Party Discovery: Doris Cespedes v. Gustavo Lemus Sayes

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                                FILED: NASSAU COUNTY CLERK 06/14/2023 03:57 PM                                                      INDEX NO. 607750/2023
NYSCEF DOC. NO. 7                                                                           RECEIVED NYSCEF: 06/14/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NASSAU
           ------------------------------------------------------------x
           DORIS CESPEDES                                                  Index No.: 607750/2023

                                     Plaintiff,
                                                                           NOTICE TO TAKE DEPOSTION
                   -against-

           GUSTAVO LEMUS SAYES

                                     Defendant.

           ------------------------------------------------------------x
          TO:     ALL PARTIES

                         NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION:

                  PLEASE TAKE NOTICE that Pursuant to Article 31 of the Civil Practice Law and

         Rules the testimony, upon oral examination of Plaintiff and Defendant as 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, at 10 A.M. on the 14th

          day of July, 2023 with respect to evidence material and necessary in the prosecution/defense of

          this action:

                  All of the relevant facts and circumstances in connection with the accident which

          occurred on the 25th day of January, 2022 including negligence, contributory negligence,

          liability and damages.

                  That the said person to be examined is required to produce at such examination the

          following: That for the purpose of refreshing their recollection, the said parties are to have and

          produce upon such examination such records, books, papers, documents, correspondence copies

          thereof, and other writing and papers kept by them or in their custody or control as relate to




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FILED: NASSAU COUNTY CLERK 06/14/2023 03:57 PM                                                 INDEX NO. 607750/2023
NYSCEF DOC. NO. 7                                                                       RECEIVED NYSCEF: 06/14/2023




          matters in controversy in said action and to the dealings or transactions between the parties to

          said action, as alleged and set forth in the Complaint in said action and answers.

          Dated: Brooklyn, New York
                 June 14, 2023

                                                        Yours, etc.,

                                                        /s/ANTHONY MARTINE
                                                        ANTHONY MARTINE
                                                        McMAHON, MARTINE & GALLAGHER, LLP
                                                        Attorneys for Defendant
                                                        55 Washington Street, 7th Floor
                                                        Brooklyn, New York 11201
                                                        (212) 747-1230
                                                        Our File No.: 799.4367
          TO:

          LAW OFFICE OF COHEN & JAFFE, LLP
          Attorneys for Plaintiff
          2001 Marcus Avenue - Suite W295
          Lake Success, New York 11042
          Attn: CAITLIN MCNAUGHTON, ESQ.
          (516) 358-6900




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FILED: NASSAU COUNTY CLERK 06/14/2023 03:57 PM                                                                  INDEX NO. 607750/2023
NYSCEF DOC. NO. 7                                                                                      RECEIVED NYSCEF: 06/14/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NASSAU                                                                            Index #607750/2023

          DORIS CESPEDES

                               Plaintiff,

                   -against-

         GUSTAVO LEMUS SAYES

                               Defendant.


                   NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION
                                 McMAHON, MARTINE & GALLAGHER, LLP
                        ATTORNEYS FOR DEFENDANTS SEAN KENDALL and SHAROLETTE JENKINS
                                               55 WASHINGTON STREET, SUITE 720
                                                          BROOKLYN, N.Y. 11201
                                                             (212) 747-1230

          All Documents Contained Herein Certified Pursuant to Rule 130 By: Anthony Martine
                                                                             ANTHONY MARTINE

          STATE OF NEW YORK, COUNTY OF NASSAU ss: (If more than one box check - indicate after names type of service used)
         I, Marquise Eaddy, being sworn, say: I am not a party to the action, am over 18 years of age and
         reside at 55 Washington Street, Brooklyn, NY On June 14, 2023 I served the NOTICE TO TAKE
         DEPOSITION UPON ORAL EXAMINATION

         _X___ by transmitting the papers by electronic means through the New York State E-File System. I received
               an email from the New York State E-File System indicating that the transmission was received and
               delivered to all counsel in the action.

          TO:

          LAW OFFICE OF COHEN & JAFFE, LLP
          Attorneys for Plaintiff
          2001 Marcus Avenue - Suite W295
          Lake Success, New York 11042
          Attn: CAITLIN MCNAUGHTON, ESQ.
          (516) 358-6900




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