On April 12, 2023 a
Party Discovery
was filed
involving a dispute between
Jose Romero,
and
Lawrence Exterior Restoration Corp.,
The Trustees Of Columbia University In The City Of New York,
for Torts - Other Negligence (Construction Accident)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 08/02/2023 01:01 AM INDEX NO. 153338/2023
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 08/02/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK Index No.: 153338/2023
-------------------------------------------------------------------X
JOSE ROMERO,
Plaintiff, CROSS NOTICE TO
TAKE DEPOSITION
-against- UPON ORAL
EXAMINATION AS TO
LAWRENCE EXTERIOR RESTORATION CORP. ALL DEFENDANTS
and THE TRUSTEES OF COLUMBIA UNIVERSITY
IN THE CITY OF NEW YORK,
Defendants.
--------------------------------------------------------------------X
PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and
Rules, the testimony upon oral examination of 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,
DATE/TIME: To be agreed upon
LOCATION: Virtually or To Be Agreed Upon
with respect to evidence material and necessary in the prosecution/defense of this action and all
relevant facts and circumstances in connection with the accident which occurred on July 26,
2021, including negligence, contributory negligence, liability and damages.
That, said to be examined, is required to produce at such examination all evidence
relative to the negligence, liability and damages of any party to this lawsuit.
Dated: Garden City, New York
August 2, 2023
1 of 3
FILED: NEW YORK COUNTY CLERK 08/02/2023 01:01 AM INDEX NO. 153338/2023
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 08/02/2023
Yours, etc.,
THE BONGIORNO LAW FIRM, PLLC
Brandon M. Cruz
By: _____________________________
BRANDON M. CRUZ
Attorneys for Plaintiff
JOSE ROMERO
1415 Kellum Place, Suite 205
Garden City, New York 11530
(516) 741-4170
TO:
SEGAL MCCAMBRIDGE SINGER &
MAHONEY, LTD
Attorneys for Defendant
LAWRENCE EXTERIOR RESTORATION CORP.
777 Third Avenue, Suite 2400
New York, New York 10017
(212) 651-7500
Attorney: Antigone Tzakis, Esq.
Email: atzakis@smsm.com
RIVKIN RADLER LLP
Attorneys for Defendant
THE TRUSTEES OF COLUMBIA UNIVERSITY
IN THE CITY OF NEW YORK
926 RXR Plaza – 10th Floor
Uniondale, New York 11556-0926
(516) 357-3289
File No.: 21519-1537
Attorney: Brian Schlosser, Esq.
Email: Brian.Schlosser@rivkin.com
2 of 3
FILED: NEW YORK COUNTY CLERK 08/02/2023 01:01 AM INDEX NO. 153338/2023
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 08/02/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK INDEX NO.: 153338/2023
JOSE ROMERO,
Plaintiff,
-against-
LAWRENCE EXTERIOR RESTORATION CORP.
and THE TRUSTEES OF COLUMBIA UNIVERSITY
IN THE CITY OF NEW YORK,
Defendants.
--------------------------------------------------------------------------------------------------------------------
CROSS NOTICE TO TAKE DEPOSITION
UPON ORAL EXAMINATIOIN
AS TO ALL DEFENDANTS
THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
JOSE ROMERO
1415 Kellum Place, Suite 205
Garden City, New York 11530
(516) 741-4170
ATTORNEY CERTIFICATION: Pursuant to NYCRR 130-1.1, the undersigned, an attorney
admitted to practice in the Courts of the State of New York, certifies, to the best of his
knowledge after reasonable inquiry, that the contentions contained in the annexed documents are
not frivolous.
Brandon M. Cruz
Dated: Garden City, New York By: _______________________________
August 2, 2023 Brandon M. Cruz, Esq.
PLEASE TAKE NOTICE
____ NOTICE OF ENTRY that the within is a true copy of a entered
in the office of the clerk of the within named Court on
____ NOTICE OF SETTLEMENT that an Order of which the within is a true copy will be
presented for settlement to the Hon. one of the judges of the within named Court, on
THE BONGIORNO LAW FIRM, PLLC
Attorneys for Plaintiff
3 of 3
Document Filed Date
August 02, 2023
Case Filing Date
April 12, 2023
Category
Torts - Other Negligence (Construction Accident)
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Preview
FILED: NEW YORK COUNTY CLERK 08/02/2023 01:01 AM INDEX NO. 153338/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 08/02/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No.: 153338/2023 -------------------------------------------------------------------X JOSE ROMERO, Plaintiff, CROSS NOTICE TO TAKE DEPOSITION -against- UPON ORAL EXAMINATION AS TO LAWRENCE EXTERIOR RESTORATION CORP. ALL DEFENDANTS and THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK, Defendants. --------------------------------------------------------------------X PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony upon oral examination of 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, DATE/TIME: To be agreed upon LOCATION: Virtually or To Be Agreed Upon with respect to evidence material and necessary in the prosecution/defense of this action and all relevant facts and circumstances in connection with the accident which occurred on July 26, 2021, including negligence, contributory negligence, liability and damages. That, said to be examined, is required to produce at such examination all evidence relative to the negligence, liability and damages of any party to this lawsuit. Dated: Garden City, New York August 2, 2023 1 of 3 FILED: NEW YORK COUNTY CLERK 08/02/2023 01:01 AM INDEX NO. 153338/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 08/02/2023 Yours, etc., THE BONGIORNO LAW FIRM, PLLC Brandon M. Cruz By: _____________________________ BRANDON M. CRUZ Attorneys for Plaintiff JOSE ROMERO 1415 Kellum Place, Suite 205 Garden City, New York 11530 (516) 741-4170 TO: SEGAL MCCAMBRIDGE SINGER & MAHONEY, LTD Attorneys for Defendant LAWRENCE EXTERIOR RESTORATION CORP. 777 Third Avenue, Suite 2400 New York, New York 10017 (212) 651-7500 Attorney: Antigone Tzakis, Esq. Email: atzakis@smsm.com RIVKIN RADLER LLP Attorneys for Defendant THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK 926 RXR Plaza – 10th Floor Uniondale, New York 11556-0926 (516) 357-3289 File No.: 21519-1537 Attorney: Brian Schlosser, Esq. Email: Brian.Schlosser@rivkin.com 2 of 3 FILED: NEW YORK COUNTY CLERK 08/02/2023 01:01 AM INDEX NO. 153338/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 08/02/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK INDEX NO.: 153338/2023 JOSE ROMERO, Plaintiff, -against- LAWRENCE EXTERIOR RESTORATION CORP. and THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK, Defendants. -------------------------------------------------------------------------------------------------------------------- CROSS NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATIOIN AS TO ALL DEFENDANTS THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff JOSE ROMERO 1415 Kellum Place, Suite 205 Garden City, New York 11530 (516) 741-4170 ATTORNEY CERTIFICATION: Pursuant to NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the Courts of the State of New York, certifies, to the best of his knowledge after reasonable inquiry, that the contentions contained in the annexed documents are not frivolous. Brandon M. Cruz Dated: Garden City, New York By: _______________________________ August 2, 2023 Brandon M. Cruz, Esq. PLEASE TAKE NOTICE ____ NOTICE OF ENTRY that the within is a true copy of a entered in the office of the clerk of the within named Court on ____ NOTICE OF SETTLEMENT that an Order of which the within is a true copy will be presented for settlement to the Hon. one of the judges of the within named Court, on THE BONGIORNO LAW FIRM, PLLC Attorneys for Plaintiff 3 of 3