On March 15, 2023 a
Party Discovery
was filed
involving a dispute between
Duberney Rincon-Leon,
and
35-01 Astoria Owner, Llc,
Aki Renovations, Inc.,
Rjb Contracting Carting Corp. D B A Armteck Construction Corp.,
Smb Qozb 1, Llc,
Sm Qozb 1, Llc,
for Torts - Other Negligence (Labor Law)
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 06/23/2023 10:46 AM INDEX NO. 705517/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/23/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
------------------------------------------------------------------------X
DUBERNEY RINCON-LEON,
Index No.: 705517/2023
Plaintiff,
NOTICE TO TAKE
-against- DEPOSITIONS UPON
ORAL EXAMINATION
35-01 ASTORIA OWNER, LLC, SMB QOZB 1, LLC,
RJB CONTRACTING CARTING CORP. D/B/A
ARMTECK CONSTRUCTION CORP., and AKI
RENOVATIONS, INC.,
Defendants.
------------------------------------------------------------------------X
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules,
the testimony, upon oral examination of plaintiff DUBERNEY RINCON-LEON 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 the office of COFFEY MODICA
O’MEARA LLP located at 200 E Post Rd, Suite 210, White Plains, New York 10601, on 20th day
of October, 2023, at 10:00 A.M. in the forenoon of that day with respect to evidence and material
necessary in the defense of this action.
That the said persons to be examined are required to produce at such examination any
and all documents relative to the claims in the Plaintiff’s Verified Complaint.
To the best of my knowledge, information and belief, formed after an inquiry reasonable under
the circumstances, the presentation of this paper or the contentions herein are not frivolous, as
that term is defined in Part 130 of the Court Rules.
Dated: White Plains, New York
June 23, 2023
Yours, etc.,
COFFEY MODICA O’MEARA LLP
_____________________________________
By: Michael P. Mezzacappa
Attorneys for Defendants
1
1 of 2
FILED: QUEENS COUNTY CLERK 06/23/2023 10:46 AM INDEX NO. 705517/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/23/2023
35-01 ASTORIA OWNER LLC s/h/a 35-01
ASTORIA OWNER, LLC; SM QOZB 1 LLC s/h/a
SMB QOZB 1, LLC; RJB CONTRACTING
CARTING CORP. s/h/a RJB CONTRACTING
CARTING CORP. D/B/A ARMTECK
CONSTRUCTION CORP.; and AKI
RENOVATIONS GROUP, INC. s/h/a AKI
RENOVATIONS, INC.
200 E. Post Road, Suite 210
White Plains, NY 10601
(212) 827-4501
File No. 1081-0056
TO: CHAIKIN, PLLC
Attorneys for Plaintiff
445 Broadhollow Road, Suite 232
Melville, NY 11747
(212) 977-2020
2
2 of 2
Document Filed Date
June 23, 2023
Case Filing Date
March 15, 2023
Category
Torts - Other Negligence (Labor Law)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: QUEENS COUNTY CLERK 06/23/2023 10:46 AM INDEX NO. 705517/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/23/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ------------------------------------------------------------------------X DUBERNEY RINCON-LEON, Index No.: 705517/2023 Plaintiff, NOTICE TO TAKE -against- DEPOSITIONS UPON ORAL EXAMINATION 35-01 ASTORIA OWNER, LLC, SMB QOZB 1, LLC, RJB CONTRACTING CARTING CORP. D/B/A ARMTECK CONSTRUCTION CORP., and AKI RENOVATIONS, INC., Defendants. ------------------------------------------------------------------------X PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony, upon oral examination of plaintiff DUBERNEY RINCON-LEON 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 the office of COFFEY MODICA O’MEARA LLP located at 200 E Post Rd, Suite 210, White Plains, New York 10601, on 20th day of October, 2023, at 10:00 A.M. in the forenoon of that day with respect to evidence and material necessary in the defense of this action. That the said persons to be examined are required to produce at such examination any and all documents relative to the claims in the Plaintiff’s Verified Complaint. To the best of my knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of this paper or the contentions herein are not frivolous, as that term is defined in Part 130 of the Court Rules. Dated: White Plains, New York June 23, 2023 Yours, etc., COFFEY MODICA O’MEARA LLP _____________________________________ By: Michael P. Mezzacappa Attorneys for Defendants 1 1 of 2 FILED: QUEENS COUNTY CLERK 06/23/2023 10:46 AM INDEX NO. 705517/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/23/2023 35-01 ASTORIA OWNER LLC s/h/a 35-01 ASTORIA OWNER, LLC; SM QOZB 1 LLC s/h/a SMB QOZB 1, LLC; RJB CONTRACTING CARTING CORP. s/h/a RJB CONTRACTING CARTING CORP. D/B/A ARMTECK CONSTRUCTION CORP.; and AKI RENOVATIONS GROUP, INC. s/h/a AKI RENOVATIONS, INC. 200 E. Post Road, Suite 210 White Plains, NY 10601 (212) 827-4501 File No. 1081-0056 TO: CHAIKIN, PLLC Attorneys for Plaintiff 445 Broadhollow Road, Suite 232 Melville, NY 11747 (212) 977-2020 2 2 of 2