No Value: Alban Zaimi, Entuela Zaimi v. Igotru, Llc, Edgemere Commons B1 L.P., Ec A1 Housing Development Fund Corporation, Ec A1 Limited Partnership, Ec A1 Commercial Llc., Ec Parcel, L.L.C., Chateau Gc Llc, Peninsula Rockaway Housing Development Fund Corp., Peninsula Rockaway, L.P., Peninsula Rockaway Limited Partnership, Peninsula Rockaway Gp Llc., The Arker Companies, The Arker Companies Llc.

On August 14, 2023 a No Value was filed involving a dispute between Alban Zaimi, Entuela Zaimi, and Chateau Gc Llc, Ec A1 Commercial Llc., Ec A1 Housing Development Fund Corporation, Ec A1 Limited Partnership, Ec Parcel, L.L.C., Edgemere Commons B1 L.P., Igotru, Llc, Peninsula Rockaway Gp Llc., Peninsula Rockaway Housing Development Fund Corp., Peninsula Rockaway Limited Partnership, Peninsula Rockaway, L.P., The Arker Companies, The Arker Companies Llc., for Torts - Other (Labor Law- Construction) in the District Court of Queens County.

Preview
FILED: QUEENS COUNTY CLERK 09/06/2023 11:43 AM INDEX NO. 716747/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 09/06/2023

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
--------------------------------------------------------------------x
ALBAN ZAIMI and ENTUELA ZAIMI Index No: 716747/2023

Plaintiff(s), Certification
-against-

IGOTRU, LLC, EDGEMERE COMMONS B1 L.P.,
EC AI HOUSING DEVELOPMENT FUND
CORPORATION, EC A1 LIMITED PARTNERSHIP,
EC A1 COMMERCIAL LLC., EC PARCEL, L.L.C.,
CHATEAU GC LLC, PENINSULA ROCKAWAY
HOUISNG DEVELOPMENT FUND CORP.,
PENINSULA ROCKAWAY, L.P., PENINSULA
ROCKAWAY LIMITED PARTNSHIP, PENINSULA
ROCKAWAY GP LLC., THE ARKER COMPANIES,
and THE ARKER COMPANIES LLC.,

Defendant(s).
--------------------------------------------------------------------x
C O U N S E L O R S:

PLEASE TAKE NOTICE, that the annexed documents are hereby Certified by the signature

which appears below.

Dated: New York, New York
September 6, 2023 FUCHS ROSENZWEIG PLLC

Cheryl Fuchs
/s/
__________________________
Cheryl Fuchs, Esq.
Attorneys for Defendants
EC A1 HOUSING DEVELOPMENT FUND
CORPORTION, EC A1 LIMITED
PARTNERSHIP, EC A1 COMMERCIAL
LLC, CHATEAU GC LLC, PENINSULA
ROCKAWAY HOUSING DEVELOPMENT
FUND CORP., PENINSULA ROCKAWAY,
LP., and THE ARKER COMPANIES,
11 Broadway, Suite 570
New York, New York 10004
(212) 933-9901
Fr File No.: 230.12372
To: (All Parties via NYSCEF)

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
--------------------------------------------------------------------x
ALBAN ZAIMI and ENTUELA ZAIMI Index No: 716747/2023

Plaintiff(s), Demand for Bills of Particulars
-against-

Defendant(s).
--------------------------------------------------------------------x

PLEASE TAKE NOTICE, that you are hereby required to serve and file the following

verified particulars of plaintiff’s alleged cause of action herein, within thirty (30) days from the date

hereof:

1. The date of birth, social security number and residence of each plaintiff.

2. Date, approximate time, location and condition of weather at time of accident.

3. State the exact manner in which plaintiff alleges or will allege the accident occurred.

4. A statement of the acts or omissions constituting the negligence claimed.

5. Give the nature, extent, location and duration of each and every injury claimed to have

been sustained by each plaintiff specifying each injury which is claimed permanent or that none is

permanent.

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6. How long will it be claimed that each plaintiff was confined to (a) hospital or hospitals,

giving specific dates of admission and discharge, (b), bed and (c) home, giving the specific dates of

confinement.

7. If x-rays, MRIs, CT Scans, EMGs or other diagnostic tests were taken, state the name

and address of the place where they were taken, the name and address of the person who took them,

the date each was taken and what it disclosed.

8. If treated by doctors or medical care providers, state the name and present address of

each doctor or medical care provider, the dates and places where treatments were received and the

date of last treatment. Annex true copies of all written reports rendered to you by any such doctors

whom you propose to have testify in your behalf.

