Preview
FILED: KINGS COUNTY CLERK 04/05/2022 01:26 PM INDEX NO. 512147/2020
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 04/05/2022
File No.: 31464
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------------------------------------------------------------------X
LUIS ALBERTO HERRERA,
DEMAND FOR VIDEOS
Plaintiff(s),
Index No.: 512147/2020
-against-
Law Dept. No.: 2020-025169
THE CITY OF NEW YORK, BELMONT RE, LLC AND
SUTTER AVENUE REALTY CO. LLC,
Defendant(s).
----------------------------------------------------------------------X
SUTTER AVENUE REALTY CO. LLC,
Third-Party Plaintiff(s),
-against-
TRINCHESE IRON WORKS & CONSTRUCTION INC.,
Third-Party Defendant(s).
--------------------------------------------------------------------X
S I R S:
PLEASE TAKE NOTICE that Plaintiff, by his attorneys, SUBIN ASSOCIATES, LLP,
hereby makes the following demands upon the Defendant(s)/Third-Party Defendant(s) to be
replied to within twenty (20) days:
1. Demand for video surveillance records/tapes depicting the sidewalk abutting the
premises known as 218-240 Belmont Avenue as well as Belmont Avenue side of 333A Van
Sinderen Avenue, in the County of Kings, City and State of New York, for the period of six (6)
hours before and six (6) hours after the incident on August 6, 2019, at approximately 7:30 P.M.
2. If no such record exists, an affidavit to that effect.
1 of 3
FILED: KINGS COUNTY CLERK 04/05/2022 01:26 PM INDEX NO. 512147/2020
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 04/05/2022
PLEASE TAKE FURTHER NOTICE that the foregoing is a continuing demand and
that if any of the above items are obtained after the date of this demand, they are to be furnished
to the undersigned pursuant to these demands.
PLEASE TAKE FURTHER NOTICE that in the event of your failure to comply, a
motion will be made for an Order to Strike your Answer, with costs.
Dated: New York, New York
April 5, 2022
Yours, etc.
Lee M. Huttner
LEE M. HUTTNER, ESQ.
SUBIN ASSOCIATES, LLP
Attorneys for Plaintiff(s)
LUIS ALBERTO HERRERA
150 Broadway, 23rd Floor
New York, New York 10038
(212) 285-3800
TO: SYLVIA HINDS-RADIX
CORPORATION COUNSEL
Attorney for Defendant(s)
THE CITY OF NEW YORK
350 Jay Street, 8th Floor
Brooklyn, New York 11201
(718) 724-5200
NEWMAN LAW ASSOCIATES, PLLC
Attorneys for Defendant(s)/Third-Party Defendant(s)
BELMONT RE, LLC and
TRINCHESE IRON WORKS & CONSTRUCTION INC.
111 John Street, Suite 1500
New York, New York 10038
(212) 945-1010
EUSTACE, PREZIOSO & YAPCHANYK
Attorneys for Defendant(s)/Third-Party Plaintiff(s)
SUTTER AVENUE REALTY CO. LLC
55 Water Street, 28th Floor
New York, New York 10041
(212) 612-4200
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FILED: KINGS COUNTY CLERK 04/05/2022 01:26 PM INDEX NO. 512147/2020
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 04/05/2022
Index No.: 512147/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KING
LUIS ALBERTO HERRERA,
Plaintiff(s),
-against-
THE CITY OF NEW YORK, BELMONT RE, LLC AND SUTTER AVENUE REALTY CO. LLC,
Defendant(s).
---------------------------------------------------------------------------------------------------------------------
SUTTER AVENUE REALTY CO. LLC,
Third-Party Plaintiff(s),
-against-
TRINCHESE IRON WORKS & CONSTRUCTION INC.,
Third-Party Defendant(s).
DEMAND FOR VIDEOS
SUBIN ASSOCIATES, LLP
Attorneys for Plaintiff(s)
Office and Post Office Address, Telephone
150 Broadway, 23rd Floor
New York, New York 10038
Telephone: (212) 285-3800
“WE DO NOT ACCEPT SERVICE BY ELECTRONIC TRANSMISSION (FAX)”
Service of a copy of the within is hereby admitted
Dated:
........................................................
Attorney(s) for
PLEASE TAKE NOTICE
┌─┐
└─┘ That the within is a (certified) true copy of an ORDER entered in the office
NOTICE OF of the clerk of the within named court on , 2022.
ENTRY
┌─┐
└─┘ That an Order of which the within is a true copy will be presented for
NOTICE OF settle to the Hon.one of the judges of the within
SETTLEMENT named court, at on , 2022, at 10:00 a.m.
