Preview
FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023
SUPREME COURT OF THE STATE OF NEW YORK Index No.: 522833/2023
COUNTY OF KINGS
----------------------------------------------------------------------X PRELIMINARY
ROBERT LYNN, CONFERENCE
REQUEST
Plaintiff,
- against -
555 BROADWAY LLC, JOEJACK BROADWAY LLC,
and TARGET CONSTRUCTION LLC,
Defendants.
______________________________________________________________________Ç
The undersigned requests a Preliminary Conference.
The nature of the action is Personal Injury.
The names, addresses and telephone numbers of all attorneys appearing in the action areas
follows:
LAW OFFICES OF MICHAEL S.
LAMONSOFF, PLLC
Attorneys for Plaintiff
ROBERT LYNN
Financial Square at 32 Old - 8* Floor
Slip
New York, NY 10005
(212) 962-1020
LITCHFIELD CAVO LLP
Attorneys for Defendant(s)
555 BROADWAY LLC
JOEJACK BROADWAY LLC
and TARGET CONSTRUCTION LLC
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
Dated: New York, New York Yours, etc.
November 20, 2023
SH AH AR AZOU LAY
Shahar Azoulay, Esq.
LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC
Attorneys for Plaintiff
ROBERT LYNN
Financial Square at 32 Old - 8* Floor
Slip
1 of 5
FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023
New York, NY 10005
(212) 962-1020
To:
LITCHFIELD CAVO LLP
Attorneysfor Defendant(s)
555 BROADWAY LLC
JOEJACK BROADWAY LLC
and TARGET CONSTRUCTION LLC
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
2 of 5
FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023
SUPREME COURT OF THE STATE OF NEW YORK
CŒUNTY OF KINGS
-------------------------------------------------------------------X
ROBERT LYNN, Index No. 522833/2023
AFFIRMATION OF
-against- GOOD FAITH
555 BROADWAY LLC, JOEJACK BROADWAY LLC,
and TARGET CONSTRUCTION LLC,
Defendant.
______________________________________________________________Ç
SHAHAR AZOULAY, an attorney admitted to practice before the Courts of this State affirms
the truth of the following under the penalty of perjury and pursuant to CPLR Rule 2106 that the following
facts are true:
1. I am the attorney for the plaintiff herein and as such I am fully familiar with the facts and
circumstances of this action based upon a review of the case file and the investigation materialscontained
therein.
2. This affirmation is submitted in connection with the filing of a Request for Judicial
Intervention requesting a Preliminary Conference.
3. This is a negligence action to recover damages for serious permanent injuries sustained by
plaintiff and as a result of an accident which occurred on July 5, 2023.
4. A Summons and Complaint was served on the defendant(s) and issue was joined shortly
thereafter.
WHEREFORE, plaintiff respectfully requests a preliminary conference be scheduled at
the Court's earliest convenience.
Dated: New York, New York Yours, etc.
November 20, 2023
SHAH AR AZOU LAY
Shahar Azoulay, Esq.
LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC
Attorneys for Plaintiff
ROBERT LYNN
Financial Square at 32 Old - 80' Floor
Slip
New York, NY 10005
(212) 962.-1020
3 of 5
FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023
TO:
LITCHFIELD CAVO LLP
Attorneysfor Defendant(s)
555 BROADWAY LLC
JOEJACK BROADWAY LLC
and TARGET CONSTRUCTION LLC
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
4 of 5
FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023
AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
) ss.:
COUNTY OF QUEENS )
James Mihalcik, being duly sworn, deposes and says:
I am over 18 years of age, I am not a party to the action, and I reside in New York County
in the State of New York.
On November 20, 2023 I served a true copy of the annexed REQUEST FOR
PRELIMINARY CONFERENCE AND REQUEST FOR JUDICIAL
INTERVENTION by mailing the same in a sealed envelope, with postage prepaid
thereon, in a post office or official depository of the U.S. Postal Service within the State
of New York, addressed to the last known address of the addressee as indicated below:
TO:
LITCHFIELD CAVO LLP
Attorneys for Defendant(s)
555 BROADWAY LLC
JOEJACK BROADWAY LLC
and TARGET CONSTRUCTION LLC
420 Lexington Avenue, Suite 2104
New York, New York 10170
(212) 434-0100
James Mihalcik
S rn to before me o this
No ember 20, 2023
otary Public
SEKOU F. MARTIN
State of New York ..