9. If still being treated, the name and address of each doctor rendering treatment, where

and how often treatment is received and the nature thereof.

10. If a previous injury, disease, illness or condition is claimed to have been aggravated,

accelerated or exacerbated, specify in detail the nature of each and the name and present address of

each doctor, if any, who rendered treatment for said condition.

11. If employed at the time of accident, state: (a) The name and address of the employer.

(b) Position held and nature of work performed. (c) Average weekly wages for past year. (d) Period

of time lost from employment, giving dates. (e) Amount of wages lost, if any.

12. If other loss of income, profit or earnings is claimed:

(a) State total amount of said loss.

(b) Give a complete detailed computation of said loss.

deprivation thereof.

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13. Itemize any and all other losses or expenses incurred not otherwise set forth.

14. State what earnings, if any, each plaintiff claims to have lost.

15. If there has been a return to employment or occupation, state:

(a) Name and address of present employer.

(b) Position held and nature of work performed.

16. State the sum of money claimed incurred or spent by or on behalf of each plaintiff for:

(a) medicines,

(b) physicians services,

(d) nurses' services, itemizing amounts paid to each doctor or hospital.

17. Describe all injuries sustained by you in any prior accident.

18. Annex hereto copies of all interrogatories or bills of particular ever signed by you in

said prior incidents.

19. If damage to property is claimed to have resulted from such accident:

a. describe in detail each and every item of property allegedly damaged;

b. state the cost to repair or replace each and every item of damage to plaintiff's

property;

c. state the amount of damages sustained by plaintiff for loss of profits and how

this amount was calculated.

20. If the accident involves property or premises, state:

a. the exact part or portion of the premises wherein the alleged accident occurred;

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b. if said occurrence took place upon a stairway the location and the step thereon.

If accident happened on sidewalk, the distance from the nearest intersection and

the nearest curb or building line;

c. the exact defect which caused the alleged occurrence and in what manner the

defendants were negligent;

d. whether this defendant had actual and/or constructive notice of the alleged

defective condition;

e. if such notice was actual, state who gave such notice, to whom same was given

and the date and who gave such notice. If constructive, the length of time the

condition existed.

f. if it is claimed that negligent repairs were made, state when, where and by

whom on behalf of the defendant they were made, and in what manner such

repairs were negligent.

21. If an intentional act or tort is claimed:

a. set forth in detail the circumstances leading up to the alleged intentional act,

including but not limited to, the physical acts, verbal threats, etc.,

b. set forth the exact acts which are alleged to constitute the intentional act.

22. State what statutes, regulations, rules, ordinances, industry wide customs or practices

it will be claimed were violated by this defendant, specifying the chapter, section, subdivision, article

or practice thereof:

a. the date of each alleged violation;

b. how and in what manner was each violation committed by this defendant.

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23. State whether plaintiff was married at the time of the occurrence alleged in the

Complaint.

24. Set forth the name and address of plaintiff's spouse.

25. If a claim will be made for loss of service or consortium set forth the manner in which

such damages are calculated.

a. identify the nature of the loss of services or consortium;

b. set forth the length of time for which such claim is made.

PLEASE TAKE FURTHER NOTICE, that in the event of the plaintiff's failure to comply

with the foregoing demand within thirty (30) days, the defendant will move to preclude the offering

of any evidence as to the matters herein demanded.

Dated: New York, New York
September 6, 2023 FUCHS ROSENZWEIG PLLC
Attorneys for Defendants
EC A1 HOUSING DEVELOPMENT FUND
CORPORTION, EC A1 LIMITED
PARTNERSHIP, EC A1 COMMERCIAL
LLC, CHATEAU GC LLC, PENINSULA
ROCKAWAY HOUSING DEVELOPMENT
FUND CORP., PENINSULA ROCKAWAY,
LP., and THE ARKER COMPANIES,
11 Broadway, Suite 570
New York, New York 10004
(212) 933-9901
Fr File No.: 230.12372
To: (All Parties via NYSCEF)

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
--------------------------------------------------------------------x
ALBAN ZAIMI and ENTUELA ZAIMI Index No: 716747/2023

Plaintiff(s), Notice to take Depositions
-against-

Defendant(s).
--------------------------------------------------------------------x
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules the

testimony, upon oral examination, of all 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, at the offices of Fuchs Rosenzweig, PLLC, 11 Broadway, Suite 570, New

York, New York 10004, on the 27th day of October 2023 at 10:00 o'clock in the forenoon of that day

with respect to the evidence material and necessary in the defense of this action.

