Preview
FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
---------X
ISHA MEHTA REQUEST FOR
PRELIMINARY
CONFERENCE
Plaintiff, INDEX NO.: 610460/2020
- against -
RASHEEN T. MACK and MARY T. SMITH,
Defendants.
X
S I R S :
The undersigned requests a Preliminary Conference.
The nature of the action is for personal injuries arising out of an accident or incident which
occurred on 7/26/2019.
The names, addresses and telephone numbers of all attorneys in the action are as
appearing
follows:
TORESCO & SIMONELLI, P.C.
Attorneys for Plaintiff
ISHA MEHTA
361 Union Boulevard
West Islip, New York 11795
(631) 518-6410
Law Offices of Moira Doherty, P.C.
Attorney for Defendant(s)
RASHEEN MACK AND MARY T. SMITH
250 Pehle Avenue, St 800
Saddle Brook, NJ 07663
(718) 495-2579
Dated: West Islip, New York
November 17, 2020
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FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020
Yours c .
By:
Gin Simo li, Esq.
TO S & SIMONELLI, P.C.
Attorneys for Plaintiff
ISHA MEHTA
361 Union Boulevard
West Islip, New York 11795
(631) 518-6410
File No.: 1900090
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FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
------ --··-X
ISHA MEHTA GOOD FAITH AFFIRMATION
Plaintiff, INDEX NO.: 610460/2020
- against -
RASHEEN T. MACK and MARY T. SMITH,
Defendants.
---..-- X
COUNTY OF SUFFOLK} ss.:
Gina M. Sirenelli, an attorney duly admitted to practice before the Courts of the
State of New York, affirms under the penalties of perjury that:
1. I am an associate of the firm of TORESCO & SIMONELLI, P.C., attorneys for the
Plaintiff, ISHA MEHTA, in the above-entitled action, and as such am fully familiar with all the
facts and circumstances surrounding this action.
2. I submit this good faith affirmation in support of the instant request for a
preliminary conference.
3. Plaintiff served and filed a Verified Summons and Complaint in this matter on or
about September 29, 2020. Defendant's interposed an answer on November 17, 2020.
4. A Preliminary Conference is respectfully requested so that the parties may enter
into a binding discovery schedule. It is unlikely discovery can proceed in an expeditious manner
without this Court's intervention.
Dated: West Islip, New York
November 17, 2020
Gina MÏ Si onelli, Esq.
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FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020
AFFIDAVIT OF SERVICE
STATE OF NEW YORK }
COUNTY OF SUFFOLK } ss.:
I, GINA SIMONELLI, being duly sworn, depose and state: That I am not a party to
this action, am over 18 years age, and reside in Babylon, New York.
That on , 2020, I served the within REQUEST FOR PRELIMINARY
CONFERENCE, GOOD FAITH AFFIRMATION and REQUEST FOR JUDICIAL
INTERVENTION upon:
Law Offices of Moira Doherty, P.C.
Attorney for Defendant(s)
RASHEEN MACK AND MARY T. SMITH
250 Pehle Avenue, St 800
Saddle Brook, NJ 07663
(718) 495-2579
the address designated by said party(s) or attorney(s) for that purpose:
[X] by depositing a true copy of the same, enclosed in a post-paid properly addressed wrapper, VIA
FIRST CLASS MAIL, in a post office depository under the exclusive care of the United States
Postal Service within the State of New York.
[ ] by depositing a true copy of the same, enclosed in a post-paid properly addressed CERTIFIED
MAIL/RETURN RECEIPT wrapper, in a post office depository under the exclusive care of the
United States Postal Service within the State of New York.
[ ] by dispatching a copy by overnight delivery via UPS OVERNIGHT MAIL to the parties above
named at the address so indicated.
[ ] by PERSONALLY delivering a truecopy of same to each person above named at the address so
indicated. I knew each person mentioned and described in said papers a party therein;
[ ] by transmitting a true copy of same to the parties above na d by FAX transmission at the
facsimile number so designated by said parties.
Swo n to ore on , 2020
NOTARY C GINA S 1 10 LI
CRISTINA BELLETTI
NOTARY PUBLIC, STATE OF NEW YORK
Registration No. 01BE6329869
Qualified in Nassau
Expires: , Z3
Commission
My
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FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
INDEX NO.: 610460/2020
ISHA MEHTA,
Plaintiff,
- against -
RASHEEN T. MACK and MARY T. SMITH,
Defendants.
REQUEST FOR PRELIMINARY CONFERENCE
GOOD FAITH AFFIRMATION
TORESCO & SIMONELLI, P.C.
Attorneys for Plaintiff
ISHA MEHTA
361 Union Boulevard
West Islip, New York 11795
(631) 518-6410
TO:
Attorney(s) for
ADMISSION OF SERVICE
Service of a copy of the within is hereby
admitted.
Dated: ....................................................................................