Notary Public, +'T
No. 01MA6316003
QuaUfiedin Kings County
Cou
certificate Filed In New York
Cornmission Expires; Dec. 08,
5 of 5
Preview
FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023 SUPREME COURT OF THE STATE OF NEW YORK Index No.: 522833/2023 COUNTY OF KINGS ----------------------------------------------------------------------X PRELIMINARY ROBERT LYNN, CONFERENCE REQUEST Plaintiff, - against - 555 BROADWAY LLC, JOEJACK BROADWAY LLC, and TARGET CONSTRUCTION LLC, Defendants. ______________________________________________________________________Ç The undersigned requests a Preliminary Conference. The nature of the action is Personal Injury. The names, addresses and telephone numbers of all attorneys appearing in the action areas follows: LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC Attorneys for Plaintiff ROBERT LYNN Financial Square at 32 Old - 8* Floor Slip New York, NY 10005 (212) 962-1020 LITCHFIELD CAVO LLP Attorneys for Defendant(s) 555 BROADWAY LLC JOEJACK BROADWAY LLC and TARGET CONSTRUCTION LLC 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 Dated: New York, New York Yours, etc. November 20, 2023 SH AH AR AZOU LAY Shahar Azoulay, Esq. LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC Attorneys for Plaintiff ROBERT LYNN Financial Square at 32 Old - 8* Floor Slip 1 of 5 FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023 New York, NY 10005 (212) 962-1020 To: LITCHFIELD CAVO LLP Attorneysfor Defendant(s) 555 BROADWAY LLC JOEJACK BROADWAY LLC and TARGET CONSTRUCTION LLC 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 2 of 5 FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023 SUPREME COURT OF THE STATE OF NEW YORK CŒUNTY OF KINGS -------------------------------------------------------------------X ROBERT LYNN, Index No. 522833/2023 AFFIRMATION OF -against- GOOD FAITH 555 BROADWAY LLC, JOEJACK BROADWAY LLC, and TARGET CONSTRUCTION LLC, Defendant. ______________________________________________________________Ç SHAHAR AZOULAY, an attorney admitted to practice before the Courts of this State affirms the truth of the following under the penalty of perjury and pursuant to CPLR Rule 2106 that the following facts are true: 1. I am the attorney for the plaintiff herein and as such I am fully familiar with the facts and circumstances of this action based upon a review of the case file and the investigation materialscontained therein. 2. This affirmation is submitted in connection with the filing of a Request for Judicial Intervention requesting a Preliminary Conference. 3. This is a negligence action to recover damages for serious permanent injuries sustained by plaintiff and as a result of an accident which occurred on July 5, 2023. 4. A Summons and Complaint was served on the defendant(s) and issue was joined shortly thereafter. WHEREFORE, plaintiff respectfully requests a preliminary conference be scheduled at the Court's earliest convenience. Dated: New York, New York Yours, etc. November 20, 2023 SHAH AR AZOU LAY Shahar Azoulay, Esq. LAW OFFICES OF MICHAEL S. LAMONSOFF, PLLC Attorneys for Plaintiff ROBERT LYNN Financial Square at 32 Old - 80' Floor Slip New York, NY 10005 (212) 962.-1020 3 of 5 FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023 TO: LITCHFIELD CAVO LLP Attorneysfor Defendant(s) 555 BROADWAY LLC JOEJACK BROADWAY LLC and TARGET CONSTRUCTION LLC 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 4 of 5 FILED: KINGS COUNTY CLERK 11/20/2023 03:28 PM INDEX NO. 522833/2023 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 11/20/2023 AFFIDAVIT OF SERVICE STATE OF NEW YORK ) ) ss.: COUNTY OF QUEENS ) James Mihalcik, being duly sworn, deposes and says: I am over 18 years of age, I am not a party to the action, and I reside in New York County in the State of New York. On November 20, 2023 I served a true copy of the annexed REQUEST FOR PRELIMINARY CONFERENCE AND REQUEST FOR JUDICIAL INTERVENTION by mailing the same in a sealed envelope, with postage prepaid thereon, in a post office or official depository of the U.S. Postal Service within the State of New York, addressed to the last known address of the addressee as indicated below: TO: LITCHFIELD CAVO LLP Attorneys for Defendant(s) 555 BROADWAY LLC JOEJACK BROADWAY LLC and TARGET CONSTRUCTION LLC 420 Lexington Avenue, Suite 2104 New York, New York 10170 (212) 434-0100 James Mihalcik S rn to before me o this No ember 20, 2023 otary Public SEKOU F. MARTIN State of New York .. Notary Public, +'T No. 01MA6316003 QuaUfiedin Kings County Cou certificate Filed In New York Cornmission Expires; Dec. 08, 5 of 5