Preview
FILED: KINGS COUNTY CLERK 12/22/2020 10:26 AM INDEX NO. 515277/2018
NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 12/22/2020
EXHIBIT I
FILED: KINGS COUNTY CLERK 12/22/2020 10:26 AM INDEX NO. 515277/2018
NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 12/22/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_________________------------------------------X
RESPONSE TO THE
ANTONIO ESPINOSA
THIRD SUPPLEMANTAL
DEMAND FOR
Plaintiff,
AUTHORIZATIONS
-against-
Index No.: 515277/2018
MAC 60 LLC AND ROYAL HOME IMPROVEMENTS,
INC. AND GILMAR DESIGN CORP.
Defendants.
------------------------------------------------------------X
MAC 60 LLC and ROYAL HOME IMPROVEMENTS,
INC.
Third-Party Plaintiffs,
-against-
GILMAR DESIGN CORPORATION,
Third-Party Defendant.
______________________________------------X
Plaintiff, ANTONIO ESPINOSA, by his attorneys, ORESKY & ASSOCIATES, PLLC, as
and for a Response to the Third Supplemental Demand for Authorizations dated December 9, 2020,
responds follows:
1. Plaintiff hereby objects to this demand as not materially relevant, overly broad, privileged,
and otherwise palpably improper.
PLEASE TAKE NOTICE, that this response is a continuing response, and counsel for the
plaintiff reserves the right to amend or supplement this response in accordance with the CPLR.
Dated: Bronx, New York
December 10, 2020
FILED: KINGS COUNTY CLERK 12/22/2020 10:26 AM INDEX NO. 515277/2018
NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 12/22/2020
Yours, etc.
Barry Semel-TVeinste n, Esq.
ORESKY & ASSOCIATES, PLLC
Attorneys for Plaintiff
Antonio Espinosa
149th
149 East Street
Bronx, NY 10451
(718)993-9999
Our File No.: 18-1005
TO: HAVKINS, ROSENFIELD, RITZERT, & VARRIALE, LLP
Attorney for Defendants
MAC 60 LLC AND ROYAL HOME IMPROVEMENTS, INC.
114 Old Country Road, Suite 300
Mineola, NY 11501
RAWLER & HENDERSON, LLP
Attorney for Defendants
GILMAR DESIGN CORP.
14 Wall Street, 27th Floor
New York, NY 10005
(212) 323-7070
2
FILED: KINGS COUNTY CLERK 12/22/2020 10:26 AM INDEX NO. 515277/2018
NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 12/22/2020
AFFIDAVIT OF SERVICE
STATE OF NEW YORK
SS:
COUNTY OF BRONX
Melissa Peralta, being duly sworn, deposes and says:
I am over 18 years of age, I am not a party to the action, and I reside in Queens County
in the State of New York.
I served a true copy of the annexed
RESPONSE THE THIRD SUPPLEMENTAL DEMAND FOR AUTHORIZATIONS
on December 10, 2020
by mailing the same in a sealed envelope, with postage prepaid thereon, in a post office
or official depository of the U.S. Postal Service within the State of New York, addressed to the
last known address of the addressee as indicated below:
Havkins Rosenfield Ritzert & Varriale, LLP
Attorney for Defendant(s)
Mac 60 LLC and Royal Home Improvements, Inc.
114 Old Country Road, Suite 300
Mineola, NY 11501
Rawler 4, Henderson, LLP
Attorney for Defendant(s)
Gilmar Design Corp.
14 Wall Street
27th Floor
New York, NY 10005
Me issa Pera ta
Sworn to before m ecernber 10, 2020
Notary Public
I."'
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C'.
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Qonu
Preview
FILED: KINGS COUNTY CLERK 12/22/2020 10:26 AM INDEX NO. 515277/2018 NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 12/22/2020 EXHIBIT I FILED: KINGS COUNTY CLERK 12/22/2020 10:26 AM INDEX NO. 515277/2018 NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 12/22/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS _________________------------------------------X RESPONSE TO THE ANTONIO ESPINOSA THIRD SUPPLEMANTAL DEMAND FOR Plaintiff, AUTHORIZATIONS -against- Index No.: 515277/2018 MAC 60 LLC AND ROYAL HOME IMPROVEMENTS, INC. AND GILMAR DESIGN CORP. Defendants. ------------------------------------------------------------X MAC 60 LLC and ROYAL HOME IMPROVEMENTS, INC. Third-Party Plaintiffs, -against- GILMAR DESIGN CORPORATION, Third-Party Defendant. ______________________________------------X Plaintiff, ANTONIO ESPINOSA, by his attorneys, ORESKY & ASSOCIATES, PLLC, as and for a Response to the Third Supplemental Demand for Authorizations dated December 9, 2020, responds follows: 1. Plaintiff hereby objects to this demand as not materially relevant, overly broad, privileged, and otherwise palpably improper. PLEASE TAKE NOTICE, that this response is a continuing response, and counsel for the plaintiff reserves the right to amend or supplement this response in accordance with the CPLR. Dated: Bronx, New York December 10, 2020 FILED: KINGS COUNTY CLERK 12/22/2020 10:26 AM INDEX NO. 515277/2018 NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 12/22/2020 Yours, etc. Barry Semel-TVeinste n, Esq. ORESKY & ASSOCIATES, PLLC Attorneys for Plaintiff Antonio Espinosa 149th 149 East Street Bronx, NY 10451 (718)993-9999 Our File No.: 18-1005 TO: HAVKINS, ROSENFIELD, RITZERT, & VARRIALE, LLP Attorney for Defendants MAC 60 LLC AND ROYAL HOME IMPROVEMENTS, INC. 114 Old Country Road, Suite 300 Mineola, NY 11501 RAWLER & HENDERSON, LLP Attorney for Defendants GILMAR DESIGN CORP. 14 Wall Street, 27th Floor New York, NY 10005 (212) 323-7070 2 FILED: KINGS COUNTY CLERK 12/22/2020 10:26 AM INDEX NO. 515277/2018 NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 12/22/2020 AFFIDAVIT OF SERVICE STATE OF NEW YORK SS: COUNTY OF BRONX Melissa Peralta, being duly sworn, deposes and says: I am over 18 years of age, I am not a party to the action, and I reside in Queens County in the State of New York. I served a true copy of the annexed RESPONSE THE THIRD SUPPLEMENTAL DEMAND FOR AUTHORIZATIONS on December 10, 2020 by mailing the same in a sealed envelope, with postage prepaid thereon, in a post office or official depository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressee as indicated below: Havkins Rosenfield Ritzert & Varriale, LLP Attorney for Defendant(s) Mac 60 LLC and Royal Home Improvements, Inc. 114 Old Country Road, Suite 300 Mineola, NY 11501 Rawler 4, Henderson, LLP Attorney for Defendant(s) Gilmar Design Corp. 14 Wall Street 27th Floor New York, NY 10005 Me issa Pera ta Sworn to before m ecernber 10, 2020 Notary Public I."' ' c C'. C ~- ',- - '„'oi/ao2 Qonu