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(FILED: NEW YORK COUNTY CLERK 03/16/2015 05:04 PM INDEX NO. 158327/2013
NYSCEF DOC. NO. 42 RECEIVED NYSCEF: 03/16/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
KEVIN McGONIGAL,
Plaintiff,
-against-
Index No.: 158327/13
NYY STEAK MANHATTAN, LLC, PREF 7 WEST 51
STREET LLC, PLAZA CONSTRUCTION CORP. and
BARING INDUSTRIES, INC,
Defendants
NOTICE TO TAKE
PLAZA CONSTRUCTION CORP., DEPOSITION UPON
ORAL EXAMINATION
Defendant/Third-Party Plaintiff
-against-
BARING INDUSTRIES, INC., Third-Party Index No.
§95146/14
Third-Party Defendant.
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law
and Rules, the testimony, upon oral examination of all adverse parties, will be taken
before a Notary Public who is not an attorney, or employee of an attorney, for any party
or prospective party herein and is not a person who would be disqualified to act as a juror
because of interest or because of consanguinity or affinity to any party herein, to be held
at the offices of FABIANI COHEN & HALL, LLP, 570 Lexington Avenue, New York,
New York, on the 1m day of August, 2015, at 10:00 o'clock in the forenoon of that day,
with respect to evidence material and necessary in the prosecution/defense of this action.
That said person to be examined is required to produce at such examination all
papers, documents, records, reports, written statements, correspondence, photographs,
diagrams, etc. relating to the within action.
814272Dated: New York, New York
March |, 2015
Yours, etc.,
tf. A f -
lanes | peer
Kenneth J. Kutner cf
Attorneys for Defendant/third-party plaintiff
PLAZA CONSTRUCTION, LLC f/k/a
PLAZA CONSTRUCTION CORP.
570 Lexington Avenue, 4th Floor
New York, New York 10022
Tel, No.: (212) 644-4420
File No.: 731.37132
FABIANI COHEN & HALL, EL
TO: SACKS AND SACKS, LLP
Attorneys for Plaintiff
KEVIN McGONIGAL
150 Broadway — 4" Floor
New York, New York 10038
(212) 964-5570
JONES HIRSCH CONNORS MILLER & BULL, PC
Attomeys for Defendant
NYY STEAK MANHATTAN, LLC
One Battery Park Plaza
New York, New York 10004
212-527-1000
LAW OFFICES OF CHARLES J, SIEGEL
Attorneys for Defendant/third-party defendant
BARING INDUSTRIES, INC.
125 Broad Street - 7" Floor
New York, New York 10004
Attention: Nikolas E. Diamantis, Esq,
(814272
Preview
(FILED: NEW YORK COUNTY CLERK 03/16/2015 05:04 PM INDEX NO. 158327/2013 NYSCEF DOC. NO. 42 RECEIVED NYSCEF: 03/16/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK KEVIN McGONIGAL, Plaintiff, -against- Index No.: 158327/13 NYY STEAK MANHATTAN, LLC, PREF 7 WEST 51 STREET LLC, PLAZA CONSTRUCTION CORP. and BARING INDUSTRIES, INC, Defendants NOTICE TO TAKE PLAZA CONSTRUCTION CORP., DEPOSITION UPON ORAL EXAMINATION Defendant/Third-Party Plaintiff -against- BARING INDUSTRIES, INC., Third-Party Index No. §95146/14 Third-Party Defendant. PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony, upon oral examination of all adverse parties, will be taken before a Notary Public who is not an attorney, or employee of an attorney, for any party or prospective party herein and is not a person who would be disqualified to act as a juror because of interest or because of consanguinity or affinity to any party herein, to be held at the offices of FABIANI COHEN & HALL, LLP, 570 Lexington Avenue, New York, New York, on the 1m day of August, 2015, at 10:00 o'clock in the forenoon of that day, with respect to evidence material and necessary in the prosecution/defense of this action. That said person to be examined is required to produce at such examination all papers, documents, records, reports, written statements, correspondence, photographs, diagrams, etc. relating to the within action. 814272Dated: New York, New York March |, 2015 Yours, etc., tf. A f - lanes | peer Kenneth J. Kutner cf Attorneys for Defendant/third-party plaintiff PLAZA CONSTRUCTION, LLC f/k/a PLAZA CONSTRUCTION CORP. 570 Lexington Avenue, 4th Floor New York, New York 10022 Tel, No.: (212) 644-4420 File No.: 731.37132 FABIANI COHEN & HALL, EL TO: SACKS AND SACKS, LLP Attorneys for Plaintiff KEVIN McGONIGAL 150 Broadway — 4" Floor New York, New York 10038 (212) 964-5570 JONES HIRSCH CONNORS MILLER & BULL, PC Attomeys for Defendant NYY STEAK MANHATTAN, LLC One Battery Park Plaza New York, New York 10004 212-527-1000 LAW OFFICES OF CHARLES J, SIEGEL Attorneys for Defendant/third-party defendant BARING INDUSTRIES, INC. 125 Broad Street - 7" Floor New York, New York 10004 Attention: Nikolas E. Diamantis, Esq, (814272