Preview
FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 01/02/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-__________-__ -------------------- ----------X
YVETTE MCCLAMB, Index No. 154374/2018
(ECF)
Plaintiff,
v.
HOUSING PARTNERSHIP DEVELOPMENT
CORPORATION, KALAHARI CONDOMINIUM,
THE BOARD OF MANAGERS OF KALAHARI Assigned Judge: Lynn R. Kotler
CONDOMINIUM, WALLACK MANAGEMENT
CO., INC., RNC INDUSTRIES, LLC and WEST
NEW YORK RESTORATION OF CT, INC.,
Defendants.
---------------- ------------------------------------x
DEMAND FOR EXPERT DISCLOSURE
COUNSELORS:
Cross-Claimeat-Defendant West New York Restoration of CT, Inc. hereby makes
demand upon Plaintiff Yvette McClamb, as follows:
1. State the name and address of every expert retained or employed by you in
anticipation of this litigation, in preparation for trialas a consultant, or whom you expect to call
as a witness at the trial.
2. Identify and state the qualifications of each person whom you expect to call as an
expert witness at trial.
3. State, in reasonable detail, the subject matter upon which the expert is expected to
testify.
4. Provide the substance of the facts and opinions upon which the expert is expected
to testify.
5. Provide a summary of the grounds of each such opinion.
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FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 01/02/2019
witnesses'
6. Provide a brief chronological resume of the education background and
professional background, including the associations or societies of which the expert is a member,
and as to the medical personnel, the names and addresses of allhospitals on whose staffs such
experts are or where such medical experts have courtesy privileges or acts as consultants.
7. State whether each named expert will testify as an expert at the trialof this case.
PLEASE TAKE FURTHER NOTICE, that this demand is further made for you to
supplement your response to this request immediately upon consultation and retention of an
expert witness.
PLEASE TAKE FURTHER NOTICE, that the within is a continuing request. In the
event any of the above items are obtained after service hereof, they are to be immediately
furnished to the undersigned.
PLEASE TAKE FURTHER NOTICE, that upon your failure to produce, identify, state
and provide the aforesaid items within thirty (30) days of service hereof, a motion will be made
for the appropriate relief to the New York State Supreme Court, New York County.
Dated: January 2, 2019
New York, New York
Yours, etc.,
(
Scott H. Bernstein, Esq.
STRADLEY RONON STEVENS & YOUNG, LLP
ATTORNEYS FOR CROSS-CLAIMANT-DEFENDANT,
WEST NEW YORK RESTORATION OF CT, INC.
100 Park Avenue, Suite 2000
New York, New York 10017
Telephone: (212) 812-4132
Facsimile: (646) 682-7180
Sbernstein@stradley.com
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FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 01/02/2019
TO:
RHEINGOLD GIUFFRA RUFFO & PLOTKIN LLP
ATTORNEYS FOR PLAINTIFF YVETTE MCCLAMB
Jeremy A. Hellman, Esq.
551 Fifth Avenue, 29th Floor
New York, New York 10176
PERRY, VAN ETTEN, ROZANSKI & PRIMAVERA, LLP
ATTORNEYS FOR DEFENDANT/CROSS-CLAIMANT
RNC INDUSTRIES, LLC
Kenneth J. Kutner, Esq.
60 Broad Street, Suite 3600A
New York, New York 10004
MARGARET G. KLEIN & ASSOCIATES
ATTORNEYS FOR DEFENDANTS/CROSS-CLAIMANTS
KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI
CONDOMINIUM, AND WALLACK MANAGEMENT CO., 1NC.
Carol Morell, Esq.
200 Madison Avenue, 2nd Floor
New York, New York 10016
DEVITT SPELLMAN BARRETT, LLP
ATTORNEYS FOR DEFENDANT/CROSS-CLAIMANT
HOUSING PARTNERSHIP DEVELOPMENT CORPORATION
Kelly E. Wright, Esq.
50 Route 11, Suite 314
Smithtown, New York 11787
3
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FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 01/02/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Index No. 154374/2018
YVETTE MCCLAMB,
Plaintiff,
-against-
HOUSING PARTNERSHIP DEVELOPMENT
CORPORATION, KALAHARI CONDOMINIUM,
THE BOARD OF MANAGERS OF KALAHARI
CONDOMINIUM, WALLACK MANAGEMENT
CO., INC., RNC INDUSTRIES, LLC and WEST NEW
YORK RESTORATION OF CT, INC.,
Defendants.
DEMAND FOR EXPERT DISCLOSURE
STRADLEY RONON STEVENS & YOUNG, LLP
Attorneys for Defendant
100 Park Avenue, Suite 2000
New York, New York 10017
(212) 812-4124 (telephone)
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New
York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained
in the annexed document are not frivolous.
