Preview
FILED: KINGS COUNTY CLERK 07/05/2022 02:50 PM INDEX NO. 508119/2022
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 07/05/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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EMILY LONGFIELD, INDEX NO.: 508119/2022
Plaintiff,
- against -
DEMAND FOR CELLPHONE
BROOKLYN BRIDGE PARK CORPORATION, ST. RECORDS/AUTHORIZATION
ANN’S WAREHOUSE, INC., BROOKLYN BRIDGE & NOTICE TO PRESERVE
PARK DEVELOPMENT CORPORATION, and NEW
YORK STATE URBAN DEVELOPMENT
CORPORATION D/B/A EMPIRE STATE
DEVELOPMENT CORPORATION,
Defendants.
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COUNSELORS:
PLEASE TAKE NOTICE, that if plaintiff, EMILY LONGFIELD, possessed a cellular
phone, mobile phone, smartphone and/or other similar device which was on his/her person at the
time of the accident and was operational on the date of the accident, then pursuant to CPLR 3101,
et seq., plaintiff is to serve upon the undersigned, within thirty (30) days: (a) true, accurate and
complete copies of all cellular phone, mobile phone, smartphone and/or other similar device
records and photographs in plaintiff’s possession for the date of the alleged occurrence; and (b)
duly executed and acknowledged original authorizations permitting the undersigned to secure
complete copies of all such records and photographs for the date of the alleged occurrence.
PLEASE TAKE FURTHER NOTICE, that as applicable, authorizations shall be
addressed and directed as follows:
AT&T Wireless (includes Cingular, Cricket, GoPhone)
c/o CT Corporation System
One Corporate Center – Floor 11
Harford, Connecticut 06103-3220
CT ID: 0660752
1
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FILED: KINGS COUNTY CLERK 07/05/2022 02:50 PM INDEX NO. 508119/2022
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 07/05/2022
Cellco Partnership d/b/a Verizon Wireless
c/o CT Corporation System
One Corporate Center – Floor 11
Hartford, Connecticut 06013-3220
CT ID: 1038095
Metro PCS
c/o Corporation Service Company
50 Weston Street
Hartford, Connecticut 06120-1537
CT ID: 0928407
Sprint PCS Wireless (includes Virgin Mobile and Boost Mobile)
c/o The Prentice-Hall Corporation Service Company
50 Weston Street
Hartford, Connecticut 06120-1537
CT ID: 0530320
T-Mobile USA, Inc.
c/o Corporation Service Company
50 Weston Street
Hartford, Connecticut 06120-1537
CT ID: 0637780
TracFone Wireless, Inc. (includes Straight Talk Wireless, Net10, Total
Wireless, TelCel, and Safelink)
c/o Corporate Creations Network, Inc.
615 West Johnson Avenue, #202
Cheshire, Connecticut 06410
CT ID: 0915315
U.S. Cellular
One Pierce Place, Suite 800
Itasca, Illinois 60143
PLEASE TAKE FURTHER NOTICE, that the foregoing authorizations shall be issued and
executed in favor of the undersigned not more than thirty (30) days before receipt by the undersigned.
PLEASE TAKE FURTHER NOTICE, that in the event of failure or refusal to comply
with any of these demands, said answering defendant will apply to the Court for the appropriate
relief including, but not limited to, an Order compelling compliance pursuant to CPLR 3124 and/or
appropriate relief pursuant to CPLR §3126 and 22 NYCRR Part 130.
2
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FILED: KINGS COUNTY CLERK 07/05/2022 02:50 PM INDEX NO. 508119/2022
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 07/05/2022
Dated: Garden City, New York
July 5, 2022
Yours, etc.,
QUIRK AND BAKALOR, P.C.
By:_______________________________
TIMOTHY J. KEANE
Attorneys for Defendant
ST. ANN’S WAREHOUSE, INC.