Dated:
3 of 3
Preview
FILED: KINGS COUNTY CLERK 04/05/2022 01:26 PM INDEX NO. 512147/2020 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 04/05/2022 File No.: 31464 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------X LUIS ALBERTO HERRERA, DEMAND FOR VIDEOS Plaintiff(s), Index No.: 512147/2020 -against- Law Dept. No.: 2020-025169 THE CITY OF NEW YORK, BELMONT RE, LLC AND SUTTER AVENUE REALTY CO. LLC, Defendant(s). ----------------------------------------------------------------------X SUTTER AVENUE REALTY CO. LLC, Third-Party Plaintiff(s), -against- TRINCHESE IRON WORKS & CONSTRUCTION INC., Third-Party Defendant(s). --------------------------------------------------------------------X S I R S: PLEASE TAKE NOTICE that Plaintiff, by his attorneys, SUBIN ASSOCIATES, LLP, hereby makes the following demands upon the Defendant(s)/Third-Party Defendant(s) to be replied to within twenty (20) days: 1. Demand for video surveillance records/tapes depicting the sidewalk abutting the premises known as 218-240 Belmont Avenue as well as Belmont Avenue side of 333A Van Sinderen Avenue, in the County of Kings, City and State of New York, for the period of six (6) hours before and six (6) hours after the incident on August 6, 2019, at approximately 7:30 P.M. 2. If no such record exists, an affidavit to that effect. 1 of 3 FILED: KINGS COUNTY CLERK 04/05/2022 01:26 PM INDEX NO. 512147/2020 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 04/05/2022 PLEASE TAKE FURTHER NOTICE that the foregoing is a continuing demand and that if any of the above items are obtained after the date of this demand, they are to be furnished to the undersigned pursuant to these demands. PLEASE TAKE FURTHER NOTICE that in the event of your failure to comply, a motion will be made for an Order to Strike your Answer, with costs. Dated: New York, New York April 5, 2022 Yours, etc. Lee M. Huttner LEE M. HUTTNER, ESQ. SUBIN ASSOCIATES, LLP Attorneys for Plaintiff(s) LUIS ALBERTO HERRERA 150 Broadway, 23rd Floor New York, New York 10038 (212) 285-3800 TO: SYLVIA HINDS-RADIX CORPORATION COUNSEL Attorney for Defendant(s) THE CITY OF NEW YORK 350 Jay Street, 8th Floor Brooklyn, New York 11201 (718) 724-5200 NEWMAN LAW ASSOCIATES, PLLC Attorneys for Defendant(s)/Third-Party Defendant(s) BELMONT RE, LLC and TRINCHESE IRON WORKS & CONSTRUCTION INC. 111 John Street, Suite 1500 New York, New York 10038 (212) 945-1010 EUSTACE, PREZIOSO & YAPCHANYK Attorneys for Defendant(s)/Third-Party Plaintiff(s) SUTTER AVENUE REALTY CO. LLC 55 Water Street, 28th Floor New York, New York 10041 (212) 612-4200 2 of 3 FILED: KINGS COUNTY CLERK 04/05/2022 01:26 PM INDEX NO. 512147/2020 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 04/05/2022 Index No.: 512147/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KING LUIS ALBERTO HERRERA, Plaintiff(s), -against- THE CITY OF NEW YORK, BELMONT RE, LLC AND SUTTER AVENUE REALTY CO. LLC, Defendant(s). --------------------------------------------------------------------------------------------------------------------- SUTTER AVENUE REALTY CO. LLC, Third-Party Plaintiff(s), -against- TRINCHESE IRON WORKS & CONSTRUCTION INC., Third-Party Defendant(s). DEMAND FOR VIDEOS SUBIN ASSOCIATES, LLP Attorneys for Plaintiff(s) Office and Post Office Address, Telephone 150 Broadway, 23rd Floor New York, New York 10038 Telephone: (212) 285-3800 “WE DO NOT ACCEPT SERVICE BY ELECTRONIC TRANSMISSION (FAX)” Service of a copy of the within is hereby admitted Dated: ........................................................ Attorney(s) for PLEASE TAKE NOTICE ┌─┐ └─┘ That the within is a (certified) true copy of an ORDER entered in the office NOTICE OF of the clerk of the within named court on , 2022. ENTRY ┌─┐ └─┘ That an Order of which the within is a true copy will be presented for NOTICE OF settle to the Hon.one of the judges of the within SETTLEMENT named court, at on , 2022, at 10:00 a.m. Dated: 3 of 3