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LEVINE & ASSOCIATES, P.C.
ATTORNEYS-AT-LAW
15 Barclay Road
Scarsdale, New York 10583-2707
e-mail: ml@LevLaw.org
Fax (914) 725-4778
Telephone (914) 600-4288
September 12, 2016
Via Fax (845-708-7236)
Katherine Sullivan
Part Clerk to Hon. William A. Kelly
Supreme Court, Rockland County
1 South Main Street, Suite 200
New City, NY 10956
RE: Newman y. Greystone (034478/2015)
Dear Ms. Sullivan:
The undersigned is counsel to the Plaintiff in the above-referenced matter. Subsequent to the filing
of the Complaint herein, the Defendant (through its then-counsel) made a motion for summary
Judgment and commenced a third-party action which generated additional motion and cross-
motion practice. On May 10, 2016, this Court issued an Order denying the summary judgment
motion [NYSCEF Doc. # 97]. On May 17, 2016, Defendant filed a consent to change attorneys
[NYSCEF Doc. # 114]. On July 13, 2016, the parties filed a stipulation withdrawing the Third-
Party Complaint and all then-pending motions and cross-motions. On July 21, 2016, the parties
filed a stipulation providing for the filing of corrected and/or amended pleadings [NYSCEF Doc.
# 123]. On the same date, July 21, 2016, Plaintiff filed a corrected Complaint, and on August 17,
2016, Defendant filed an Amended Answer.
There is presently scheduled a status conference with the Court for tomorrow, September 13"" at
9:30 AM. Counsel for the parties have consulted and have agreed that, given the withdrawal of
the Third-Party Complaint, and the modification to the prior pleadings, that the discovery demands
(and objections thereto) are no longer necessarily relevant to this now-paired down action. As
such, the parties have stipulated (subject to the approval of the Court) to serve new discovery
demands directed at the current pleadings by October 12", with responses to be served by
November 11", and party depositions to be completed by January 12, 2017. A copy of the said
stipulation, which the parties jointly request be So Ordered by the Court, is enclosed.
In view of the above, the parties further request that the status conference scheduled for tomorrow
be adjourned to a date after January 12, 2017, with the parties to advise the Court in the event that
any discovery dispute arises earlier than that. We would appreciate hearing from you as to the
disposition of the request to adjourn tomorrow’s status conference.LEVINE & ASSOCIATES, P.C.
ATTORNEYS-AT-LAW
Katherine Sullivan
Page 2
Thank you for your attention.
Respectfully,
ZO <
MICHAEL LEVINE
ML/la
Encs.
ce Daniel R. Milstein, Esq. (via e-mail)
September 12, 2016SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
we ee eee X
DAVID NEWMAN : Index No. 034478/2015
Plaintiff,
- against - : STIPULATION
GREYSTONE & CO., INC.,
Defendant.
we eee 4
IT IS HEREBY STIPULATED AND AGREED by and between undersigned counsel
for all parties, subject to the approval by the Court, that:
1. Each party will serve amended interrogatories and document demands addressed
to the Verified Corrected Complaint [NYSCEF Doc. # 124] and First Amended Verified Answer
to the Verified Amended Complaint [NYSCEF Doc. # 125] on or before October 12, 2016.
2. Responses to the Amended Interrogatories and Document Demands shall be
served by each party on or before November 11, 2016, and any non-objected to documents that
the parties have been able to locate as of that time will be produced at that time. Complete
production of all non-objected to documents will be made on or before November 30, 2016.
3. The deposition of Plaintiff will take place on December 29, 2016 (or such earlier
date as counsel may agree), commencing at 10:00 A.M. and continuing day-to-day thereafter
until completed. The deposition of Defendant will take place on January 12, 2017 (or such
earlierdate as counsel may agree), commencing at 10:00 A.M. and continuing day-to-day thereafter
until completed.
Dated: September 12, 2016
GREENBERG TRAURIG, LLP LEVINE & ASSOCIATES, P.C.
