On July 05, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Anthony Magni,
and
Clune Construction Company, L.P.,
Concepts For Business, Llc,
G&S Concepts, Inc.,
Polsinelli Pc,
Third Avenue Tower Owner, Llc,
for Torts - Other Negligence (Premises liability)
in the District Court of New York County.
Preview
INDEX NO. 155570/2016
FILED: NEW YORK COUNTY CLERK 01/12/2017 01:53 PM
NYSCEF DOC. NO} 21 RECEIVED NYSCEF: 01/12/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
ne an -X
ANTHONY MAGNI, Index No.:155570/16E
Plaintiff, NOTICE OF MOTION
-against-
THIRD AVENUE TOWER OWNER, LLC, POLSINELLI
PC and CLUNE CONSTRUCTION COMPANY, L.P.,
Defendants.
nanan X
MOTION BY: Defendant, THIRD AVENUE TOWER OWNER, LLC,
by their attorneys, O; CONNOR REDD LLP, will move
this Court.
DATE AND PLACE: On February 3, 2017 at 9:30 a.m. at the Supreme
Court, New York County, located at 60 Centre Street,
New York, New York 10007.
RELIEF REQUESTED: (a) For an Order, pursuant to CPLR §3124 and CPLR
§3126, compelling plaintiff and defendants to respond
to movants’ outstanding discovery demands; and
(b) Such further relief as to this Court may deem to be
just, proper and equitable.
SUPPORTING PAPERS. Affirmation of Sean A. Latella, Esq., dated January 12,
2017, together with exhibits and all prior pleadings had
herein to date.
NATURE OF ACTION: Personal Injury.
ANSWERING PAPERS: Demand is hereby made that, pursuant to CPLR
2214(b), answering papers, if any, shall be personally
served upon the undersigned at least seven (7) days
prior to the return date of this motion.
1 of 2
PLEASE TAKE NOTICE, that service by fax is not accepted Please call to
request permission of this firm if you wish to serve by fax.
Dated: January 12, 2017
Port Chester, New York
Yours, etc.,
O’CONNOR REDD LLP
AZCA Os thse
Sean A. Latella
Attorney for Defendant
THIRD AVENUE TOWER OWNER, LLC.
242 King Street
P.O. Box 1000
Port Chester, New York 10573
(914) 686-1700
Our File No.:D-6226
latella@oconnorlawfirm.com
TO:
Laurence D. Rogers, Esq.
SACKSTEIN, SACKSTEIN & LEE, LLP
1140 Franklin Avenue, Suite 210
Garden City, New York 11530
Sana Suhail, Esq.
LEWIS BRISBOIS BISGAARD & SMITH, LLP
77 Water Street, 21* Floor
New York, New York 1000
John R. Marquez, Esq.
EUSTACE, MARQUEZ, EPSTEIN
PREZIOSO & ARCIOLD
55 Water Street, 29" Floor
New York, New York 10041
Des
2 of 2
Preview
INDEX NO. 155570/2016 FILED: NEW YORK COUNTY CLERK 01/12/2017 01:53 PM NYSCEF DOC. NO} 21 RECEIVED NYSCEF: 01/12/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ne an -X ANTHONY MAGNI, Index No.:155570/16E Plaintiff, NOTICE OF MOTION -against- THIRD AVENUE TOWER OWNER, LLC, POLSINELLI PC and CLUNE CONSTRUCTION COMPANY, L.P., Defendants. nanan X MOTION BY: Defendant, THIRD AVENUE TOWER OWNER, LLC, by their attorneys, O; CONNOR REDD LLP, will move this Court. DATE AND PLACE: On February 3, 2017 at 9:30 a.m. at the Supreme Court, New York County, located at 60 Centre Street, New York, New York 10007. RELIEF REQUESTED: (a) For an Order, pursuant to CPLR §3124 and CPLR §3126, compelling plaintiff and defendants to respond to movants’ outstanding discovery demands; and (b) Such further relief as to this Court may deem to be just, proper and equitable. SUPPORTING PAPERS. Affirmation of Sean A. Latella, Esq., dated January 12, 2017, together with exhibits and all prior pleadings had herein to date. NATURE OF ACTION: Personal Injury. ANSWERING PAPERS: Demand is hereby made that, pursuant to CPLR 2214(b), answering papers, if any, shall be personally served upon the undersigned at least seven (7) days prior to the return date of this motion. 1 of 2 PLEASE TAKE NOTICE, that service by fax is not accepted Please call to request permission of this firm if you wish to serve by fax. Dated: January 12, 2017 Port Chester, New York Yours, etc., O’CONNOR REDD LLP AZCA Os thse Sean A. Latella Attorney for Defendant THIRD AVENUE TOWER OWNER, LLC. 242 King Street P.O. Box 1000 Port Chester, New York 10573 (914) 686-1700 Our File No.:D-6226 latella@oconnorlawfirm.com TO: Laurence D. Rogers, Esq. SACKSTEIN, SACKSTEIN & LEE, LLP 1140 Franklin Avenue, Suite 210 Garden City, New York 11530 Sana Suhail, Esq. LEWIS BRISBOIS BISGAARD & SMITH, LLP 77 Water Street, 21* Floor New York, New York 1000 John R. Marquez, Esq. EUSTACE, MARQUEZ, EPSTEIN PREZIOSO & ARCIOLD 55 Water Street, 29" Floor New York, New York 10041 Des 2 of 2