On September 07, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Brian C. Prusik,
and
Geddes Federal Savings And Loan Association,
Liberty Mutual Insurance Group Inc.,
for Commercial Division
in the District Court of Onondaga County.
Preview
FILED: ONONDAGA COUNTY CLERK 11/29/2021 05:36 PM INDEX NO. 008588/2018
NYSCEF DOC. NO. 222 RECEIVED NYSCEF: 11/29/2021
EXHIBIT G
FILED: ONONDAGA COUNTY CLERK 11/29/2021 05:36 PM INDEX NO. 008588/2018
NYSCEF DOC. NO. 222 RECEIVED NYSCEF: 11/29/2021
STATE OF NEW YORK
SUPREME COURT COUNTY OF ONONDAGA
BRIAN C. PRUSIK PLAINTIFF’S
PLAINTIFF'S NOTICE TO
ADMIT TO DEFENDANT
Plaintiff, GEDDES FEDERAL
SAVINGS AND LOAN
vs.
VS. ASSOCIATION
LIBERTY MUTUAL INSURANCE GROUP INC.,
GEDDES FEDERAL SAVINGS AND LOAN Index No.: E008588/2018
E00858812018
ASSOCIATION,
Defendants.
PLEASE TAKE NOTICE that, Plaintiff Brian C. Prusik, by and through his attorneys,
Woods Oviatt Gilman LLP as and for a Notice to Admit, pursuant to CPLR § 3123, demands that
Defendant Geddes Federal Savings and Loan Association (“Geddes”)
("Geddes") admit or deny the following
statements within twenty days hereof:
REQUESTS FOR ADMISSION
1. Geddes instructed TJMG Properties LLC ("TJMG") to perform work at 121 Slosson
Road in West Monroe, NY (the "Premises") in June, 2017.
2. Geddes directed TJMG to clean the interior of the Premises in June 2017.
3. In June 2017, TJMG entered the Premises and removed personal property from the
Premises, placed it into two dumpsters, and ultimately disposed of the personal
property.
PLEASE TAKE NOTICE that pursuant to CPLR § 3123, each of the foregoing shall be
deemed admitted within twenty (20) days after services of this Notice, or within such further time
that the Court may allow, the undersigned receives a sworn statement either denying specifically the
matters of which admission is requested, or setting forth in detail the reasons why Geddes cannot
truthfully admit or deny those matters; and
{8549454: }}
FILED: ONONDAGA COUNTY CLERK 11/29/2021 05:36 PM INDEX NO. 008588/2018
NYSCEF DOC. NO. 222 RECEIVED NYSCEF: 11/29/2021
PLEASE TAKE FURTHER NOTICE, that if you do not admit the matters herein, and
Plaintiff has to prove the truth of the above facts and genuineness of such documents at trial of this
matter, you may be responsible to pay Plaintiff for the reasonable expenses incurred in proving such
facts and documents, including reasonable attorneys'
attorneys’ fees.
Plaintiff reserves the right to amend or supplement these responses if
Plaintiff if additional information
becomes known or available.
DATED: August 3, 2021
Rochester, New York WOODS OVIATT GILMAN LLP
By:
Andrew J. Ryan, Esq.
for Plaintiff
Attorneysfor Plaintiff
1900 Bausch & Lomb Place
Rochester, New York 14604
(585) 987-2800
aryan@woodsoviatt.com
TO: Daniel F. Mathews, III, Esq.
for Defendant
Attorneyfor
Geddes Federal Savings and Loan Assoc.
120 E. Washington Street
913-919 University Building
Syracuse, New York 13202
315.471.2188
DFMathewsIII@aol.com
cc: Cory J. Schoonmaker, Esq.
Sugarman Law Firm LLP
for Defendant
Attorneysfor
Liberty Mutual Insurance Group Inc.
211 West Jefferson Street
Syracuse, New York 13202
315.362.8941
cschoonmaker@sugarmanlaw.com
{8549454: }} 2
Document Filed Date
November 29, 2021
Case Filing Date
September 07, 2018
Category
Commercial Division
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FILED: ONONDAGA COUNTY CLERK 11/29/2021 05:36 PM INDEX NO. 008588/2018 NYSCEF DOC. NO. 222 RECEIVED NYSCEF: 11/29/2021 EXHIBIT G FILED: ONONDAGA COUNTY CLERK 11/29/2021 05:36 PM INDEX NO. 008588/2018 NYSCEF DOC. NO. 222 RECEIVED NYSCEF: 11/29/2021 STATE OF NEW YORK SUPREME COURT COUNTY OF ONONDAGA BRIAN C. PRUSIK PLAINTIFF’S PLAINTIFF'S NOTICE TO ADMIT TO DEFENDANT Plaintiff, GEDDES FEDERAL SAVINGS AND LOAN vs. VS. ASSOCIATION LIBERTY MUTUAL INSURANCE GROUP INC., GEDDES FEDERAL SAVINGS AND LOAN Index No.: E008588/2018 E00858812018 ASSOCIATION, Defendants. PLEASE TAKE NOTICE that, Plaintiff Brian C. Prusik, by and through his attorneys, Woods Oviatt Gilman LLP as and for a Notice to Admit, pursuant to CPLR § 3123, demands that Defendant Geddes Federal Savings and Loan Association (“Geddes”) ("Geddes") admit or deny the following statements within twenty days hereof: REQUESTS FOR ADMISSION 1. Geddes instructed TJMG Properties LLC ("TJMG") to perform work at 121 Slosson Road in West Monroe, NY (the "Premises") in June, 2017. 2. Geddes directed TJMG to clean the interior of the Premises in June 2017. 3. In June 2017, TJMG entered the Premises and removed personal property from the Premises, placed it into two dumpsters, and ultimately disposed of the personal property. PLEASE TAKE NOTICE that pursuant to CPLR § 3123, each of the foregoing shall be deemed admitted within twenty (20) days after services of this Notice, or within such further time that the Court may allow, the undersigned receives a sworn statement either denying specifically the matters of which admission is requested, or setting forth in detail the reasons why Geddes cannot truthfully admit or deny those matters; and {8549454: }} FILED: ONONDAGA COUNTY CLERK 11/29/2021 05:36 PM INDEX NO. 008588/2018 NYSCEF DOC. NO. 222 RECEIVED NYSCEF: 11/29/2021 PLEASE TAKE FURTHER NOTICE, that if you do not admit the matters herein, and Plaintiff has to prove the truth of the above facts and genuineness of such documents at trial of this matter, you may be responsible to pay Plaintiff for the reasonable expenses incurred in proving such facts and documents, including reasonable attorneys' attorneys’ fees. Plaintiff reserves the right to amend or supplement these responses if Plaintiff if additional information becomes known or available. DATED: August 3, 2021 Rochester, New York WOODS OVIATT GILMAN LLP By: Andrew J. Ryan, Esq. for Plaintiff Attorneysfor Plaintiff 1900 Bausch & Lomb Place Rochester, New York 14604 (585) 987-2800 aryan@woodsoviatt.com TO: Daniel F. Mathews, III, Esq. for Defendant Attorneyfor Geddes Federal Savings and Loan Assoc. 120 E. Washington Street 913-919 University Building Syracuse, New York 13202 315.471.2188 DFMathewsIII@aol.com cc: Cory J. Schoonmaker, Esq. Sugarman Law Firm LLP for Defendant Attorneysfor Liberty Mutual Insurance Group Inc. 211 West Jefferson Street Syracuse, New York 13202 315.362.8941 cschoonmaker@sugarmanlaw.com {8549454: }} 2