That the said person to be examined is required to produce at such examination the following:

books, records and papers pertaining to the above action.

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
--------------------------------------------------------------------x
ALBAN ZAIMI and ENTUELA ZAIMI Index No: 716747/2023

Plaintiff(s), Combined Demands with First
Notice to Produce Documents
-against-

Defendant(s).
--------------------------------------------------------------------x
PLEASE TAKE NOTICE, that pursuant to CPLR Section 3101 et seq., you are hereby

required to comply with this Combined Discovery Demand and First Notice to Produce within twenty

(20) days from the date of service hereof:

First Notice to Produce Documents

1. All documents that relate to or support your claim that this defendant was negligent.

2. All documents that relate to or support your claim that this defendant had notice, either

actual or constructive, of the condition that your claim caused your accident.

3. All documents that relate to or support your claim that plaintiffs sustained permanent

or disabling injuries.

4. All documents that relate to or support your claim that plaintiffs sustained lost income

or diminished earning capacity as a result of the incident in question.

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5. All documents, bills, and statements that relate to or support your claim quantifying

plaintiffs’ total medical bills.

6. All documents, bills, and statements that relate to or support your claim quantifying

those amounts paid by any collateral source including insurance for plaintiffs’ medical bills.

7. All documents, bills, and statements that relate to or support your claim quantifying

those amounts paid out of pocket by or on behalf of plaintiffs for plaintiffs’ medical bills.

Demand for Names and Addresses of Experts

Set forth in writing:

1. The name and address of each and every expert witness.

2. The qualifications of each and every expert witness.

3. The subject matter on which each and every expert is expected to testify.

4. The substance of the facts on which each and every expert is expected to testify.

5. The substance of the opinion of each and every witness.

6. A summary of the grounds of each and every expert's opinion.

Demand for Statements

1. A copy of the statement of any party, agent, servant and/or employee of any party

represented by the undersigned whether signed or unsigned or the transcript of any electronically

recorded statement in accordance with CPLR 3101(e).

PLEASE TAKE FURTHER NOTICE that if said party is a corporation, the undersigned

demands that you serve upon him a copy of a written statement, whether signed or unsigned, or the

transcript of any electronically recorded statement of any officer, director, agent, servant or employee

in accordance with CPLR 3101(e).

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PLEASE TAKE FURTHER NOTICE that the term “statement” shall be defined in

accordance with the definition set forth in accordance with CPLR 3101(e).

Demand for Witnesses (Eyewitness, Notice and Admissions):

Pursuant to CPLR 3101, et. seq., plaintiff(s) and co-defendant(s) are required to serve upon

and deliver to the undersigned, the names and addresses of any and all witnesses to the occurrence

complained of herein, whether or not obtained by investigation made after the date of the occurrence

and regardless of how made.

PLEASE TAKE FURTHER NOTICE, that demand is also made for the names and

addresses of any and all witnesses whose testimony will be relied on to prove the existence of a

defective condition, whether or not obtained by investigation made after the date of the occurrence

and regardless of how made.

PLEASE TAKE FURTHER NOTICE, that demand is also made for the names and

addresses of any witnesses concerning any admission allegedly made by any party.

PLEASE TAKE FURTHER NOTICE, that demand is also made for the name and last

known place of residence or business of any person with information or knowledge of facts relevant

to the incident(s) or occurrence(s) which is the subject of this litigation.

PLEASE TAKE FURTHER NOTICE, that this demand shall be deemed to continue during

the pendency of the action including the trial thereof. In the event of failure or refusal to comply with

this demand, the defendant(s) shall seek to preclude the testimony of any such witnesses.

Demand for Accident Reports

Copies of all written reports of the accident or occurrence which is the subject of this lawsuit

prepared in the regular course of business operations or practices of any person, firm, corporation,

association or other public or private entity.

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Demand for Project File

Copy of defendant’s entire project file with respect to the location referred to in the pleadings,

or concerning work at the premises where the incident allegedly occurred, including but not limited to

daily logs, photographs, and architectural drawings.

Demand for Collateral Source Information Pursuant to CPLR 4545

1. A statement whether any part of the cost of medical care, dental care, custodial care,

rehabilitation services, loss of earnings, or other economic loss sought to be recovered herein was

replaced or indemnified, in whole or in part, from any collateral source such as insurance, social

security, workers' compensation, employee benefits programs, etc.

