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UU U6 06
NYSCEF DOC. NO. 177 RECEIVED NYSGEF: 0872 2/0011
E-FiL
SUPREME COURT OF THE STATE OF NEW. YORK
COUNTY OF SUFFOLK
anennnneee a X
ALBERT PEREZ, individually and derivatively
: Index No.: 96319372013
on behalf of TOTAL COMPUTER SOFTWARE, LLC,
Plaintiff, : SO ORDERED STIPULATION
-against-
VINCENT TEDESCO, TOTAL COMPUTER
SYSTEMS, LTD. d/b/a TOTAL COMPUTER GROUP, :
TOTAL COMPUTER GROUP, LLC, TOTAL
COMPUTERS, LTD. And JOHN DOE
CORPROATION,
Defendants.
— enencennnnee
denominated a Verified
11, 2014, Defendants fil led a document
WHEREAS, on December
forth third-party ¢: laims by Total Computer
Answer, Counterclaims and Third-Party Claims, setting
;
Software, LLC against Albert Perez individually
filed a document denominated a Verified Reply
WHEREAS, on January 23, 2015, Albert Perez Total
and Answer to the Thi rd Party Complaint of
to Counterclaims of Defendant, Vincent Tedesco
Computer Software, LLC;
2017, the Cou rt raised the issue of an unfiled
WHEREAS, at the hearing held on April 27,
Third-Party Summons;
Defendant would file a Third Party Summons,
WHEREAS, counse! agreed on the record that
g suc! h summons retroactive to the date of the filing
and the parti ies would enter into a stipulation makin
Third Party Claims and counsel further agreed that the
of the Verified Answer, Counterclaims and
considered a timely response to the Verified Answer,
previously filed Reply -by Mr. Perez would be
Counterclaims and Third Party Claims;
by counsel to the parties that:
WHEREFORE, it is hereby stipulated ani d agreed
ered filed retroactive to the date of the-fi ling of the
1) The Third Party Summons shall be consid
Verified Answer, Counterclaims and Third-Pa ity Claims;
aims of Defendant, Vincent Tedesco and Answer to the
2) Mr. Perez’s Verified. Reply to Counterc
re, LLC shall be considered timely filed as a
Third Party Complaint of Total Computer Softwa
s ani d Third-Party Claims, retroactive to its
responsive pleading to the Verified Answer, Counterclaim
original date of filing; and
3) The caption of this li tigation shall be modified to read as follows:
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
eannnnncanenancnaeennmwcncensmennaes X
ALBERT PEREZ, individually and derivatively
on behalf of TOTAL COMPUTER SOF TWARE, LLC, : Index No.: 063193/2013
1 of 2
JUN U6 06
NYSCEF DOC. NO. 177 RECEIVED NYSCEF: 06/28/2017
Plaintiff,
-against-
VINCENT TEDESCO, TOTAL COMPUTER
SYSTEMS, LTD. d/b/a TOTAL COMPUTER GROUP, :
TOTAL COMPUTER GROUP, LLC, TOTAL
COMPUTERS, LTD. And JOHN DOE
CORPROATION,
Defendants.
pen ewen enn nenne ne ennnnne nn nnnmnnnneneanne
Index No.
TOTAL COMPUTER SOFTWARE, LLC.
Third-Party Plaintiff,
-against-
ALBERT PEREZ.
Third-Party Defendant.
ceceenenerennne re neeene en ncneenennn eeecennneracnannnmumnenereerns
FARREL Z, PC.
LAW OFFICES OF TIMOTHY MCENANEY
By
AaronjfE.