Attorney(s) for
NOTICE OF ENTRY
PLEASE TAKE NOTICE that the within is a (certified) true copy of an Order duly entered in the office of the
Clerk of the within named Court on
Dated:
NOTICE OF SETTLEMENT
PLEASE TAKE NOTICE that an Order, of which the within is a true copy, will be presented for settlement to the Hon.
one of the judges of the within named Court in , New York, on
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Preview
FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ---------X ISHA MEHTA REQUEST FOR PRELIMINARY CONFERENCE Plaintiff, INDEX NO.: 610460/2020 - against - RASHEEN T. MACK and MARY T. SMITH, Defendants. X S I R S : The undersigned requests a Preliminary Conference. The nature of the action is for personal injuries arising out of an accident or incident which occurred on 7/26/2019. The names, addresses and telephone numbers of all attorneys in the action are as appearing follows: TORESCO & SIMONELLI, P.C. Attorneys for Plaintiff ISHA MEHTA 361 Union Boulevard West Islip, New York 11795 (631) 518-6410 Law Offices of Moira Doherty, P.C. Attorney for Defendant(s) RASHEEN MACK AND MARY T. SMITH 250 Pehle Avenue, St 800 Saddle Brook, NJ 07663 (718) 495-2579 Dated: West Islip, New York November 17, 2020 1 of 5 FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020 Yours c . By: Gin Simo li, Esq. TO S & SIMONELLI, P.C. Attorneys for Plaintiff ISHA MEHTA 361 Union Boulevard West Islip, New York 11795 (631) 518-6410 File No.: 1900090 2 of 5 FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ------ --··-X ISHA MEHTA GOOD FAITH AFFIRMATION Plaintiff, INDEX NO.: 610460/2020 - against - RASHEEN T. MACK and MARY T. SMITH, Defendants. ---..-- X COUNTY OF SUFFOLK} ss.: Gina M. Sirenelli, an attorney duly admitted to practice before the Courts of the State of New York, affirms under the penalties of perjury that: 1. I am an associate of the firm of TORESCO & SIMONELLI, P.C., attorneys for the Plaintiff, ISHA MEHTA, in the above-entitled action, and as such am fully familiar with all the facts and circumstances surrounding this action. 2. I submit this good faith affirmation in support of the instant request for a preliminary conference. 3. Plaintiff served and filed a Verified Summons and Complaint in this matter on or about September 29, 2020. Defendant's interposed an answer on November 17, 2020. 4. A Preliminary Conference is respectfully requested so that the parties may enter into a binding discovery schedule. It is unlikely discovery can proceed in an expeditious manner without this Court's intervention. Dated: West Islip, New York November 17, 2020 Gina MÏ Si onelli, Esq. 3 of 5 FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020 AFFIDAVIT OF SERVICE STATE OF NEW YORK } COUNTY OF SUFFOLK } ss.: I, GINA SIMONELLI, being duly sworn, depose and state: That I am not a party to this action, am over 18 years age, and reside in Babylon, New York. That on , 2020, I served the within REQUEST FOR PRELIMINARY CONFERENCE, GOOD FAITH AFFIRMATION and REQUEST FOR JUDICIAL INTERVENTION upon: Law Offices of Moira Doherty, P.C. Attorney for Defendant(s) RASHEEN MACK AND MARY T. SMITH 250 Pehle Avenue, St 800 Saddle Brook, NJ 07663 (718) 495-2579 the address designated by said party(s) or attorney(s) for that purpose: [X] by depositing a true copy of the same, enclosed in a post-paid properly addressed wrapper, VIA FIRST CLASS MAIL, in a post office depository under the exclusive care of the United States Postal Service within the State of New York. [ ] by depositing a true copy of the same, enclosed in a post-paid properly addressed CERTIFIED MAIL/RETURN RECEIPT wrapper, in a post office depository under the exclusive care of the United States Postal Service within the State of New York. [ ] by dispatching a copy by overnight delivery via UPS OVERNIGHT MAIL to the parties above named at the address so indicated. [ ] by PERSONALLY delivering a truecopy of same to each person above named at the address so indicated. I knew each person mentioned and described in said papers a party therein; [ ] by transmitting a true copy of same to the parties above na d by FAX transmission at the facsimile number so designated by said parties. Swo n to ore on , 2020 NOTARY C GINA S 1 10 LI CRISTINA BELLETTI NOTARY PUBLIC, STATE OF NEW YORK Registration No. 01BE6329869 Qualified in Nassau Expires: , Z3 Commission My 4 of 5 FILED: NASSAU COUNTY CLERK 11/17/2020 12:34 PM INDEX NO. 610460/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 11/17/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU INDEX NO.: 610460/2020 ISHA MEHTA, Plaintiff, - against - RASHEEN T. MACK and MARY T. SMITH, Defendants. REQUEST FOR PRELIMINARY CONFERENCE GOOD FAITH AFFIRMATION TORESCO & SIMONELLI, P.C. Attorneys for Plaintiff ISHA MEHTA 361 Union Boulevard West Islip, New York 11795 (631) 518-6410 TO: Attorney(s) for ADMISSION OF SERVICE Service of a copy of the within is hereby admitted. Dated: .................................................................................... Attorney(s) for NOTICE OF ENTRY PLEASE TAKE NOTICE that the within is a (certified) true copy of an Order duly entered in the office of the Clerk of the within named Court on Dated: NOTICE OF SETTLEMENT PLEASE TAKE NOTICE that an Order, of which the within is a true copy, will be presented for settlement to the Hon. one of the judges of the within named Court in , New York, on 5 of 5