On March 09, 2018 a
No Value
was filed
involving a dispute between
Julio Irala-Martinez,
and
Cook & Krupa, Llc,
Krill Contracting Inc.,
Sera Holding Corp.,
Shuman 673 16 Llc,
for Torts - Other (Labor Law)
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 11/30/2021 03:51 PM INDEX NO. 703644/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 11/30/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
-------------------------------------------------------------------------X
JULIO IRALA-MARTINEZ, Index # 703644/2018
Plaintiff,
-against-
SHUMAN 673/16 LLC and COOK & KRUPA, LLC, POST DEPOSITION
DEMANDS
Defendants.
-------------------------------------------------------------------------X
SHUMAN 673/16 LLC AND COOK & KRUPA, LLC
Third Party Plaintiffs,
-against-
CCI CONTRACTING, INC.,
Third Party Defendant.
--------------------------------------------------------------------X
PLEASE TAKE NOTICE that, pursuant to Rules 3101 and 3120 of New York Civil
Practice Law and Rules, Defendants SHUMAN 673/16 LLC and COOK & KRUPA, LLC, by their
attorneys AHMUTY, DEMERS & MCMANUS, ESQS., demands that CCI CONTRACTING
produce and permit the undersigned to inspect and copy within thirty (30) days of the date hereof,
the following documents:
1. Copy of the entire project file for the work performed at 34-01 Steinway.
2. Copy of any accident reports.
3. Copy of the employee files or documentation as to employment of Samuel (“Sammy”),
Luis and Manuel.
4. The last known contact information including, but not limited to, phone number, address
and e-mail for Samuel (“Sammy”).
5. The last known contact information including, but not limited to, phone number, address
and e-mail for Luis.
1 of 2
FILED: QUEENS COUNTY CLERK 11/30/2021 03:51 PM INDEX NO. 703644/2018
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 11/30/2021
6. The last known contact information including, but not limited to, phone number, address
and e-mail for Manuel.
PLEASE TAKE FURTHER NOTICE, that the foregoing demands are continuing
demands. In the event that any of the above items are obtained after service of this demand, or
service of a response hereto, they are to be furnished to the undersigned forthwith.
Dated: New York, New York
November 30, 2021
BY: Christopher J. Matcovich
CHRISTOPHER J. MATCOVICH
AHMUTY, DEMERS & MCMANUS, ESQS.
Attorneys for the Defendants/
Third Party Plaintiffs
SHUMAN 673/16 LLC and
COOK & KRUPA, LLC
s/h/a COOK & KRUPA, LLC.
199 Water Street, 16th Floor
New York, NY 10038
Our File No.: NCSP053618SDZ
To:
WILLIAM SCHWITZER & ASSOCIATES, PC
Attorneys for PLAINTIFF
820 Second Avenue, 10th Floor
299 Broadway, Suite 910
New York, New York 10017
(212) 683-3800
File# Sep18-028
O’CONNOR REDD ORLANDO, LLP
Attorneys for Third-Party Defendant
CCI CONTRACTING, INC.
242 King Street
Port Chester, New York 10573
2
2 of 2
Document Filed Date
November 30, 2021
Case Filing Date
March 09, 2018
Category
Torts - Other (Labor Law)
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FILED: QUEENS COUNTY CLERK 11/30/2021 03:51 PM INDEX NO. 703644/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 11/30/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS -------------------------------------------------------------------------X JULIO IRALA-MARTINEZ, Index # 703644/2018 Plaintiff, -against- SHUMAN 673/16 LLC and COOK & KRUPA, LLC, POST DEPOSITION DEMANDS Defendants. -------------------------------------------------------------------------X SHUMAN 673/16 LLC AND COOK & KRUPA, LLC Third Party Plaintiffs, -against- CCI CONTRACTING, INC., Third Party Defendant. --------------------------------------------------------------------X PLEASE TAKE NOTICE that, pursuant to Rules 3101 and 3120 of New York Civil Practice Law and Rules, Defendants SHUMAN 673/16 LLC and COOK & KRUPA, LLC, by their attorneys AHMUTY, DEMERS & MCMANUS, ESQS., demands that CCI CONTRACTING produce and permit the undersigned to inspect and copy within thirty (30) days of the date hereof, the following documents: 1. Copy of the entire project file for the work performed at 34-01 Steinway. 2. Copy of any accident reports. 3. Copy of the employee files or documentation as to employment of Samuel (“Sammy”), Luis and Manuel. 4. The last known contact information including, but not limited to, phone number, address and e-mail for Samuel (“Sammy”). 5. The last known contact information including, but not limited to, phone number, address and e-mail for Luis. 1 of 2 FILED: QUEENS COUNTY CLERK 11/30/2021 03:51 PM INDEX NO. 703644/2018 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 11/30/2021 6. The last known contact information including, but not limited to, phone number, address and e-mail for Manuel. PLEASE TAKE FURTHER NOTICE, that the foregoing demands are continuing demands. In the event that any of the above items are obtained after service of this demand, or service of a response hereto, they are to be furnished to the undersigned forthwith. Dated: New York, New York November 30, 2021 BY: Christopher J. Matcovich CHRISTOPHER J. MATCOVICH AHMUTY, DEMERS & MCMANUS, ESQS. Attorneys for the Defendants/ Third Party Plaintiffs SHUMAN 673/16 LLC and COOK & KRUPA, LLC s/h/a COOK & KRUPA, LLC. 199 Water Street, 16th Floor New York, NY 10038 Our File No.: NCSP053618SDZ To: WILLIAM SCHWITZER & ASSOCIATES, PC Attorneys for PLAINTIFF 820 Second Avenue, 10th Floor 299 Broadway, Suite 910 New York, New York 10017 (212) 683-3800 File# Sep18-028 O’CONNOR REDD ORLANDO, LLP Attorneys for Third-Party Defendant CCI CONTRACTING, INC. 242 King Street Port Chester, New York 10573 2 2 of 2