1205 Franklin Avenue – Suite 110
Garden City, New York 11530
(212) 319-1000
tkeane@quirkbakalor.com
TO:
SILBOWITZ, GARAFOLA, SILBOWITZ
& SCHATZ, LLP
Attorneys for Plaintiff
55 Water Mill Lane, Suite 400
Great Neck, New York 11021
(212) 354-6800
File No.: 202200439
Sylvia O. Hinds-Radix
Corporation Counsel
Attorneys for Defendants
BROOKLYN BRIDGE PARK CORPORATION,
BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION
NEW YORK STATE URBAN DEVELOPMENT
CORPORATION, D/B/A EMPRIE STATE
DEVELOPMENT CORPORATION
100 Church Street
New York, New York 10007
3
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FILED: KINGS COUNTY CLERK 07/05/2022 02:50 PM INDEX NO. 508119/2022
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 07/05/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS INDEX NO.: 508119/2022
EMILY LONGFIELD,
CCECILIARE
D Plaintiff,
SAFSOJADFKJSD
- against –
BROOKLYN BRIDGE PARK CORPORATION, ST. ANN’S WAREHOUSE,INC., BROOKLYN
BRIDGE PARK DEVELOPMENT CORPORATION and NEW YORK STATE URBAN
DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION
Defendants.
DEMAND FOR CELLPHONE RECORDS/AUTHORIZATION & NOTICE TO PRESERVE
QUIRK AND BAKALOR, P.C.
Attorney(s) for: DEFENDANT
ST. ANN’S WAREHOUSE, INC.
Office and Post Office Address, Telephone
1205 Franklin Avenue – Suite 110
Garden City, New York 11530
(212) 319-1000
To Signature (Rule 130-1.1-a)
_______________________
Print name beneath
Service of a copy of the within is hereby admitted.
Dated: __________________________
Attorney(s) for
PLEASE TAKE NOTICE:
ï‚ NOTICE OF ENTRY
that the within is a (certified) true copy of a
duly entered in the office of the clerk of the within named court on
ï‚ NOTICE OF SETTLEMENT
that an order of which the within is a true copy
will be presented for settlement to the HON. one of the judges of the
within named Court, at
on at M.
Dated,
Yours, etc.
QUIRK AND BAKALOR, P.C.
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Preview
FILED: KINGS COUNTY CLERK 07/05/2022 02:50 PM INDEX NO. 508119/2022 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 07/05/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------X EMILY LONGFIELD, INDEX NO.: 508119/2022 Plaintiff, - against - DEMAND FOR CELLPHONE BROOKLYN BRIDGE PARK CORPORATION, ST. RECORDS/AUTHORIZATION ANN’S WAREHOUSE, INC., BROOKLYN BRIDGE & NOTICE TO PRESERVE PARK DEVELOPMENT CORPORATION, and NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION, Defendants. --------------------------------------------------------------------X COUNSELORS: PLEASE TAKE NOTICE, that if plaintiff, EMILY LONGFIELD, possessed a cellular phone, mobile phone, smartphone and/or other similar device which was on his/her person at the time of the accident and was operational on the date of the accident, then pursuant to CPLR 3101, et seq., plaintiff is to serve upon the undersigned, within thirty (30) days: (a) true, accurate and complete copies of all cellular phone, mobile phone, smartphone and/or other similar device records and photographs in plaintiff’s possession for the date of the alleged occurrence; and (b) duly executed and acknowledged original authorizations permitting the undersigned to secure complete copies of all such records and photographs for the date of the alleged occurrence. PLEASE TAKE FURTHER NOTICE, that as applicable, authorizations shall be addressed and directed as follows: AT&T Wireless (includes Cingular, Cricket, GoPhone) c/o CT Corporation System One Corporate Center – Floor 11 Harford, Connecticut 06103-3220 CT ID: 0660752 1 1 of 4 FILED: KINGS COUNTY CLERK 07/05/2022 