On December 22, 2022 a
Party Discovery
was filed
involving a dispute between
Nadezhda Zaytseva
, Administratrix Of The Estate Of Irina A. Zaytseva, Deceased,,
and
Andrew D. Tift
,,
Doreen Macdonald
;,
Earle R. Hill Iii
; And,
Scott J. Macdonald
;,
for Torts - Other Negligence (Personal Injury)
in the District Court of Tioga County.
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FILED: TIOGA COUNTY CLERK 12/31/2022 03:55 PM INDEX NO. 2022-00062771
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 12/31/2022
STATE OF NEW YORK
SUPREME COURT : COUNTY OF TIOGA
NADEZHDA ZAYTSEVA, Administratrix of the
Estate of Irina A. Zaytseva, deceased
NOTICE TO TAKE
DEPOSITION UPON
Plaintiff, ORAL EXAMINATION
vs.
SCOTT J. MACDONALD; DOREEN
MACDONALD; EARLE R. HILL, III; ,
and ANDREW D. TIFT,
Index No. 2022-00062771
Defendants
PLEASE TAKE NOTICE, that, pursuant to Article 31 of Civil Practice Law and Rules,
the testimony, upon oral examination, of NADEZHDA ZAYTSEVA, as party witness, 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 place, date
and time to be agreed upon by the parties with respect to evidence material and necessary in
the defense of the aforementioned action.
PLEASE TAKE FURTHER NOTICE, that you are required to bring all documents
reviewed by the deponent in preparation for the deposition and which were used to refresh the
deponent's recollection.
Dated: December 30, 2022
1 of 2
FILED: TIOGA COUNTY CLERK 12/31/2022 03:55 PM INDEX NO. 2022-00062771
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 12/31/2022
MARK D. GORIS, Esq.
Attorney for Defendants MacDonald
Office and Post Office Address
5 Mill Street
Cazenovia, New York 13035
Telephone: (315) 815-5092
meoris@gorislegal.com
TO: WILENTZ, GOLDMAN & SPITZER, P.A.
By: Kevin M. Berry, Esq.
Attorneys for Plaintiff
Office and Post Office Address
14 Wall Street, Suite 6B
New York, New York 10005
Telephone: (646) 746-8914
2 of 2
Document Filed Date
December 31, 2022
Case Filing Date
December 22, 2022
Category
Torts - Other Negligence (Personal Injury)
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FILED: TIOGA COUNTY CLERK 12/31/2022 03:55 PM INDEX NO. 2022-00062771 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 12/31/2022 STATE OF NEW YORK SUPREME COURT : COUNTY OF TIOGA NADEZHDA ZAYTSEVA, Administratrix of the Estate of Irina A. Zaytseva, deceased NOTICE TO TAKE DEPOSITION UPON Plaintiff, ORAL EXAMINATION vs. SCOTT J. MACDONALD; DOREEN MACDONALD; EARLE R. HILL, III; , and ANDREW D. TIFT, Index No. 2022-00062771 Defendants PLEASE TAKE NOTICE, that, pursuant to Article 31 of Civil Practice Law and Rules, the testimony, upon oral examination, of NADEZHDA ZAYTSEVA, as party witness, 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 place, date and time to be agreed upon by the parties with respect to evidence material and necessary in the defense of the aforementioned action. PLEASE TAKE FURTHER NOTICE, that you are required to bring all documents reviewed by the deponent in preparation for the deposition and which were used to refresh the deponent's recollection. Dated: December 30, 2022 1 of 2 FILED: TIOGA COUNTY CLERK 12/31/2022 03:55 PM INDEX NO. 2022-00062771 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 12/31/2022 MARK D. GORIS, Esq. Attorney for Defendants MacDonald Office and Post Office Address 5 Mill Street Cazenovia, New York 13035 Telephone: (315) 815-5092 meoris@gorislegal.com TO: WILENTZ, GOLDMAN & SPITZER, P.A. By: Kevin M. Berry, Esq. Attorneys for Plaintiff Office and Post Office Address 14 Wall Street, Suite 6B New York, New York 10005 Telephone: (646) 746-8914 2 of 2