSE BALSAMO and ROBERT GEST, Plaintiff(s), NOTICE FOR DISCOVERY AND INSPECTION -against- NEXUS ENTERPRISES, INC. DBA SOUTHAMPTON 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 Gas Station and Sunoco, Inc.: 1. Please identify the Make, model and length of video retention for the surveillance system at the gas station in effect at the time of the subject incident; 2. Please p ovide an copy of all video footage for the date of the subject incident. If the video was not preserved, please provide an affidavit indicating the settings on the system for the length of retention of the video before it is recorded over with new data from the video camera(s). 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 March 8, 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. 1 of 2 FILED: SUFFOLK COUNTY CLERK 02/08/2022 04:21 PM INDEX NO. 606267/2021 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 02/08/2022 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 February 8, 2022 Yours, etc. GLENN AULETTA, ESQ. Gruenberg Kelly Della 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