On May 15, 2023 a
Party Notice
was filed
involving a dispute between
Doris Cespedes,
and
Gustavo Lemus Sayes,
for Torts - Motor Vehicle
in the District Court of Nassau County.
Preview
FILED: NASSAU COUNTY CLERK 06/22/2023 03:11 PM INDEX NO. 607750/2023
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 06/22/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
___-______..__________--____________________________Ç
DORIS CESPEDES, Index No.: 607750/2023
Plaintiff, NOTICE TO ADMIT
-against-
GUSTAVO LEMUS SAYES,
Defendants.
________________________________________________x
PLEASE TAKE NOTICE, that Plaintiff demands that the Defendant, GUSTAVO
LEMUS SAYES, admit the following facts pursuant to CPLR Section 3123:
PLEASE TAKE FURTHER NOTICE, that if the Defendants refuse to admit the truth
of such facts, at the time of trial Plaintiff will move for an order that said Defendants pay to
Plaintiff reasonable expenses incurred in acquiring and submitting proof that these answers do in
fact exist at this time as requested in this notice, including reasonable attorney's fees by reason of
the fact that there is no legitimate reason for the refusal to admit the truth of such facts, in that
the admission sought are of substantial importance and that no item in this notice is vague and
conclusory, ambiguous or complex.
1. That on January 25, 2022, Defendant GUSTAVO LEMUS SAYES was the owner
of a 2013 Ford motor vehicle bearing New York State license plate number KSM7824.
PLEASE TAKE FURTHER NOTICE, that each of the matters of which an admission
is requested shall be deemed admitted unless within twenty (20) days after service thereof, the
party to whom the request is directed serves upon the party requesting the admission a sworn
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FILED: NASSAU COUNTY CLERK 06/22/2023 03:11 PM INDEX NO. 607750/2023
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 06/22/2023
statement either denying specifically the matters of which an admission is requested or setting
forth in detail the reasons why he cannot truthfully either admit or deny those matters.
Dated: Lake Success, New York
June 22, 2023
Respectfully submitted,
B c AUGHTON, ESQ.
LAW OFFICE OF COHEN & JAFFE, LLP
Attorneys for Plaintif
2001 Marcus Avenue, Suite W295
Lake Success, New York 11042
Telephone: (516) 358-6900
www.CohenJaffe.com
TO:
McMAHON, MARTINE & GALLAGHER, LLP
Attorneys for Defendant
7th
55 Washington Street, FlOOr
Brooklyn, New York 11201
(212) 747-1230
File No.: 799.4367
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FILED: NASSAU COUNTY CLERK 06/22/2023 03:11 PM INDEX NO. 607750/2023
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 06/22/2023
Index No.: 607750/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
DORIS CESPEDES,
Plaintiff,
-against-
GUSTAVO LEMUS SAYES,
Defendant.
_________-_____________.._______________.._______________________________________
NOTICE TO ADMIT
____...____________________..------------------_____..____....________________..----
LAW OFFICE OF COHEN & JAFFE, LLP
Attorneys for Plaintif
2001 Marcus Avenue, Suite W295
Lake Success, N.Y. 11042
(516) 358-6900
www.CohenJaffe.com
3 of 3
Document Filed Date
June 22, 2023
Case Filing Date
May 15, 2023
Category
Torts - Motor Vehicle
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FILED: NASSAU COUNTY CLERK 06/22/2023 03:11 PM INDEX NO. 607750/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 06/22/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ___-______..__________--____________________________Ç DORIS CESPEDES, Index No.: 607750/2023 Plaintiff, NOTICE TO ADMIT -against- GUSTAVO LEMUS SAYES, Defendants. ________________________________________________x PLEASE TAKE NOTICE, that Plaintiff demands that the Defendant, GUSTAVO LEMUS SAYES, admit the following facts pursuant to CPLR Section 3123: PLEASE TAKE FURTHER NOTICE, that if the Defendants refuse to admit the truth of such facts, at the time of trial Plaintiff will move for an order that said Defendants pay to Plaintiff reasonable expenses incurred in acquiring and submitting proof that these answers do in fact exist at this time as requested in this notice, including reasonable attorney's fees by reason of the fact that there is no legitimate reason for the refusal to admit the truth of such facts, in that the admission sought are of substantial importance and that no item in this notice is vague and conclusory, ambiguous or complex. 1. That on January 25, 2022, Defendant GUSTAVO LEMUS SAYES was the owner of a 2013 Ford motor vehicle bearing New York State license plate number KSM7824. PLEASE TAKE FURTHER NOTICE, that each of the matters of which an admission is requested shall be deemed admitted unless within twenty (20) days after service thereof, the party to whom the request is directed serves upon the party requesting the admission a sworn 1 of 3 FILED: NASSAU COUNTY CLERK 06/22/2023 03:11 PM INDEX NO. 607750/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 06/22/2023 statement either denying specifically the matters of which an admission is requested or setting forth in detail the reasons why he cannot truthfully either admit or deny those matters. Dated: Lake Success, New York June 22, 2023 Respectfully submitted, B c AUGHTON, ESQ. LAW OFFICE OF COHEN & JAFFE, LLP Attorneys for Plaintif 2001 Marcus Avenue, Suite W295 Lake Success, New York 11042 Telephone: (516) 358-6900 www.CohenJaffe.com TO: McMAHON, MARTINE & GALLAGHER, LLP Attorneys for Defendant 7th 55 Washington Street, FlOOr Brooklyn, New York 11201 (212) 747-1230 File No.: 799.4367 2 of 3 FILED: NASSAU COUNTY CLERK 06/22/2023 03:11 PM INDEX NO. 607750/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 06/22/2023 Index No.: 607750/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU DORIS CESPEDES, Plaintiff, -against- GUSTAVO LEMUS SAYES, Defendant. _________-_____________.._______________.._______________________________________ NOTICE TO ADMIT ____...____________________..------------------_____..____....________________..---- LAW OFFICE OF COHEN & JAFFE, LLP Attorneys for Plaintif 2001 Marcus Avenue, Suite W295 Lake Success, N.Y. 11042 (516) 358-6900 www.CohenJaffe.com 3 of 3