Dated: January 1 2019 Signature:
Scott H. Bernstein
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Preview
FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 01/02/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -__________-__ -------------------- ----------X YVETTE MCCLAMB, Index No. 154374/2018 (ECF) Plaintiff, v. HOUSING PARTNERSHIP DEVELOPMENT CORPORATION, KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI Assigned Judge: Lynn R. Kotler CONDOMINIUM, WALLACK MANAGEMENT CO., INC., RNC INDUSTRIES, LLC and WEST NEW YORK RESTORATION OF CT, INC., Defendants. ---------------- ------------------------------------x DEMAND FOR EXPERT DISCLOSURE COUNSELORS: Cross-Claimeat-Defendant West New York Restoration of CT, Inc. hereby makes demand upon Plaintiff Yvette McClamb, as follows: 1. State the name and address of every expert retained or employed by you in anticipation of this litigation, in preparation for trialas a consultant, or whom you expect to call as a witness at the trial. 2. Identify and state the qualifications of each person whom you expect to call as an expert witness at trial. 3. State, in reasonable detail, the subject matter upon which the expert is expected to testify. 4. Provide the substance of the facts and opinions upon which the expert is expected to testify. 5. Provide a summary of the grounds of each such opinion. # 3766749 v. 2 1 of 4 FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 01/02/2019 witnesses' 6. Provide a brief chronological resume of the education background and professional background, including the associations or societies of which the expert is a member, and as to the medical personnel, the names and addresses of allhospitals on whose staffs such experts are or where such medical experts have courtesy privileges or acts as consultants. 7. State whether each named expert will testify as an expert at the trialof this case. PLEASE TAKE FURTHER NOTICE, that this demand is further made for you to supplement your response to this request immediately upon consultation and retention of an expert witness. PLEASE TAKE FURTHER NOTICE, that the within is a continuing request. In the event any of the above items are obtained after service hereof, they are to be immediately furnished to the undersigned. PLEASE TAKE FURTHER NOTICE, that upon your failure to produce, identify, state and provide the aforesaid items within thirty (30) days of service hereof, a motion will be made for the appropriate relief to the New York State Supreme Court, New York County. Dated: January 2, 2019 New York, New York Yours, etc., ( Scott H. Bernstein, Esq. STRADLEY RONON STEVENS & YOUNG, LLP ATTORNEYS FOR CROSS-CLAIMANT-DEFENDANT, WEST NEW YORK RESTORATION OF CT, INC. 100 Park Avenue, Suite 2000 New York, New York 10017 Telephone: (212) 812-4132 Facsimile: (646) 682-7180 Sbernstein@stradley.com 2 # 3766749 v. 2 2 of 4 FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 01/02/2019 TO: RHEINGOLD GIUFFRA RUFFO & PLOTKIN LLP ATTORNEYS FOR PLAINTIFF YVETTE MCCLAMB Jeremy A. Hellman, Esq. 551 Fifth Avenue, 29th Floor New York, New York 10176 PERRY, VAN ETTEN, ROZANSKI & PRIMAVERA, LLP ATTORNEYS FOR DEFENDANT/CROSS-CLAIMANT RNC INDUSTRIES, LLC Kenneth J. Kutner, Esq. 60 Broad Street, Suite 3600A New York, New York 10004 MARGARET G. KLEIN & ASSOCIATES ATTORNEYS FOR DEFENDANTS/CROSS-CLAIMANTS KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI CONDOMINIUM, AND WALLACK MANAGEMENT CO., 1NC. Carol Morell, Esq. 200 Madison Avenue, 2nd Floor New York, New York 10016 DEVITT SPELLMAN BARRETT, LLP ATTORNEYS FOR DEFENDANT/CROSS-CLAIMANT HOUSING PARTNERSHIP DEVELOPMENT CORPORATION Kelly E. Wright, Esq. 50 Route 11, Suite 314 Smithtown, New York 11787 3 # 3766749 v. 2 3 of 4 FILED: NEW YORK COUNTY CLERK 01/02/2019 03:57 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 01/02/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No. 154374/2018 YVETTE MCCLAMB, Plaintiff, -against- HOUSING PARTNERSHIP DEVELOPMENT CORPORATION, KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI CONDOMINIUM, WALLACK MANAGEMENT CO., INC., RNC INDUSTRIES, LLC and WEST NEW YORK RESTORATION OF CT, INC., Defendants. DEMAND FOR EXPERT DISCLOSURE STRADLEY RONON STEVENS & YOUNG, LLP Attorneys for Defendant 100 Park Avenue, Suite 2000 New York, New York 10017 (212) 812-4124 (telephone) Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated: January 1 2019 Signature: Scott H. Bernstein 4 of 4