Preview
FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 82 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
NOTICE TO PRODUCE STATEMENT OF
PARTY PURSUANT TO CPLR 66 3101(e) AND 3120
PLEASE TAKE NOTICE that Cross-Claimant-Defendant West New York Restoration
of CT, Inc. hereby demands, pursuant to CPLR Sections 3101(e) and 3120, that its undersigned
attorneys be provided at the offices Stradley Ronon Stevens & Young, LLP, located at 100 Park
Avenue, Suite 2000, New York, New York 10017, with true and accurate copies of all
statements, signed or unsigned, recoded on tape electronically or otherwise, made by Plaintiff or
his/her agents, servants and/or employees, taken by, or on behalf of, or in the possession of, any
of the other parties to this action or their respective attorneys.
PLEASE TAKE FURTHER NOTICE that if there are no such statements, please so
state in a sworn reply to this demand.
PLEASE TAKE FURTHER NOTICE that default in complying with this demand
within thirty (30) days of the date of service hereof will serve as a basis for objection by the
undersigned attorneys to the use of any such statement upon the trial of this action.
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FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 82 RECEIVED NYSCEF: 01/02/2019
PLEASE TAKE FURTHER NOTICE that the above-demands are continuing demands
and all responsive information that is subsequently known or becomes available shall be
furnished to the undersigned in a timely manner.
Dated: January 2, 2019
New York, New York
Yours, etc.,
Scott H. ernstein, 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
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. KLEIN & ASSOCIATES
ATTORNEYS FOR DEFENDANTS/CROSS-CLAIMANTS
KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI
CONDOMINIUM, AND WALLACK MANAGEMENT CO., INC.
Carol Morell, Esq.
200 Madison Avenue, 2nd Floor
New York, New York 10016
DEVITT SPELLMAN BARRETT, LLP
2
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FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 82 RECEIVED NYSCEF: 01/02/2019
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. 82 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.
NOTICE TO PRODUCE STATEMENT OF PARTY
PURSUANT TO CPLR §§ 3101(e) AND 3120
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 attor tiéy
admitted to practice in the courts of New
York State, certif les that, upon information and belief and reasonable inquiry, the contentions estai=ëd
in the annexed document are not frivolous.
Dated: January 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. 82 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 NOTICE TO PRODUCE STATEMENT OF PARTY PURSUANT TO CPLR 66 3101(e) AND 3120 PLEASE TAKE NOTICE that Cross-Claimant-Defendant West New York Restoration of CT, Inc. hereby demands, pursuant to CPLR Sections 3101(e) and 3120, that its undersigned attorneys be provided at the offices Stradley Ronon Stevens & Young, LLP, located at 100 Park Avenue, Suite 2000, New York, New York 10017, with true and accurate copies of all statements, signed or unsigned, recoded on tape electronically or otherwise, made by Plaintiff or his/her agents, servants and/or employees, taken by, or on behalf of, or in the possession of, any of the other parties to this action or their respective attorneys. PLEASE TAKE FURTHER NOTICE that if there are no such statements, please so state in a sworn reply to this demand. PLEASE TAKE FURTHER NOTICE that default in complying with this demand within thirty (30) days of the date of service hereof will serve as a basis for objection by the undersigned attorneys to the use of any such statement upon the trial of this action. # 3766749 v. 2 1 of 4 FILED: NEW YORK COUNTY CLERK 01/02/2019 04:08 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 82 RECEIVED NYSCEF: 01/02/2019 PLEASE TAKE FURTHER NOTICE that the above-demands are continuing demands and all responsive information that is subsequently known or becomes available shall be furnished to the undersigned in a timely manner. Dated: January 2, 2019 New York, New York Yours, etc., Scott H. ernstein, 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 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. KLEIN & ASSOCIATES ATTORNEYS FOR DEFENDANTS/CROSS-CLAIMANTS KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI CONDOMINIUM, AND WALLACK MANAGEMENT CO., INC. Carol Morell, Esq. 200 Madison Avenue, 2nd Floor New York, New York 10016 DEVITT SPELLMAN BARRETT, LLP 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. 82 RECEIVED NYSCEF: 01/02/2019 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. 82 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. NOTICE TO PRODUCE STATEMENT OF PARTY PURSUANT TO CPLR §§ 3101(e) AND 3120 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 attor tiéy admitted to practice in the courts of New York State, certif les that, upon information and belief and reasonable inquiry, the contentions estai=ëd in the annexed document are not frivolous. Dated: January 2019 Signature: Scott H. Bernstein 4 of 4