On May 05, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
National Union Fire Insurance Company Of Pittsburgh, Pa. As Subrogee Of 131 Lexington Avenue, Llc,
and
Falcon Equities, Inc.,
John Doe,
Ta Cenc Inc.,
Ta Genc Inc.,
Ta Tenc Inc.,
for Torts - Other Negligence (Subro Action, Prop Damage)
in the District Court of New York County.
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INDEX NO. 154187/2017
FILED: NEW YORK COUNTY CLERK 11/01/2017 04:40 PM
NYSCEF DOC. NO. 9 RECEIVED NYSCEF 11/01/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
neee poner
ee nee pene eenen nee: “=X
NATIONAL UNION FIRE INSURANCE COMPANY Index: 154187/17
OF PITTSBURGH, PA as subrogee of 131
LEXINGTON AVENUE, LLC
Plaintiff, NOTICE OF MOTION
-against-
TA CENC INC., TA GENC INC., TA TENC INC.,
FALCON EQUITIES, INC. and JOHN DOE, a
Fictitious name for any person or business who was the
Owner and/or managing agent re 132 East 29" Street,
New York, New York, on and before May 19, 2014,
Defendants.
monnennn) xX
COUNSELORS:
PLEASE TAKE NOTICE, that a motion will be made as follows:
MOTION RETURNABLE: November 27, 2017 at 9:30 a.m.
PLACE RETURNABLE: Motion Support Part of the Supreme Court of the State of
New York, County of New York, 60 Centre Street, New
York, NY 10017
SUPPORTING PAPERS: Affirmation of Jennifer L. Coviello, Esq., dated November
1, 2017, annexed exhibits and upon all pleadings and
proceedings had herein.
RELIEF REQUESTED: Order dismissing the plaintiffs’ Summons and Complaint for
failing to provide certain discovery; or in the alternative for
an order precluding the plaintiff from giving any evidence
upon the trial of this action of the claims as to which a Bill
of Particulars was demanded, because of the plaintiff's
failure to serve such Bill of Particulars as required by said
demand in accordance with the Rules of Civil Practice; or in
the alternative compelling the plaintiffs to provide certain
discovery and for such other and further relief as to this
Court may deem just and proper.
1 of 2
INDEX NO. 154187/2017
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/01/2017
PLEASE TAKE FURTHER NOTICE, that, pursuant to CPLR 2214(b), answering
papers, if any, are required to be served at least seven (7) days, prior to the return date hereof.
Dated: New York, NY
November 1, 2017 Yours, etc.
GIALLEONARDO, MCDONALD.
SAFRANEK & TURCHETTI
Attorneys for Defendant
TA CENC INC
One Whitehall Street
New York, NY 10004-2109
Phone: (212) 248-9100
Fax Nos: (212) 510-9257; 92583 259
dah
Matter} 0 17913873
Ae
WN
V4 Y ff
OVIELLO, ESQ.
TO BradleyJ. Corsair, Esq.
THE LAW OFFICES OF LEON R. KOWALSKI
Attorneys for Plaintiff
12 Metrotech Center, 28" Floor
Brooklyn, NY 11201
(718) 250-1100
File No, NYNY-31526
FALCON EQUITIES, INC.
30 East 42™4 Street, Room 1101
New York, NY 10017
2 of 2
Document Filed Date
November 01, 2017
Case Filing Date
May 05, 2017
Category
Torts - Other Negligence (Subro Action, Prop Damage)
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INDEX NO. 154187/2017 FILED: NEW YORK COUNTY CLERK 11/01/2017 04:40 PM NYSCEF DOC. NO. 9 RECEIVED NYSCEF 11/01/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK neee poner ee nee pene eenen nee: “=X NATIONAL UNION FIRE INSURANCE COMPANY Index: 154187/17 OF PITTSBURGH, PA as subrogee of 131 LEXINGTON AVENUE, LLC Plaintiff, NOTICE OF MOTION -against- TA CENC INC., TA GENC INC., TA TENC INC., FALCON EQUITIES, INC. and JOHN DOE, a Fictitious name for any person or business who was the Owner and/or managing agent re 132 East 29" Street, New York, New York, on and before May 19, 2014, Defendants. monnennn) xX COUNSELORS: PLEASE TAKE NOTICE, that a motion will be made as follows: MOTION RETURNABLE: November 27, 2017 at 9:30 a.m. PLACE RETURNABLE: Motion Support Part of the Supreme Court of the State of New York, County of New York, 60 Centre Street, New York, NY 10017 SUPPORTING PAPERS: Affirmation of Jennifer L. Coviello, Esq., dated November 1, 2017, annexed exhibits and upon all pleadings and proceedings had herein. RELIEF REQUESTED: Order dismissing the plaintiffs’ Summons and Complaint for failing to provide certain discovery; or in the alternative for an order precluding the plaintiff from giving any evidence upon the trial of this action of the claims as to which a Bill of Particulars was demanded, because of the plaintiff's failure to serve such Bill of Particulars as required by said demand in accordance with the Rules of Civil Practice; or in the alternative compelling the plaintiffs to provide certain discovery and for such other and further relief as to this Court may deem just and proper. 1 of 2 INDEX NO. 154187/2017 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/01/2017 PLEASE TAKE FURTHER NOTICE, that, pursuant to CPLR 2214(b), answering papers, if any, are required to be served at least seven (7) days, prior to the return date hereof. Dated: New York, NY November 1, 2017 Yours, etc. GIALLEONARDO, MCDONALD. SAFRANEK & TURCHETTI Attorneys for Defendant TA CENC INC One Whitehall Street New York, NY 10004-2109 Phone: (212) 248-9100 Fax Nos: (212) 510-9257; 92583 259 dah Matter} 0 17913873 Ae WN V4 Y ff OVIELLO, ESQ. TO BradleyJ. Corsair, Esq. THE LAW OFFICES OF LEON R. KOWALSKI Attorneys for Plaintiff 12 Metrotech Center, 28" Floor Brooklyn, NY 11201 (718) 250-1100 File No, NYNY-31526 FALCON EQUITIES, INC. 30 East 42™4 Street, Room 1101 New York, NY 10017 2 of 2