On August 08, 2023 a
Party Discovery
was filed
involving a dispute between
Robert Lynn,
and
555 Broadway Llc,
Joejack Broadway Llc,
Target Construction Llc,
for Torts - Other Negligence (Labor Law)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 11/20/2023 12:57 PM INDEX NO. 522833/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 11/20/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------------------X
ROBERT LYNN, Index No.: 522833/2023
Plaintiff, NOTICE TO TAKE
DEPOSITION UPON
– against – ORAL EXAMINATION
555 BROADWAY LLC, JOEJACK BROADWAY LLC
and TARGET CONSTRUCTION LLC,
Defendants.
-------------------------------------------------------------------------------X
COUNSELORS:
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and
Rules, the testimony, upon oral examination of all parties, as 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 office of LITCHFIELD CAVO LLP located
at 420 Lexington Ave., Suite 2104, New York, New York on February 21, 2024, at 10:00 o’clock
in the forenoon of that day with respect to evidence and material necessary in the defense of this
action.
To the best of my knowledge, information and belief, formed after an inquiry reasonable under
the circumstances, the presentation of this paper of contentions herein are not frivolous, as that
term is defined in Part 130 of the Court Rules.
Dated: New York, New York
November 20, 2023
LITCHFIELD CAVO LLP
By: _____________________________
Dennis J. Dozis
Attorneys for Defendants
555 BROADWAY LLC
1 of 2
FILED: KINGS COUNTY CLERK 11/20/2023 12:57 PM INDEX NO. 522833/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 11/20/2023
JOEJACK BROADWAY LLC
and TARGET CONSTRUCTION LLC
420 Lexington Avenue, Suite 2104
New York, New York 10170
Tel: (212) 434-0100
Fax: (212) 434-0105
File No.: 5458-380D
Email: dozis@litchfieldcavo.com
TO: VIA NYSCEF
Shahar Azoulay, Esq.
LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC
Attorneys for Plaintiff
ROBERT LYNN
32 Old Slip, 8th Floor
New York, New York 10005
Tel: (212) 962-1020
File No.: 35312
Email: sazoulay@msllegal.com
2 of 2
Document Filed Date
November 20, 2023
Case Filing Date
August 08, 2023
Category
Torts - Other Negligence (Labor Law)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: KINGS COUNTY CLERK 11/20/2023 12:57 PM INDEX NO. 522833/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 11/20/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------------------X ROBERT LYNN, Index No.: 522833/2023 Plaintiff, NOTICE TO TAKE DEPOSITION UPON – against – ORAL EXAMINATION 555 BROADWAY LLC, JOEJACK BROADWAY LLC and TARGET CONSTRUCTION LLC, Defendants. -------------------------------------------------------------------------------X COUNSELORS: PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony, upon oral examination of all parties, as 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 office of LITCHFIELD CAVO LLP located at 420 Lexington Ave., Suite 2104, New York, New York on February 21, 2024, at 10:00 o’clock in the forenoon of that day with respect to evidence and material necessary in the defense of this action. To the best of my knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of this paper of contentions herein are not frivolous, as that term is defined in Part 130 of the Court Rules. Dated: New York, New York November 20, 2023 LITCHFIELD CAVO LLP By: _____________________________ Dennis J. Dozis Attorneys for Defendants 555 BROADWAY LLC 1 of 2 FILED: KINGS COUNTY CLERK 11/20/2023 12:57 PM INDEX NO. 522833/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 11/20/2023 JOEJACK BROADWAY LLC and TARGET CONSTRUCTION LLC 420 Lexington Avenue, Suite 2104 New York, New York 10170 Tel: (212) 434-0100 Fax: (212) 434-0105 File No.: 5458-380D Email: dozis@litchfieldcavo.com TO: VIA NYSCEF Shahar Azoulay, Esq. LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC Attorneys for Plaintiff ROBERT LYNN 32 Old Slip, 8th Floor New York, New York 10005 Tel: (212) 962-1020 File No.: 35312 Email: sazoulay@msllegal.com 2 of 2