Attorneys for Plaintiff and Third-Party Attorneys for ‘Defendants and Third-
Defendant Albert Perez Party Plaintiff
400 RXR Plaza
14 Vanderventer Avenue, Suite 250
Uniondale, New York 11556
SN
rt Washington, N V 1050
4
Ay
oly)
RDE best Jone 29th
ARGUILO Dated: twhty 2017
ERR’
4AFF\6528134.1FF\6528134.1
2 of 2
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UU U6 06 NYSCEF DOC. NO. 177 RECEIVED NYSGEF: 0872 2/0011 E-FiL SUPREME COURT OF THE STATE OF NEW. YORK COUNTY OF SUFFOLK anennnneee a X ALBERT PEREZ, individually and derivatively : Index No.: 96319372013 on behalf of TOTAL COMPUTER SOFTWARE, LLC, Plaintiff, : SO ORDERED STIPULATION -against- VINCENT TEDESCO, TOTAL COMPUTER SYSTEMS, LTD. d/b/a TOTAL COMPUTER GROUP, : TOTAL COMPUTER GROUP, LLC, TOTAL COMPUTERS, LTD. And JOHN DOE CORPROATION, Defendants. — enencennnnee denominated a Verified 11, 2014, Defendants fil led a document WHEREAS, on December forth third-party ¢: laims by Total Computer Answer, Counterclaims and Third-Party Claims, setting ; Software, LLC against Albert Perez individually filed a document denominated a Verified Reply WHEREAS, on January 23, 2015, Albert Perez Total and Answer to the Thi rd Party Complaint of to Counterclaims of Defendant, Vincent Tedesco Computer Software, LLC; 2017, the Cou rt raised the issue of an unfiled WHEREAS, at the hearing held on April 27, Third-Party Summons; Defendant would file a Third Party Summons, WHEREAS, counse! agreed on the record that g suc! h summons retroactive to the date of the filing and the parti ies would enter into a stipulation makin Third Party Claims and counsel further agreed that the of the Verified Answer, Counterclaims and considered a timely response to the Verified Answer, previously filed Reply -by Mr. Perez would be Counterclaims and Third Party Claims; by counsel to the parties that: WHEREFORE, it is hereby stipulated ani d agreed ered filed retroactive to the date of the-fi ling of the 1) The Third Party Summons shall be consid Verified Answer, Counterclaims and Third-Pa ity Claims; aims of Defendant, Vincent Tedesco and Answer to the 2) Mr. Perez’s Verified. Reply to Counterc re, LLC shall be considered timely filed as a Third Party Complaint of Total Computer Softwa s ani d Third-Party Claims, retroactive to its responsive pleading to the Verified Answer, Counterclaim original date of filing; and 3) The caption of this li tigation shall be modified to read as follows: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK eannnnncanenancnaeennmwcncensmennaes X ALBERT PEREZ, individually and derivatively on behalf of TOTAL COMPUTER SOF TWARE, LLC, : Index No.: 063193/2013 1 of 2 JUN U6 06 NYSCEF DOC. NO. 177 RECEIVED NYSCEF: 06/28/2017 Plaintiff, -against- VINCENT TEDESCO, TOTAL COMPUTER SYSTEMS, LTD. d/b/a TOTAL COMPUTER GROUP, : TOTAL COMPUTER GROUP, LLC, TOTAL COMPUTERS, LTD. And JOHN DOE CORPROATION, Defendants. pen ewen enn nenne ne ennnnne nn nnnmnnnneneanne Index No. TOTAL COMPUTER SOFTWARE, LLC. Third-Party Plaintiff, -against- ALBERT PEREZ. Third-Party Defendant. ceceenenerennne re neeene en ncneenennn eeecennneracnannnmumnenereerns FARREL Z, PC. LAW OFFICES OF TIMOTHY MCENANEY By AaronjfE. Attorneys for Plaintiff and Third-Party Attorneys for ‘Defendants and Third- Defendant Albert Perez Party Plaintiff 400 RXR Plaza 14 Vanderventer Avenue, Suite 250 Uniondale, New York 11556 SN rt Washington, N V 1050 4 Ay oly) RDE best Jone 29th ARGUILO Dated: twhty 2017 ERR’ 4AFF\6528134.1FF\6528134.1 2 of 2