Party Discovery: Jose Bermudez v. The New York City Housing Authority

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                                FILED:         NEW     YORK       COUNTY        CLERK        10/06/2022             02:59        PM                INDEX    NO.   157958/2022
   NYSCEF     DOC.   NO.   5                                                                                 RECEIVED      NYSCEF:     10/06/2022




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF NEW YORK                                                                                 ECF
                                                                                    -X
                                                                                                   Index No. 157958/22
                  JOSE BERMUDEZ,
                                                      Plaintiff,                                   NOTICE OF
                                                                                                   EXAMINATION
                                                                                                   BEFORE TRIAL
                                    - against -


                  NEW YORK CITY HOUSING AUTHORITY,
                                                      Defendants.
                                                                                    -X
                           PLEASE TAKE NOTICE that, pursuant to sections 3101                     and 3107 of the Civil Practice
                  Law    and  Rules, the    defendants     will cause   to  be  taken   testimony    of the   plaintiff,  his agents,
                  servants or employees of said         parties having knowledge of the subject matter concerning all of
                  the relevant facts and     circumstances in comiection         with the issues alleged in plaintiffs verified
                  complaint,     including    negligence,    contributory     negligence,    liability   and   damages,     and   said
                  persons to be examined        are  required   to produce    all books, records and papers in their custody
                  and possession that may be relevant to the issues herein.
                           PLEASE TAKE FURTHER NOTICE that such examination and deposition will be taken
                  at Lewis Jobs Avallone Aviles, LLP , 61           Broadway, Suite 2000, New York, New York 10006 on
                  the 7th day of December 2022 at 10:00 o'clock in the forenoon of that day, OR VIA ZOOM,or
                  at such time and place to which the parties or their attorneys may stipulate.
                  Dated:   October 4, 2022
                            New York, NY                                LEWIS JOHS AVALLONE AVILES,LLP
                                                                        Attorneys for Defendant
                                                                        NEW YORK CITY HOUSING AUTHORITY
                                                                       61 Broadway,^ite 2000
                                                                        New York, hiw "^rk 10006
                                                                        LJAA File^.>47-I880-NY00

                                                                                 John E. Koran
                  TO:
                  Daniella Levi & Associates, PC
                  Attorneys for Plaintiff
                  159-16 Union Tnpk., Suite 200
                  Fresh Meadows, NY 11366
                  718.380.1010




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