2. If so, state the full name and address of each organization, program or entity

providing such replacement or indemnification.

3. An itemized statement of the amount in which each such claim of economic loss was

replaced or indemnified by each organization, program or entity identified in (2) above.

4. Duly executed and acknowledged original written authorizations allowing us to

obtain all such records.

PLEASE TAKE FURTHER NOTICE that, you are required to timely supplement your

responses to the foregoing demands with any additional or further information which becomes known

to you or your attorneys during this action from plaintiff’s health, disability or other insurer or entity

paying or reimbursing such economic loss.

Demand for Employment Records

1. The names and addresses of all plaintiff(s)' employers for five (5) years prior to the

accident and up to the present, including the dates of employment by each such employer;

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2. Duly executed and acknowledged original written authorizations to allow us to obtain

the complete employment records for the plaintiff(s) from each of the employers identified in (1)

above;

Demand for Medical Records

Please take notice, that demand is hereby made that you serve upon the undersigned duly

executed HIPAA compliant authorizations for the release of records pertaining to the care and

treatment rendered to plaintiff(s) in any and all hospitals.

Demand is additionally made for the production of the records of treating physicians and

HIPAA compliant authorizations permitting the inspection of said records, together with a list of the

names and addresses of all treating physicians.

Demand is additionally made for the production of medical reports of those physicians who

have previously treated or examined the plaintiff(s) and who will testify on his/her behalf. These shall

include a detailed recital of the injuries and conditions as to which testimony will be offered at the

trial, referring to and identifying those x-rays and technician reports which will be offered at the trial.

Demand is additionally made for all medical records, reports, charts, x-rays and tests (or duly

executed authorization to obtain same), from any and all sources concerning the injuries, illness,

physical or mental condition of plaintiff(s) as respects any injury, illness, physical or mental condition

referred to in plaintiff(s) bill of particulars, answers to interrogatories or deposition.

Demand Pursuant to The Medicare, Medicaid and SCHIP Extension Act of 2007

1. Pursuant to CPLR §3120(a) and the requirements of Section 111 of the Medicare,

Medicaid and SCHIP Extension Act of 2007 (42 U.S.C. §§1395(y)(b)(7) and (b) (8), provide:

a. The plaintiff’s date of birth;

b. The plaintiff’s Social Security No.;

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c. Execute and return the attached Medicare Informational Questionnaire as

required by The Centers for Medicare & Medicaid Services pursuant to Section 111 of the Medicare,

Medicaid and SCHIP Extension Act of 2007 (MMSEA), a new federal law that became effective

January 1, 2009.

d. The plaintiff’s Medicare Health Insurance Claim Numbers (HICNs), Medicaid

file number, New York State Department of Social Services (DSS) file number, and/or Medicare

Secondary Payor (MSP) file number, if applicable;

e. If the plaintiff has applied for or been awarded Medicare and/or Medicaid

and/or DSS and/or MSP benefits, all information/documentation related to the application and/or

award of said benefits;

f. If the plaintiff has applied for or been awarded Supplemental Security Income

(SSI) or Social Security Disability Insurance (SSDI), all information/documentation related to the

application and/or award of said benefits;

g. A statement as to whether plaintiff is eligible for Medicare of Medicaid;

h. If the plaintiff has been denied Medicare, Medicaid, SSI and/or SSDI benefits,

provide all information/documentation concerning any such denial; and

i. If the plaintiff has appealed or intends to appeal the denial of Medicare,

Medicaid, SSI and/or SSDI benefits, provide all information/documentation of any such appeal or

intent to appeal of the denial of such benefits;

j. State whether Medicare, Medicaid and/or the Social Security Administration

has a lien on any potential award, judgment or settlement in this lawsuit and, if so, state the amount of

such liens and provide all information/documentation relative to these liens.

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2. Pursuant to CPLR §3101(a), provide executed and acknowledged written

authorizations permitting defendant’s attorneys and defendant’s representatives to obtain and make

copies of all Medicare records, Parts A and B, specifying the correct address of said Medicare office,

along with the plaintiff’s Social Security Number and file number. Said defendant further demands

that a signed original of the attached Authorization of Use and Disclosure of Health Information and/or

a specific authorization required by Medicare be executed and provided to the undersigned for use in

conjunction with this demand.

