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  • Kevin Mcgonigal v. Nyy Steak Manhattan, Llc, Plaza Construction Corp., Baring Industries, Inc. Tort document preview
  • Kevin Mcgonigal v. Nyy Steak Manhattan, Llc, Plaza Construction Corp., Baring Industries, Inc. Tort document preview
  • Kevin Mcgonigal v. Nyy Steak Manhattan, Llc, Plaza Construction Corp., Baring Industries, Inc. Tort document preview
  • Kevin Mcgonigal v. Nyy Steak Manhattan, Llc, Plaza Construction Corp., Baring Industries, Inc. Tort document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 04/17/2023 11:48 AM INDEX NO. 158327/2013 NYSCEF DOC. NO. 559 RECEIVED NYSCEF: 04/17/2023 EXHIBIT “L” EXHIBIT “L” FILED: NEW YORK COUNTY CLERK 04/17/2023 11:48 AM INDEX NO. 158327/2013 NYSCEF DOC. NO. 559 RECEIVED NYSCEF: 04/17/2023 FULLERTON BECK LLP May 1, 2018 David A. Lore, Esq. MILBER MAKRIS PLOUSADIS & SElDEN LLP 1000 Woodbury Road, Suite 402 Woodbury New York 11797 Re: McGonigal v. B & C Electric, et al Our File No.: 62-13 Dear Mr. Lore: Third-party defendant, B&G Electrical, hereby reject and object to the purported cross-claims served by your office as improper under CPLR 3019. New York does not permit the service of naked cross-claims, and as such, these cross-claims are void under the CPLR. Therefore, it is the position of B&G that the cross-claims served by your office are a nullity, as they are not in compliance with the CPLR. Without waiving any said objections, enclosed herein please find B&G's answer, with objections, to the purported cross-claims served by your office. Very truly yours, FULLERTON BECK LLP Eileen R. Fullerton Enclosures One W. Red Oak Lane. White Plains NY 10604 I (914) 305-8634