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  • Luis Alberto Herrera v. The City Of New York, Belmont Re, Llc, Sutter Avenue Realty Co. Llc, Trinchese Iron Works & Construction IncTorts - Other Negligence (Personal Injury) document preview
  • Luis Alberto Herrera v. The City Of New York, Belmont Re, Llc, Sutter Avenue Realty Co. Llc, Trinchese Iron Works & Construction IncTorts - Other Negligence (Personal Injury) document preview
						
                                

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FILED: KINGS COUNTY CLERK 01/21/2021 02:24 PM INDEX NO. 512147/2020 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 01/21/2021 111 JOHN STREET, SUITE 1500, NEW YORK, NEW YORK 10038 PARTNERS PHONE: 212.945.1010 OF COUNSEL JON E. NEWMAN ADAM NEWMAN FAX: 212.627.2700 JASON D. WARSHAW ERIC STEHN IRWIN D. MILLER INFO@NEWMANLAWNY.COM WWW.NEWMANLAWNY.COM PARALEGALS ASSOCIATE ATTORNEYS DIANA J. LOPEZ FABIO GOMEZ ANN M. BUSSE GREGORY P. BAKOS SHEENA KAPOOR TYLER GEORGE January 19, 2021 SUBIN ASSOCIATES LLP 150 Broadway, 23rd Floor New York, New York 10038 Re: Matter: Herrera v. The City of New York, et al. Index #: 512147/2020 D.O.L. August 6, 2019 Our File #: 3378.003 Counsellors, As you are aware, my office represents Belmont Re, LLC and Trinchese Iron Works & Construction, Inc. in the above matter. On or about September 30, 2020, we e-filed our Combined Discovery Demands, which included a Demand for a Verified Bill of Particulars. However, to date, we have not received a response from your office. Please allow this letter to serve as our good-faith attempt to obtain responses to our Combined Demands. Please provide a Bill of Particulars and a response to our Combined Discovery Demands within 20 days of this letter to avoid motion practice. We look forward to a response. Should you have any questions, please let me know. I can be reached directly at (646) 872-9624. Very truly yours, NEWMAN LAW ASSOCIATES PLLC By: ____________________________ Jason D. Warshaw, Esq. 1 of 1