Party Discovery: Pamela Goldstein, Ellyn Berk, Tony Berk, Paul Benjamin v. Houlihan/Lawrence Inc.

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                                FILED:         WESTCHESTER              COUNTY         CLERK       09/08/2020             04:01        PM            INDEX    NO.   60767/2018
   NYSCEF     DOC.   NO.   619                                                                                RECEIVED      NYSCEF:     09/08/2020




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF WESTCHESTER

                   PAMELA GOLDSTEIN,                                           )
                   ELLYN & TONY BERK as Administrators of                      )
                   the   Estate    of  Winifred      Berk,   and    PAUL       )
                   BENJAMIN,        on  behalf   of  themselves    and   all   )     NOTICE OF DEPOSITION
                   others similarly situated,                                  )     TONI CHRYSTAL
                                                                               )
                                     Plaintiffs,                               )
                                                                               )     Index No. 60767/2018
                            vs.                                                )     Hon. Linda S. Jamieson
                                                                               )
                   HOULIHAN/LAWRENCE INC.,                                     )
                                                                               )
                                     Defendant.                                )
                                                                               )

                           PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and

                  Rules the testimony upon oral examination of Toni Chrystal of Houlihan Lawrence, 237

                  Mamaroneck Ave, White Plains, NY 10605, 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, remotely, on September 28, 2020, at 1:00 pm

                  Eastern Standard Time.

                           PLEASE TAKE FURTHER NOTICE, that the deposition will be conducted utilizing a

                  secure web-based video teleconferencing service via Zoom or WebEx, with a link to be

                  distributed to counsel in advance. Also take notice that, the deposition will be transcribed by

                  stenographic means and that the court reporter may participate in the deposition remotely via

                  web-based video teleconferencing for purposes of reporting the proceeding and may or may not

                  be in the presence of the deponent. The deposition will be video recorded by Matthew T. Ciulla

                  of MacGill PC, 55 Monument Circle, Suite 1200C, Indianapolis, Indiana, 46204. The deposition




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   FILED:         WESTCHESTER              COUNTY         CLERK       09/08/2020             04:01        PM            INDEX    NO.   60767/2018
   NYSCEF     DOC.   NO.   619                                                                                RECEIVED      NYSCEF:     09/08/2020




                  will continue from day to day as required until completed. Said individual is to be examined on

                  all evidence and material necessary in the prosecution and defense of the above-captioned action.


                           Dated: White Plains, New York
                                    September 8, 2020
                                                                        BY: DELBELLO DONNELLAN WEINGARTEN
                                                                        WISE & WIEDERKEHR LLP

                                                                                 /s/ Nelida      Lara
                                                                              Alfred E. Donnellan, Esq.
                                                                              Nelida Lara, Esq.
                                                                                                                     th
                                                                              One North Lexington Avenue, 11          Floor
                                                                              White Plains, New York 10601
                                                                              Phone: (914) 681-0200
                                                                              Attorneys for Defendant


                  TO:
                  Jeremy Vest
                  Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
                  Chrysler Center
                  666 Third Avenue
                  New York, NY 10017
                  Attorneys for Plaintiffs




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