On August 23, 2016 a
Letter,Correspondence
was filed
involving a dispute between
Phadia Jean,
Vladimir Jean,
and
Orangetown Police Department,
Orangetown Police Officer,
Orangetown Town Of,
for Torts - Other (Abuse of Process)
in the District Court of Rockland County.
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151 North Main 4'" New City,New York 10956
Street, Floor,
Tel: 845.708.5900 Fax: 845.708.5899 Cell:
845.598.8253 e-mail:vgrownlaw@aol.com
ValerieJ. Crown Gindy Rivera
Member N.Y. State
and Fed. Ct. Bars Paralegal
Heather M. Nappi Robert Goetz
Member N.Y.and M.l.StateBars OfficeManager
Ellen D. Lazarus Samantha Pavarini
Member N.Y. Bar Paralegal
December 5, 2018
VIA FACSIMILE (845) 483-8492 & ELECTRONIC FILING
Honorable Robert M. Berliner
Supreme Court, Rockland County
1 South Main Street
New City, NY 10956
Re: Phadia Jean and Vladimir Jean v. Town of
Orangetown, et. al.
Index No. 033456/2016
Dear Honorable Judge Berliner:
As you are aware, this office represents plaintiffs in the above-entitled matter.
Pursuant to the Court's discovery order, plaintiff is tofile a note of issue by December 7, 2018. At
this time, we respectfully request an extension of time in which to file the note of issue, as there remain
outstanding discovery issues which will be raised at the Compliance Conference scheduled before you on
December 10, 2018.
Thank you for giving this matter your continued courtesy and cooperation.
Respectfully yours,
Ellen D. Laz s
EDL/sp
VIA FACSIMILE: (845) 359-2715 and e-filing
CC: Attention Richard Pakola, Deputy Town Attorney
Document Filed Date
December 05, 2018
Case Filing Date
August 23, 2016
Category
Torts - Other (Abuse of Process)
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151 North Main 4'" New City,New York 10956 Street, Floor, Tel: 845.708.5900 Fax: 845.708.5899 Cell: 845.598.8253 e-mail:vgrownlaw@aol.com ValerieJ. Crown Gindy Rivera Member N.Y. State and Fed. Ct. Bars Paralegal Heather M. Nappi Robert Goetz Member N.Y.and M.l.StateBars OfficeManager Ellen D. Lazarus Samantha Pavarini Member N.Y. Bar Paralegal December 5, 2018 VIA FACSIMILE (845) 483-8492 & ELECTRONIC FILING Honorable Robert M. Berliner Supreme Court, Rockland County 1 South Main Street New City, NY 10956 Re: Phadia Jean and Vladimir Jean v. Town of Orangetown, et. al. Index No. 033456/2016 Dear Honorable Judge Berliner: As you are aware, this office represents plaintiffs in the above-entitled matter. Pursuant to the Court's discovery order, plaintiff is tofile a note of issue by December 7, 2018. At this time, we respectfully request an extension of time in which to file the note of issue, as there remain outstanding discovery issues which will be raised at the Compliance Conference scheduled before you on December 10, 2018. Thank you for giving this matter your continued courtesy and cooperation. Respectfully yours, Ellen D. Laz s EDL/sp VIA FACSIMILE: (845) 359-2715 and e-filing CC: Attention Richard Pakola, Deputy Town Attorney