On October 31, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Judith Zarug,
and
Ambcosino Construction Corp,
The City Of New York,
for Torts - Other Negligence (Premises)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 10/26/2020 04:52 PM INDEX NO. 521110/2017
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/27/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------- --------X
JUDITH ZARUG,
Plaintiff,
-against-
NOTICE OF MOTION
Index No.: 521110/2017
THE CITY OF NEW YORK AND AMBROSINO
CONSTRUCTION CORP.,
Defendants.
.
-----X
PLEASE TAKE NOTICE, that upon the annexed affirmation of Steven L. Sonkin, Esq.,
23rd
duly affirmed the day of October, 2020, together with the exhibits annexed thereto, and upon all
of the pleadings and prior proceedings had herein, the undersigned will move this Court, at the
courthouse thereof, located at 360 Adams Street, Brooklyn, New York on November 30, 2020 at
9:30AM in the forenoon of that day, or as soon thereafter as counsel can be heard, for (1) compelling
Defendants THE CITY OF NEW YORK and AMBROSINO CONSTRUCTION CORP. to appear
for their examinations before trial; (2) for an order to extend Plaintiff's time to File Note of Issue;
(3) for such other and different relief as this Court deems just and proper.
PLEASE TAKE FURTHER NOTICE, that answering papers, if any, are to be served upon
the undersigned not less than seven (7) days prior to the return date herein.
Dated: Fresh Meadows, New York
October 23, 2020
Your .
EVEÑ (28 IN, ESQ.
DANIELLA LEVI & ASSOCIATES, PC
Attorneys for Plaintiff
JUDITH ZARUG
159-16 Union Turnpike - Suite 200
Fresh Meadows, New York 11366
(718) 380-1010
1 of 3
FILED: KINGS COUNTY CLERK 10/26/2020 04:52 PM INDEX NO. 521110/2017
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/27/2020
TO: JAMES E. JOHNSON, ESQ.
10"'
1 Pierrepont Plaza, Floor
Brooklyn, NY 11201
718-780-2500
GALLO VITUCCI KLAR LLP
Attorneys for Defendant
AMBROSINO CONSTRUCTION CORP.
12""
90 Broad Street, Floor
New York, NY 10004
212-683-7100
2 of 3
FILED: KINGS COUNTY CLERK 10/26/2020 04:52 PM INDEX NO. 521110/2017
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/27/2020
Index No.: 521110/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
JUDITH ZARUG,
Plaintiff,
-against-
THE CITY OF NEW YORK and AMBROSINO CONSTRUCTION CORP.,
Defendants,
NOTICE OF MOTION
DANIELLA LEVI & ASSOCIATES, P.C.
Attorneys for Plaint f(s)
159-16 Union Turnpike, Suite 200
Fresh Meadows, New York 11366
(718) 380-1010
Pursuant to 2/NYCRRDO-LL the undersignedanattorne g admined to precite in the CourtsofNew York State,
certifies flaat, upon infannanon andbelief andreuenna¼in ¾, the rnn‰nun-containedin theannexed
document are not frivolous.
Dated / ) Åg
-'
 S;á»etae
Print Sighers Name: tevehiL&onkin Escr.
3 of 3
Document Filed Date
October 26, 2020
Case Filing Date
October 31, 2017
Category
Torts - Other Negligence (Premises)
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Preview
FILED: KINGS COUNTY CLERK 10/26/2020 04:52 PM INDEX NO. 521110/2017 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/27/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------- --------X JUDITH ZARUG, Plaintiff, -against- NOTICE OF MOTION Index No.: 521110/2017 THE CITY OF NEW YORK AND AMBROSINO CONSTRUCTION CORP., Defendants. . -----X PLEASE TAKE NOTICE, that upon the annexed affirmation of Steven L. Sonkin, Esq., 23rd duly affirmed the day of October, 2020, together with the exhibits annexed thereto, and upon all of the pleadings and prior proceedings had herein, the undersigned will move this Court, at the courthouse thereof, located at 360 Adams Street, Brooklyn, New York on November 30, 2020 at 9:30AM in the forenoon of that day, or as soon thereafter as counsel can be heard, for (1) compelling Defendants THE CITY OF NEW YORK and AMBROSINO CONSTRUCTION CORP. to appear for their examinations before trial; (2) for an order to extend Plaintiff's time to File Note of Issue; (3) for such other and different relief as this Court deems just and proper. PLEASE TAKE FURTHER NOTICE, that answering papers, if any, are to be served upon the undersigned not less than seven (7) days prior to the return date herein. Dated: Fresh Meadows, New York October 23, 2020 Your . EVEÑ (28 IN, ESQ. DANIELLA LEVI & ASSOCIATES, PC Attorneys for Plaintiff JUDITH ZARUG 159-16 Union Turnpike - Suite 200 Fresh Meadows, New York 11366 (718) 380-1010 1 of 3 FILED: KINGS COUNTY CLERK 10/26/2020 04:52 PM INDEX NO. 521110/2017 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/27/2020 TO: JAMES E. JOHNSON, ESQ. 10"' 1 Pierrepont Plaza, Floor Brooklyn, NY 11201 718-780-2500 GALLO VITUCCI KLAR LLP Attorneys for Defendant AMBROSINO CONSTRUCTION CORP. 12"" 90 Broad Street, Floor New York, NY 10004 212-683-7100 2 of 3 FILED: KINGS COUNTY CLERK 10/26/2020 04:52 PM INDEX NO. 521110/2017 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/27/2020 Index No.: 521110/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS JUDITH ZARUG, Plaintiff, -against- THE CITY OF NEW YORK and AMBROSINO CONSTRUCTION CORP., Defendants, NOTICE OF MOTION DANIELLA LEVI & ASSOCIATES, P.C. Attorneys for Plaint f(s) 159-16 Union Turnpike, Suite 200 Fresh Meadows, New York 11366 (718) 380-1010 Pursuant to 2/NYCRRDO-LL the undersignedanattorne g admined to precite in the CourtsofNew York State, certifies flaat, upon infannanon andbelief andreuenna¼in ¾, the rnn‰nun-containedin theannexed document are not frivolous. Dated / ) Åg -'  S;á»etae Print Sighers Name: tevehiL&onkin Escr. 3 of 3