02:50 PM INDEX NO. 508119/2022 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 07/05/2022 Cellco Partnership d/b/a Verizon Wireless c/o CT Corporation System One Corporate Center – Floor 11 Hartford, Connecticut 06013-3220 CT ID: 1038095 Metro PCS c/o Corporation Service Company 50 Weston Street Hartford, Connecticut 06120-1537 CT ID: 0928407 Sprint PCS Wireless (includes Virgin Mobile and Boost Mobile) c/o The Prentice-Hall Corporation Service Company 50 Weston Street Hartford, Connecticut 06120-1537 CT ID: 0530320 T-Mobile USA, Inc. c/o Corporation Service Company 50 Weston Street Hartford, Connecticut 06120-1537 CT ID: 0637780 TracFone Wireless, Inc. (includes Straight Talk Wireless, Net10, Total Wireless, TelCel, and Safelink) c/o Corporate Creations Network, Inc. 615 West Johnson Avenue, #202 Cheshire, Connecticut 06410 CT ID: 0915315 U.S. Cellular One Pierce Place, Suite 800 Itasca, Illinois 60143 PLEASE TAKE FURTHER NOTICE, that the foregoing authorizations shall be issued and executed in favor of the undersigned not more than thirty (30) days before receipt by the undersigned. PLEASE TAKE FURTHER NOTICE, that in the event of failure or refusal to comply with any of these demands, said answering defendant will apply to the Court for the appropriate relief including, but not limited to, an Order compelling compliance pursuant to CPLR 3124 and/or appropriate relief pursuant to CPLR §3126 and 22 NYCRR Part 130. 2 2 of 4 FILED: KINGS COUNTY CLERK 07/05/2022 02:50 PM INDEX NO. 508119/2022 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 07/05/2022 Dated: Garden City, New York July 5, 2022 Yours, etc., QUIRK AND BAKALOR, P.C. By:_______________________________ TIMOTHY J. KEANE Attorneys for Defendant ST. ANN’S WAREHOUSE, INC. 1205 Franklin Avenue – Suite 110 Garden City, New York 11530 (212) 319-1000 tkeane@quirkbakalor.com TO: SILBOWITZ, GARAFOLA, SILBOWITZ & SCHATZ, LLP Attorneys for Plaintiff 55 Water Mill Lane, Suite 400 Great Neck, New York 11021 (212) 354-6800 File No.: 202200439 Sylvia O. Hinds-Radix Corporation Counsel Attorneys for Defendants BROOKLYN BRIDGE PARK CORPORATION, BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION NEW YORK STATE URBAN DEVELOPMENT CORPORATION, D/B/A EMPRIE STATE DEVELOPMENT CORPORATION 100 Church Street New York, New York 10007 3 3 of 4 FILED: KINGS COUNTY CLERK 07/05/2022 02:50 PM INDEX NO. 508119/2022 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 07/05/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS INDEX NO.: 508119/2022 EMILY LONGFIELD, CCECILIARE D Plaintiff, SAFSOJADFKJSD - against – BROOKLYN BRIDGE PARK CORPORATION, ST. ANN’S WAREHOUSE,INC., BROOKLYN BRIDGE PARK DEVELOPMENT CORPORATION and NEW YORK STATE URBAN DEVELOPMENT CORPORATION D/B/A EMPIRE STATE DEVELOPMENT CORPORATION Defendants. DEMAND FOR CELLPHONE RECORDS/AUTHORIZATION & NOTICE TO PRESERVE QUIRK AND BAKALOR, P.C. Attorney(s) for: DEFENDANT ST. ANN’S WAREHOUSE, INC. Office and Post Office Address, Telephone 1205 Franklin Avenue – Suite 110 Garden City, New York 11530 (212) 319-1000 To Signature (Rule 130-1.1-a) _______________________ Print name beneath Service of a copy of the within is hereby admitted. Dated: __________________________ Attorney(s) for PLEASE TAKE NOTICE: ï‚ NOTICE OF ENTRY that the within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on ï‚ NOTICE OF SETTLEMENT that an order of which the within is a true copy will be presented for settlement to the HON. one of the judges of the within named Court, at on at M. Dated, Yours, etc. QUIRK AND BAKALOR, P.C. 4 of 4