On December 13, 2016 a
Request,Application
was filed
involving a dispute between
Suzanne Goodman,
and
New York Sports Clubs,
Town Sports International, Llc,
for Torts - Other Negligence (slip and fall)
in the District Court of Westchester County.
Preview
(FILED: NEW YORK COUNTY CLERK 0270372017 12:35 PM INDEX NO. 160437/2016
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 02/03/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
etter enn ee teen ene nn nn nn nntnd soneneneene
SUZANNE GOODMAN, : Index No.: 160437/2016
Plaintiff,
DEMAND FOR CHANGE
vs, OF VENUE
NEW YORK SPORTS CLUB and TOWN SPORTS :
INTERNATIONAL, LLC,
Defendants.
oe aaa
COUNSELOR(S):
PLEASE TAKE NOTICE, that defendant, TOWN SPORTS INTERNATIONAL, LLC,
d/b/a NEW YORK SPORTS CLUB i/s/b/a NEW YORK SPORTS CLUB, by and through its
attorneys, GORDON & REES LLP, herety demand that pursuant to CPLR §§ 501, 510 and
511(b), that the place of trial of the above-entitled action be changed from the County of NEW
YORK, in which it had been improperly placed, to the County of WESTCHESTER, where
venue would be proper as provided by CPLR §§ 501 and 510.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 511(b), plaintiff's
written consent to change venue, if any, must be served upon the undersigned within five (5)
days after service of this demand.
Dated: Harrison, New York
February 3, 2017
Respectfully Submitted,
GORDON & REES, LLP
By:
Greg ~ Brescia
Attomeys for Defendant
TOWN SPORTS INTERNATIONAL, LLC,
d/b/a NEW YORK SPORTS CLUB i/s/h/a
NEW YORK SPORTS CLUB,
500 Mamaroneck Avenue, Suite 503
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INDEX NO. 160437/2016
FILED: NEW YORK COUNTY CLERK 02/03/2017 12:35 PM
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 02/03/2017
Harrison, NY 10528
(914) 777-2225
File No.: TSIKK 1124553
TO: LANGSAM LAW LLP
Attomeys for Plaintiff
SUZANNE GOODMAN
217 Broadway, Suite 606
New York, New York 10007
(212) 742-2700
1124589991424725y 4
2 of 2
Preview
(FILED: NEW YORK COUNTY CLERK 0270372017 12:35 PM INDEX NO. 160437/2016 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 02/03/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK etter enn ee teen ene nn nn nn nntnd soneneneene SUZANNE GOODMAN, : Index No.: 160437/2016 Plaintiff, DEMAND FOR CHANGE vs, OF VENUE NEW YORK SPORTS CLUB and TOWN SPORTS : INTERNATIONAL, LLC, Defendants. oe aaa COUNSELOR(S): PLEASE TAKE NOTICE, that defendant, TOWN SPORTS INTERNATIONAL, LLC, d/b/a NEW YORK SPORTS CLUB i/s/b/a NEW YORK SPORTS CLUB, by and through its attorneys, GORDON & REES LLP, herety demand that pursuant to CPLR §§ 501, 510 and 511(b), that the place of trial of the above-entitled action be changed from the County of NEW YORK, in which it had been improperly placed, to the County of WESTCHESTER, where venue would be proper as provided by CPLR §§ 501 and 510. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 511(b), plaintiff's written consent to change venue, if any, must be served upon the undersigned within five (5) days after service of this demand. Dated: Harrison, New York February 3, 2017 Respectfully Submitted, GORDON & REES, LLP By: Greg ~ Brescia Attomeys for Defendant TOWN SPORTS INTERNATIONAL, LLC, d/b/a NEW YORK SPORTS CLUB i/s/h/a NEW YORK SPORTS CLUB, 500 Mamaroneck Avenue, Suite 503 1 of 2 INDEX NO. 160437/2016 FILED: NEW YORK COUNTY CLERK 02/03/2017 12:35 PM NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 02/03/2017 Harrison, NY 10528 (914) 777-2225 File No.: TSIKK 1124553 TO: LANGSAM LAW LLP Attomeys for Plaintiff SUZANNE GOODMAN 217 Broadway, Suite 606 New York, New York 10007 (212) 742-2700 1124589991424725y 4 2 of 2