On December 21, 2012 a
Motion-Secondary
was filed
involving a dispute between
Leib Weiss,
and
Promed Corinthian, Llc,
Stuart M. Weiss,
for Tort
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 0372072015 02:48 PM INL 0 159120/2012©
NYSCEF DOC. NO. 49 i RECEIVED NYSCEF: 03/20/2015
I
File No.: 20652
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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LEIB WEISS,
Plaintiff (s), AFFIRMATION IN
-against- OPPOSITION
STUART M. WEISS AND PROMED CORINTHIAN, Index #: 159120/2012
LLC,
Defendant(s).
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STUART M. WEISS,
Defendant/Third-Party Plaintiff,
-against-
PROMED CORINTHIAN, LLC,
Third-Party Defendant.
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STATE OF NEW YORK)
COUNTY OF NEW YORK) SS.:
Herbert S. Subin, Esq., an attorney duly admitted to practice before the courts of this
State, and associated with the firm of SUBIN ASSOCIATES, LLP, attorneys for the plaintiff,
affirms the following to be true under the penalties of perjury:
That I am associated with the attorney for the plaintiff herein and am familiar with the
facts and circumstances herein, except as to those alleged upon information and belief, and as to
those I verily believe them to be true.
i‘
ThatI submit this affirmation in opposition to defendant/third-party defendant PROMED
CORINTHIAN, LLC’s (“PROMED) motion to dismiss plaintiff's Complaint for failure to
provide outstanding discovery.
The defendant/third-defendant PROMED’s motion should be denied in all respects.
Defendant/third-party defendant PROMED’s motion is moot. Plaintiffs Bill of
Particulars and Combined Response to Discovery and Inspection is annexed hereto as Exhibit
“A”, and being served simultaneously with plaintiffs opposition.
CONCLUSION
For the foregoing reasons, the defendant/third-party defendant PROMED’s motion should
be denied in its entirety.
WHEREFORE, it is respectfully requested that the defendant’s motion be denied in all
respects together with such other and further relief as to this Honorable Court may seem just and
proper.
Dated: New York, New York
March 19, 2015
Herbert S. Subin, Esq.
'
i
Document Filed Date
March 20, 2015
Case Filing Date
December 21, 2012
Status
Disposed, Motion Pending
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