Yo
By: Z
Daniel R. Milstein, Esq. ichael Levine,
200 Park Avenue 15 Barclay Road
New York, New York 10166 Scarsdale, New York 10583
Telephone (212) 801-9200 Telephone (914) 600-4288
Attorneys for Defendant Attorneys for Plaintiff
PHI 317627081v1 2
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LEVINE & ASSOCIATES, P.C. ATTORNEYS-AT-LAW 15 Barclay Road Scarsdale, New York 10583-2707 e-mail: ml@LevLaw.org Fax (914) 725-4778 Telephone (914) 600-4288 September 12, 2016 Via Fax (845-708-7236) Katherine Sullivan Part Clerk to Hon. William A. Kelly Supreme Court, Rockland County 1 South Main Street, Suite 200 New City, NY 10956 RE: Newman y. Greystone (034478/2015) Dear Ms. Sullivan: The undersigned is counsel to the Plaintiff in the above-referenced matter. Subsequent to the filing of the Complaint herein, the Defendant (through its then-counsel) made a motion for summary Judgment and commenced a third-party action which generated additional motion and cross- motion practice. On May 10, 2016, this Court issued an Order denying the summary judgment motion [NYSCEF Doc. # 97]. On May 17, 2016, Defendant filed a consent to change attorneys [NYSCEF Doc. # 114]. On July 13, 2016, the parties filed a stipulation withdrawing the Third- Party Complaint and all then-pending motions and cross-motions. On July 21, 2016, the parties filed a stipulation providing for the filing of corrected and/or amended pleadings [NYSCEF Doc. # 123]. On the same date, July 21, 2016, Plaintiff filed a corrected Complaint, and on August 17, 2016, Defendant filed an Amended Answer. There is presently scheduled a status conference with the Court for tomorrow, September 13"" at 9:30 AM. Counsel for the parties have consulted and have agreed that, given the withdrawal of the Third-Party Complaint, and the modification to the prior pleadings, that the discovery demands (and objections thereto) are no longer necessarily relevant to this now-paired down action. As such, the parties have stipulated (subject to the approval of the Court) to serve new discovery demands directed at the current pleadings by October 12", with responses to be served by November 11", and party depositions to be completed by January 12, 2017. A copy of the said stipulation, which the parties jointly request be So Ordered by the Court, is enclosed. In view of the above, the parties further request that the status conference scheduled for tomorrow be adjourned to a date after January 12, 2017, with the parties to advise the Court in the event that any discovery dispute arises earlier than that. We would appreciate hearing from you as to the disposition of the request to adjourn tomorrow’s status conference.LEVINE & ASSOCIATES, P.C. ATTORNEYS-AT-LAW Katherine Sullivan Page 2 Thank you for your attention. Respectfully, ZO < MICHAEL LEVINE ML/la Encs. ce Daniel R. Milstein, Esq. (via e-mail) September 12, 2016SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND we ee eee X DAVID NEWMAN : Index No. 034478/2015 Plaintiff, - against - : STIPULATION GREYSTONE & CO., INC., Defendant. we eee 4 IT IS HEREBY STIPULATED AND AGREED by and between undersigned counsel for all parties, subject to the approval by the Court, that: 1. Each party will serve amended interrogatories and document demands addressed to the Verified Corrected Complaint [NYSCEF Doc. # 124] and First Amended Verified Answer to the Verified Amended Complaint [NYSCEF Doc. # 125] on or before October 12, 2016. 2. Responses to the Amended Interrogatories and Document Demands shall be served by each party on or before November 11, 2016, and any non-objected to documents that the parties have been able to locate as of that time will be produced at that time. Complete production of all non-objected to documents will be made on or before November 30, 2016. 3. The deposition of Plaintiff will take place on December 29, 2016 (or such earlier date as counsel may agree), commencing at 10:00 A.M. and continuing day-to-day thereafter until completed. The deposition of Defendant will take place on January 12, 2017 (or such earlierdate as counsel may agree), commencing at 10:00 A.M. and continuing day-to-day thereafter until completed. Dated: September 12, 2016 GREENBERG TRAURIG, LLP LEVINE & ASSOCIATES, P.C. Yo By: Z Daniel R. Milstein, Esq. ichael Levine, 200 Park Avenue 15 Barclay Road New York, New York 10166 Scarsdale, New York 10583 Telephone (212) 801-9200 Telephone (914) 600-4288 Attorneys for Defendant Attorneys for Plaintiff PHI 317627081v1 2