3. Pursuant to CPLR §3101(a), provide duly executed and acknowledged written

authorizations permitting defendant’s attorneys and defendant’s representatives to obtain and make

copies of all Medicaid records, specifying the correct address of said Medicaid office, along with the

plaintiff’s Social Security Number and the file number. Said defendant further demands that a signed

original of the attached Authorization for Release of Medicaid Protected Information, and/or any other

specific authorization required by Medicaid be executed and provided for use in conjunction with this

demand as it pertains to health information.

4. If plaintiff received or applied for Social Security benefits, including but not limited to

SSI or SSDI benefits, provide a duly executed and acknowledged written authorization setting forth

the correct Social Security file number, allowing the defendant’s attorneys and defendant’s

representatives to obtain and make copies of all files, records, and reports of the Social Security

Administration regarding the plaintiff. Said defendant further demands that a signed original of the

attached Social Security Administration Consent for Release of Information and/or any other specific

authorization required by the Social Security Administration be executed and provided for use in

conjunction with this demand as it pertains to health information.

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Demand for Photographs

1. All photographs, videotapes and visual depictions of the accident site or location.

2. All photographs, videotapes and visual depictions relating to any actual or constructive

notice provided to the defendant.

3. All photographs, videotapes and visual depictions depicting plaintiff’s injuries arising

out of the accident in question.

The above items are to be produced at the offices of FUCHS ROSENZWEIG PLLC, 11

Broadway, Suite 570, New York, New York 10004, where they shall be physically inspected and

reproduced by the undersigned attorneys or others acting on their behalf.

PLEASE TAKE FURTHER NOTICE that, you are required to timely supplement your

responses to the foregoing Combined Discovery Demands with any additional or further

information which becomes known to you or your attorneys during this action.

PLEASE TAKE FURTHER NOTICE that, in the event you fail to comply with the

foregoing Combined Discovery Demands, we will seek to preclude you from offering in evidence

at trial any matter which is not disclosed by you in response to this demand, in addition to all other

remedies available to this party.

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To: (All Parties via NYSCEF)

The Centers for Medicare & Medicaid Services (CMS) is the federal agency that oversees the
Medicare program. Many Medicare beneficiaries have other insurance in addition to their Medicare
benefits. Sometimes, Medicare is supposed to pay after the other insurance. However, if certain other
insurance delays payment, Medicare may make a “conditional payment” so as not to inconvenience the
beneficiary, and recover after the other insurance pays.

Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA), a new
federal law that became effective January 1, 2009, requires that liability insurers (including self-insurers),
no-fault insurers, and workers’ compensation plans report specific information about Medicare
beneficiaries who have other insurance coverage. This reporting is to assist CMS and other insurance plans
to properly coordinate payment of benefits among plans so that your claims are paid promptly and
correctly.

We are asking you to the answer the questions below so that we may comply with this law.

Please review this picture of the Medicare card to determine if you have, or have ever
had, a similar Medicare card.

Section I

Section II

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I understand that the information requested is to assist the requesting insurance arrangement to
accurately coordinate benefits with Medicare and to meet its mandatory reporting obligations
under Medicare law.

_________________________________ __________________________________
Claimant Name (Please Print) Claim Number

Name of Person Completing This Form If Claimant is Unable (Please Print)

___________________________________ ______________________________
Signature of Person Completing This Form Date

If you have completed Sections I and II above, stop here. If you are refusing to provide the
information requested in Sections I and II, proceed to Section III.

Section III

_________________________________ _________________________________
Claimant Name (Please Print) Claim Number

For the reason(s) listed below, I have not provided the information requested. I understand that
if I am a Medicare beneficiary and I do not provide the requested information, I may be violating
Are you presently, or have you ever been, enrolled in Medicare Part A or Part B? □Yes □No
If yes, please complete the following. If no, proceed to Section II.
Full Name: (Please print the name exactly as it appears on your SSN or Medicare card if available.)

Medicare Date of Birth - -
Claim (Mo/Day/Year)
Number:

Social Security Number: - - Sex □Female □Male
(If Medicare Claim Number is
Unavailable)

obligations as a beneficiary to assist Medicare in coordinating benefits to pay my claims
correctly and promptly.

