Document for Najah Stevens v. Irt Partnership, Sdhr Management, Llc

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                                FILED: KINGS COUNTY CLERK 10/30/2023 03:11 PM                                                         INDEX NO. 521039/2017
NYSCEF DOC. NO. 83                                                                             RECEIVED NYSCEF: 10/30/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF KINGS
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          NAJAH STEVENS,

                                    Plaintiff,                                   Index No.: 521039/2017

                                                                                 NOTICE OF MOTION IN
                                                                                 SUPPORT OF DEFENDANTS’
                                                                                 MOTION IN LIMINE
                           -against-

          IRT PARTNERSHIP AND SDHR MANAGEMENT, LCC,

                                     Defendant.
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          PLEASE TAKE NOTICE, that upon the annexed Affirmation of Cynthia Kouril, dated October

          27, 2023 and the exhibits thereto, the Affidavit of Engineering Expert Rudi O. Sherbansky, and

          the Memorandum of Law, and upon all of the pleadings and proceedings herein, Defendants IRT

          PARTNERSHIP and SDHR MANAGEMENT, LCC will move before this Court on October 31 ,

          2023, at 10:00 a.m., or as soon thereafter as counsel can be heard, before the Hon. Mark I. Partnow,

          JSC, at the Supreme Court of the State of New York, Kings County located at 360 Adams Street,

          Brooklyn, New York, for an Order (a) precluding the admission into evidence of the expert

          report/affidavit of Plaintiff’s engineer Scott Silberman, and any testimony by that expert; (b)

          alternatively, precluding Plaintiff from admitting into evidence any report, testimony or other

          evidence referring to the statutes, ordinances, rules, regulations, and other guidelines and

          provisions cited by Plaintiff in her Expert Witness Disclosure; (c) precluding Silberman from

          testifying about, or Plaintiff from admitting into evidence any discussion of, the human gait or

          biomechanical principles of human anatomy; and (d) such other and further relief this Court deems




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FILED: KINGS COUNTY CLERK 10/30/2023 03:11 PM                              INDEX NO. 521039/2017
NYSCEF DOC. NO. 83                                               RECEIVED NYSCEF: 10/30/2023




          just and proper.:

          Dated: Bellmore, New York
                 October 30, 2023
                                      Yours, etc.


                                      _________________________
                                      Karen C. Higgins, Esq.
                                      THE GOLD LAW FIRM PC
                                      Attorneys for Defendants
                                       IRT PARTNERSHIP and SDHR
                                       MANAGEMENT CORP.
                                       1666 Newbridge Road, Second Floor
                                       Bellmore, New York 11710
                                       (516) 512-6333




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