On August 27, 2020 a
Party Discovery
was filed
involving a dispute between
Cornerstone Community Federal Credit Union,
and
Lynne Smith,
Robert Smith,
for Other Matters - Consumer Credit (Non-Card) Transaction
in the District Court of Erie County.
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FILED: ERIE COUNTY CLERK 11/29/2021 11:29 AM INDEX NO. 809444/2020
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 11/29/2021
STATE OF NEW YORK
SUPREME COURT: COUNTY OF ERIE
__________________________________
CORNERSTONE COMMUNITY CREDIT UNITION
NOTICE OF EXAMINATION
Plaintiff, BEFORE TRIAL DIRECTED TO
CORNERSTONE COMMUNITY
CREDIT UNION M.D.
Index No. 809444/2020
LYNNE SMITH
And
ROBERT SMITH
Defendants.
_____________________________________
PLEASE TAKE NOTICE, that pursuant to CPLR Article 31, the testimony, upon oral
examination, of a representative of Plaintiff CORNERSTONE COMMUNITY CREDIT
UNION., will be taken and recorded by stenographic means immediately following the
deposition of Defendants Lynne Smith and Robert Smith, which has been noticed by Defendants
for December 17, 2021 at 2:00pm, at the Law Offices of Ilecki & Ostrowski, LLP, located at 1
Delaware Road, Suite 110, Buffalo, NY 14217. Please take further notice that this representative
shall have personal knowledge with regards to the following issues:
• All facts related to the claims raised in Plaintiff’s complaint;
• All facts related to the alleged agreement dated on or around August 14, 2020;
• All facts related to Defendants’ payment history on said account;
• All facts related to any repossession of the vehicle which was subject to the
August 14, 2020 agreement which may have occurred;
Sincerely,
1 of 2
FILED: ERIE COUNTY CLERK 11/29/2021 11:29 AM INDEX NO. 809444/2020
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 11/29/2021
Dated: November 29, 2021 _/s/Timothy Hiller_______
Timothy Hiller, Esq.
Law Office of Kenneth R. Hiller
Attorneys for Defendant
6000 North Bailey Avenue, Suite 1A
Amherst, New York 14226
(716)564-3288
Email: thiller@kennethhiller.com
To:
William Ilecki
Ilecki & Ostroswki, LLP
Attorneys for Plaintiff
1 Delaware Road, Suite 110
Buffalo, NY 14217
P: 716-838-4300
F: 716-204-9728
2 of 2
Document Filed Date
November 29, 2021
Case Filing Date
August 27, 2020
Category
Other Matters - Consumer Credit (Non-Card) Transaction
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FILED: ERIE COUNTY CLERK 11/29/2021 11:29 AM INDEX NO. 809444/2020 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 11/29/2021 STATE OF NEW YORK SUPREME COURT: COUNTY OF ERIE __________________________________ CORNERSTONE COMMUNITY CREDIT UNITION NOTICE OF EXAMINATION Plaintiff, BEFORE TRIAL DIRECTED TO CORNERSTONE COMMUNITY CREDIT UNION M.D. Index No. 809444/2020 LYNNE SMITH And ROBERT SMITH Defendants. _____________________________________ PLEASE TAKE NOTICE, that pursuant to CPLR Article 31, the testimony, upon oral examination, of a representative of Plaintiff CORNERSTONE COMMUNITY CREDIT UNION., will be taken and recorded by stenographic means immediately following the deposition of Defendants Lynne Smith and Robert Smith, which has been noticed by Defendants for December 17, 2021 at 2:00pm, at the Law Offices of Ilecki & Ostrowski, LLP, located at 1 Delaware Road, Suite 110, Buffalo, NY 14217. Please take further notice that this representative shall have personal knowledge with regards to the following issues: • All facts related to the claims raised in Plaintiff’s complaint; • All facts related to the alleged agreement dated on or around August 14, 2020; • All facts related to Defendants’ payment history on said account; • All facts related to any repossession of the vehicle which was subject to the August 14, 2020 agreement which may have occurred; Sincerely, 1 of 2 FILED: ERIE COUNTY CLERK 11/29/2021 11:29 AM INDEX NO. 809444/2020 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 11/29/2021 Dated: November 29, 2021 _/s/Timothy Hiller_______ Timothy Hiller, Esq. Law Office of Kenneth R. Hiller Attorneys for Defendant 6000 North Bailey Avenue, Suite 1A Amherst, New York 14226 (716)564-3288 Email: thiller@kennethhiller.com To: William Ilecki Ilecki & Ostroswki, LLP Attorneys for Plaintiff 1 Delaware Road, Suite 110 Buffalo, NY 14217 P: 716-838-4300 F: 716-204-9728 2 of 2