On December 31, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Rodney Jackson,
and
New York City Transit Authority,
for Torts - Other (Premises)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 08/18/2020 03:26 PM INDEX NO. 528280/2019
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 08/18/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
__-____________-___-------------------------------------X
RODNEY JACKSON,
Index No.: 528280/2019
Plaintiff,
NOTICE
-against-
OF MOTION
NEW YORK CITY TRANSIT AUTHORITY,
Defendants.
-----------------------------------------------X
MOTION MADE BY: ROSENBAUM & ROSENBAUM, P.C.
Attorneys for Plaintiff
15th
100 Wall Street, F1OOr
New York, New York 10005.
RETURN DATE AND TIME: September 18, 2020 at 9:30 A.M. or as soon thereafter as
counsel can be heard.
PLACE: Supreme Court of the State of New York, Kings County, to
be held at the Courthouse located at 360 Adams Street
Brooklyn, New York
SUPPORTING PAPERS: Affirmation of Andrew G. Meier of ROSENBAUM &
ROSENBAUM, P.C., and Exhibits annexed hereto.
RELIEF REQUESTED: Requesting the Court issue an Order granting Plaintiff's
motion pursuant to CPLR §3126(3) striking the Defendant's
Answer, or in the alternative for an Order precluding the
Defendant from offering testimony at the time of trial, or in
the alternative, for an Order pursuant to CPLR § 3124
compelling Defendants to participate for examinations
before trial together with such further and other relief as the
Court may deems just and proper.
1 of 2
FILED: KINGS COUNTY CLERK 08/18/2020 03:26 PM INDEX NO. 528280/2019
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 08/18/2020
ANSWERING PAPERS: All answering papers, if any, are to be served within seven
(7) days of the return date or adjourned date of this rnotion,
pursuant to CPLR 2214(b).
Dated: New York, New York
August 18, 2020
AndrewŸMeier
Rosenbaum & Rosenbaum, P.C.
Attorney for Plaintiff
15d'
100 Wall Street, Floor
New York, NY 10005
TO:
LAWRENCE HEISLER
Attorneys for Defendant
130 Livingston Street
Brooklyn, New York 11201
718-694-3864
2 of 2
Document Filed Date
August 18, 2020
Case Filing Date
December 31, 2019
Category
Torts - Other (Premises)
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Preview
FILED: KINGS COUNTY CLERK 08/18/2020 03:26 PM INDEX NO. 528280/2019 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 08/18/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS __-____________-___-------------------------------------X RODNEY JACKSON, Index No.: 528280/2019 Plaintiff, NOTICE -against- OF MOTION NEW YORK CITY TRANSIT AUTHORITY, Defendants. -----------------------------------------------X MOTION MADE BY: ROSENBAUM & ROSENBAUM, P.C. Attorneys for Plaintiff 15th 100 Wall Street, F1OOr New York, New York 10005. RETURN DATE AND TIME: September 18, 2020 at 9:30 A.M. or as soon thereafter as counsel can be heard. PLACE: Supreme Court of the State of New York, Kings County, to be held at the Courthouse located at 360 Adams Street Brooklyn, New York SUPPORTING PAPERS: Affirmation of Andrew G. Meier of ROSENBAUM & ROSENBAUM, P.C., and Exhibits annexed hereto. RELIEF REQUESTED: Requesting the Court issue an Order granting Plaintiff's motion pursuant to CPLR §3126(3) striking the Defendant's Answer, or in the alternative for an Order precluding the Defendant from offering testimony at the time of trial, or in the alternative, for an Order pursuant to CPLR § 3124 compelling Defendants to participate for examinations before trial together with such further and other relief as the Court may deems just and proper. 1 of 2 FILED: KINGS COUNTY CLERK 08/18/2020 03:26 PM INDEX NO. 528280/2019 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 08/18/2020 ANSWERING PAPERS: All answering papers, if any, are to be served within seven (7) days of the return date or adjourned date of this rnotion, pursuant to CPLR 2214(b). Dated: New York, New York August 18, 2020 AndrewŸMeier Rosenbaum & Rosenbaum, P.C. Attorney for Plaintiff 15d' 100 Wall Street, Floor New York, NY 10005 TO: LAWRENCE HEISLER Attorneys for Defendant 130 Livingston Street Brooklyn, New York 11201 718-694-3864 2 of 2