On March 21, 2022 a
Letter,Correspondence
was filed
involving a dispute between
Emily Longfield,
and
Brooklyn Bridge Park Corporation,
Brooklyn Bridge Park Development Corporation,
New York State Urban Development Corporation D B A Empire State Development Corporation,
St. Ann'S Warehouse, Inc.,
for Torts - Other Negligence (premises)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 02/13/2023 02:05 PM INDEX NO. 508119/2022
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 02/13/2023
QUIRK AND BAKALOR, P.C.
COUNSELORS AT LAW
1205 FRANKLIN AVENUE
GARDEN CITY, N.Y. 11530
(212) 319-1000
FAX (212) 319-1065
Loretta A. Redmond, Shareholder
lredmond@quirkbakalor.com
February 13, 2023
Silbowitz, Garafola, Silbowitz & Schatz, LLP
55 Water Mill Lane, Suite 400
Great Neck, New York 11021
RE: EMILY LONGFIELD v. BROOKLYN BRIDGE PARK CORPORATION et al
KINGS COUNTY INDEX NO.: 508119/2022
Dear Counsel:
Please accept this letter as our third good faith effort concerning overdue discovery responses.
Copies of my previous good faith correspondence can be found on the NYSCEF Docket Doc. Nos.:
23 and 24. Copies of our discovery demands can be found on the NYSCEF Docket Doc. Nos.: 11-
20. To date, we have yet to receive a response to long outstanding discovery demands. Kindly
provide your responses within ten days so as to avoid further intervention from the court. Thank you
for your anticipated cooperation.
In particular, please forward HIPAA compliant authorizations allowing this office to obtain
plaintiff’s medical records immediately as the Court is requiring that depositions be scheduled to be
held within 60 days of the Preliminary Conference date scheduled on March 6, 2023. We will need
time to process and receive plaintiff’s records prior to her deposition.
Should you have any questions or concerns, please do not hesitate to contact me.
Very truly yours,
Loretta A. Redmond
LAR:ka
Cc: Sylvia O. Hinds-Radix, Corporation Counsel
(via ECF)
1 of 1
Document Filed Date
February 13, 2023
Case Filing Date
March 21, 2022
Category
Torts - Other Negligence (premises)
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FILED: KINGS COUNTY CLERK 02/13/2023 02:05 PM INDEX NO. 508119/2022 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 02/13/2023 QUIRK AND BAKALOR, P.C. COUNSELORS AT LAW 1205 FRANKLIN AVENUE GARDEN CITY, N.Y. 11530 (212) 319-1000 FAX (212) 319-1065 Loretta A. Redmond, Shareholder lredmond@quirkbakalor.com February 13, 2023 Silbowitz, Garafola, Silbowitz & Schatz, LLP 55 Water Mill Lane, Suite 400 Great Neck, New York 11021 RE: EMILY LONGFIELD v. BROOKLYN BRIDGE PARK CORPORATION et al KINGS COUNTY INDEX NO.: 508119/2022 Dear Counsel: Please accept this letter as our third good faith effort concerning overdue discovery responses. Copies of my previous good faith correspondence can be found on the NYSCEF Docket Doc. Nos.: 23 and 24. Copies of our discovery demands can be found on the NYSCEF Docket Doc. Nos.: 11- 20. To date, we have yet to receive a response to long outstanding discovery demands. Kindly provide your responses within ten days so as to avoid further intervention from the court. Thank you for your anticipated cooperation. In particular, please forward HIPAA compliant authorizations allowing this office to obtain plaintiff’s medical records immediately as the Court is requiring that depositions be scheduled to be held within 60 days of the Preliminary Conference date scheduled on March 6, 2023. We will need time to process and receive plaintiff’s records prior to her deposition. Should you have any questions or concerns, please do not hesitate to contact me. Very truly yours, Loretta A. Redmond LAR:ka Cc: Sylvia O. Hinds-Radix, Corporation Counsel (via ECF) 1 of 1