Reason(s) for Refusal to Provide Requested Information:

______________________________________________________________________

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______________________________________________________________________

___________________________________ ____________________________
Signature of Person Completing This Form Date

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
--------------------------------------------------------------------x
ALBAN ZAIMI and ENTUELA ZAIMI Index No: 716747/2023

Plaintiff(s), Demand for Electronic
Tracking Data
-against-

Defendant(s).
--------------------------------------------------------------------x

PLEASE TAKE NOTICE, that you are hereby required to supply the undersigned, at the

below listed address, for discovery, inspection and copying, within thirty (30) days of the date

hereof, the following:

ELECTRONIC TRACKING DATA DEMANDS

PLEASE TAKE FURTHER NOTICE, that the undersigned demands pursuant to CPLR

Article 31, et seq., the following:

1. That any tracking device (FitBits; Apple Tracking Watch; or other Mobile Tracking

Devices) that was in place and/or installed.

2. Production of any and all raw data from any electronic tracking device in place and/or

installed be produced in both original electronic form as well as any and all downloads and/or print-

outs of said raw data for a period of 24 hours prior to the occurrence which is the subject of the above

captioned litigation and 24 hours following the same.

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3. The username and password of any World Wide Web access to the data from said

device for a period of 24 hours prior to the occurrence which is the subject of the above-captioned

litigation and 24 hours following same. Any and all text messages, e-mails and/or other reports and/or

alerts from said tracking devise for a period of 24 hours prior to the occurrence which is the subject of

the above captioned litigation and 24 hours following the same. A statement of the parameters of geo-

fencing and/or perimeter reports for a period of 24 hours prior to the occurrence which is the subject

of the above captioned litigation and 24 hours following the same. A sworn statement identifying the

manufacturer and model of said tracking device as well as the firmware and/or software version

running n said devise at the time of the loss which is the subject of the above-captioned action.

PLEASE TAE FURTHER NOTICE, that if there is any claim that any of the above demanded

record(s) and/or information cannot be located, have been destroyed or mislaid or for some other

reason no longer exists, an affidavit, from the plaintiffs personally, is hereby demanded pursuant to

Cromwell v. Ward, 183 A.D.2d 459, 584 N.Y.S.2d 295 1st Dep’t., 1992); Wilensky v. JrB Marketing

& Opinion Research, Inc., 161 A.D.2d 761, 556 N.Y.S.2d 356 (2nd Dep’t., 1990); and Jackson v. City

of New York, 185 A.D.2d 768, (N.Y.A.D., 1992). Said affidavit is to set forth, in detail, the following:

• Where the subject records were likely to be kept;
• What efforts, if any, were made to preserve them;
• Whether such records were routinely destroyed;
• Or; whether a research had been conducted in every location where the
records were likely to be found.

PLEASE TAKE FURTHER NOTICE, that this is a continuing demand notice and in the event

any of the requested documents and/or items are obtained after the aforesaid return date, same are to

be furnished to the undersigned within thirty (30) days after receipt.

21 of 36
FILED: QUEENS COUNTY CLERK 09/06/2023 11:43 AM INDEX NO. 716747/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 09/06/2023

PLEASE TAKE FURTHER NOTICE, that upon the failure to produce the requested

documents and/or items on the date and the time and place demanded, a Motion will be made for the

appropriate

Case Info

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Case No.

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Document Filed Date

September 06, 2023

Case Filing Date

August 14, 2023

County

Parties

Alban Zaimi Plaintiff
CAKANI, PRANVERA Attorney for the Plaintiff
CAKANI, YLLI Attorney for the Plaintiff
CHATEAU GC LLC Defendant
EC A1 COMMERCIAL LLC. Defendant
EC A1 HOUSING DEVELOPMENT FUND CORPORATION Defendant
EC A1 LIMITED PARTNERSHIP Defendant
EC PARCEL, L.L.C. Defendant
EDGEMERE COMMONS B1 L.P. Defendant
Entuela Zaimi Plaintiff
FUCHS, CHERYL DIANA Attorney for the Defendant
IGOTRU, LLC Defendant
LIU, GEOFREY CHIEN Attorney for the Defendant
PENINSULA ROCKAWAY GP LLC. Defendant
PENINSULA ROCKAWAY HOUSING DEVELOPMENT FUND CORP. Defendant
PENINSULA ROCKAWAY LIMITED PARTNERSHIP Defendant
PENINSULA ROCKAWAY, L.P. Defendant
PERO, SCOTT B Attorney for the Defendant
REICHARDT, COREY MARC Attorney for the Plaintiff
SOHNG, WON J. Attorney for the Defendant
SPARLING, JOHN E Attorney for the Defendant
THE ARKER COMPANIES Defendant
THE ARKER COMPANIES LLC. Defendant

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