Preview
FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 78 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
N O T I C E O F E X AM IN A T I O N B E F O R E T R I A L
C O U N S E L O R S :
PLEASE TAKE NOTICE that pursuant to Article 31 of the CPLR the testimony upon
oral examination of: all parties, as adverse party and witness, will be taken before a Notary
Public who is not an attorney, or employee of an attorney, for any party or prospective party
herein and is not a person who would be disqualified to act as juror because of interest or
because of consanguinity or affinity to any party herein, at the offices of Stradley Ronon Stevens
& Young, LLP located at 100 Park Avenue, Suite 2000, New York, New York 10017 at a date
and time to be mutually agreed upon by the parties with respect to evidence and material
necessary in the prosecution of this action:
All of the relevant facts and circumsteuices in connection with the accident including
negligence, contributory negligence, liability and damages.
# 3766749 v. 2
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FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 78 RECEIVED NYSCEF: 01/02/2019
That said person(s) to be examined are required to produce at such examination the
following:
ANY AND ALL PAPERS, BOOKS AND DOCUMENTS RELATING TO THIS
MATTER.
Dated: January‰ 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@stradlev.coln
TO:
RHE1NGOLD 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. KLE1N & ASSOCIATES
ATTORNEYS FOR DEFENDANTS/CROSS-CLAIMANTS
KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI
CONDOMINIUM, AND WALLACK MANAGEMENT CO., INC.
Carol Morell, Esq.
2
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FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 78 RECEIVED NYSCEF: 01/02/2019
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 04:08 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 78 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 BOARDOF MANAGERSOF KALAHARI
CONDOMINIUM, WALLACK MANAGEMENT
CO., INC., RNC INDUSTRIES, LLC and WEST NEW
YORK RESTORATION OF CT, INC.,
Defendants.
NOTICE OF EXAMINATION BEFORE TRIAL
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
Preview
FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 78 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 N O T I C E O F E X AM IN A T I O N B E F O R E T R I A L C O U N S E L O R S : PLEASE TAKE NOTICE that pursuant to Article 31 of the CPLR the testimony upon oral examination of: all parties, as adverse party and witness, will be taken before a Notary Public who is not an attorney, or employee of an attorney, for any party or prospective party herein and is not a person who would be disqualified to act as juror because of interest or because of consanguinity or affinity to any party herein, at the offices of Stradley Ronon Stevens & Young, LLP located at 100 Park Avenue, Suite 2000, New York, New York 10017 at a date and time to be mutually agreed upon by the parties with respect to evidence and material necessary in the prosecution of this action: All of the relevant facts and circumsteuices in connection with the accident including negligence, contributory negligence, liability and damages. # 3766749 v. 2 1 of 4 FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 78 RECEIVED NYSCEF: 01/02/2019 That said person(s) to be examined are required to produce at such examination the following: ANY AND ALL PAPERS, BOOKS AND DOCUMENTS RELATING TO THIS MATTER. Dated: January‰ 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@stradlev.coln TO: RHE1NGOLD 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. KLE1N & ASSOCIATES ATTORNEYS FOR DEFENDANTS/CROSS-CLAIMANTS KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI CONDOMINIUM, AND WALLACK MANAGEMENT CO., INC. Carol Morell, Esq. 2 # 3766749 v. 2 2 of 4 FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 78 RECEIVED NYSCEF: 01/02/2019 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 04:08 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 78 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 BOARDOF MANAGERSOF KALAHARI CONDOMINIUM, WALLACK MANAGEMENT CO., INC., RNC INDUSTRIES, LLC and WEST NEW YORK RESTORATION OF CT, INC., Defendants. NOTICE OF EXAMINATION BEFORE TRIAL 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