Party Discovery: Pearl Delta Funding, Llc v. Peak Title Agency Co. A/K/A PEAK TITLE CO, Tobby Jablonski, Juan Ruiz Jr

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                                FILED: NASSAU COUNTY CLERK 02/16/2023 12:08 PM                                                        INDEX NO. 600378/2023
NYSCEF DOC. NO. 21                                                                              RECEIVED NYSCEF: 02/16/2023




           SUPREME COURT OF THE STATE OF NEW YORK
           COUNTY OF NASSAU
           ------------------------------------------------------------------------X
           PEARL DELTA FUNDING, LLC,                                                   Index No. 600378/2023

                                                       Plaintiff,                      NOTICE OF DEPOSITION
                            -against-

          PEAK TITLE AGENCY CO. AKA PEAK TITLE CO
          and TOBBY JABLONSKI and JUAN RUIZ JR,

                                                        Defendants.
           ------------------------------------------------------------------------X
                   PLEASE TAKE NOTICE THAT, pursuant to Article 31 of the Civil Practice Law and

          Rules, the testimony upon oral examination of PEAK TITLE AGENCY CO. AKA PEAK TITLE

          CO will be taken before a notary public who is not an attorney, or employee or an attorney for any

          party or prospective party herein and is not a person who would be disqualified as a juror because

          of interest of, because of consanguinity, or affinity to any party herein, and to be recorded by

          stenographic means and videotape, at 100 Supreme Court Drive, Mineola, New York, 11501 in

          the Court's designated EBT Rooms on May 24, 2023, at 10:00 a.m. or such other time and place

          as may be mutually agreed on by counsel, with respect to evidence material and necessary to the

          prosecution and/or defense of this action. The oral examination will be continued thereafter from

          day to day until completed.

                  PLEASE TAKE FURTHER NOTICE that, pursuant to Rule 3111 of the Civil Practice

          Laws and Rules, PEAK TITLE AGENCY CO. AKA PEAK TITLE CO will be deposed with

          regard to the evidence and material necessary to the claims and defenses alleged in the pleadings

          in this action. The persons to be examined are required to produce at such examination all the

          books, records, documents, letters and memoranda in their possession, custody or control

          concerning any matter relevant to the facts and circumstances of this action.




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FILED: NASSAU COUNTY CLERK 02/16/2023 12:08 PM                         INDEX NO. 600378/2023
NYSCEF DOC. NO. 21                                              RECEIVED NYSCEF: 02/16/2023




          Dated: February 16, 2023
                                     Attorneys for Plaintiff
                                     Murray Legal, PLLC
                                     /s/ Christopher R. Murray
                                     Christopher R. Murray, Esq.
                                     170 Old Country Road, Suite 608
                                     Mineola, New York 11501
                                     Telephone: (516) 260-7367
                                     E-Mail: cmurray@murraylegalpllc.com

          To via NYSCEF:
          Counsel for Defendants




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