Preview
FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019
LO327 85101
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
====--=-==-------------------------X
YVETTE McCLAMB Index No.: 154374/2018
Plaintiff,
REPLY TO NOTICE TO
-against- ADMIT
HOUSING PARTNERSHIP DEVELOPLMENT
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.
Defendant.
---------x
C O U N S E L:
PLEASE TAKE NOTICE, defendant, KALAHARI CONDOMIN1UM, THE BOARD
OF MANAGERS OF KALAHARI CONDOMINIUM, and WALLACK MANAGEMENT CO.,
INC. by Margaret G. Klein & Assedates, as attorneys, pursuant to CPLR § 3123 and in REPLY
TO NOTICE TO ADMIT, served by plaintiff, dated January 15, 2019, states as follows, upon
information and belief:
1. The above referciicca defendants admit to the contents of paragraplis 1, 2,3, 4, 5, 6,
7, 8, 9,and 10.
1 of 6
FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019
PLEASE TAKE NOTICE that the defendant, KALAHARI CONDOMINIUM, ,THE
BOARD OF MANAGERS OF KALAHARI CONDOMIN1UM, WALLACK MANAGEMENT
CO., INC. reserve the right to amend and/or supplement theirresponses up to and including the
time of trial.
Dated: New York, New York
February 14, 2019
Yours, etc.
MARGARET G. KLEIN & ASSOCIATES
BY:
CAROL MORELL
Electronic Sigñüturs Pursuant to STL §304(2)
Attorneys for Defendant
2nd
200 Madison Avemie, FlOOr
New York, New York 10016
(646) 392-9250
TO:
STRADLEY RONON STEVENS &
YOUNG, LLP
Attorney For: WEST NEW YORK
RESTORATION OF CT, INC.
100 Park Avenue, Suite 2000
New York, NY 10017
Phone: (212) 812-4124
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FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019
.
RHEINGOLD GIUFFRA RUFFO &
PLOTKIN, LLP
Attorney For: YVETTE McCLAMB
551 Fifth Avenue, 29th Fl.
New York, NY 10176
Phone: (212) 684-1880
DEVITT SPELLMAN BARRETT,
LLP
Attorney For: HOUSING
PARTNERSHIP DEVELOPLMENT
CORPORATION
50 Route 111, Suite 314
Smithtown, NY 11787
Phone: (631) 724-8833
PERRY, VAN ETTEN, ROZANSKI
& PRIMAVERA LLP
Attorney For: RNC INDUSTRIES,
LLC
60 Broad Street, Suite 3600A
New York, NY 10004
Phone: (212) 406-9710
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FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019
LO32785101 VERIFICATION
STATE OF NEW YORK )
) ss:
COUNTY OF NEW YORK )
, being duly sworn, deposes and says that he/she is the
Robert Schenk
Assistant SCCretary of The Ka l a h a ri condnmi n i3nn
, a partynamed in the within entitled action; that he/she has read the
-
foregoiñg REPLY TO NOTICE TO ADMIT and the contents there of, and thatthe same
istrue to his/her own knowledge, except as t the mat s he seves itto be true.
Sworn to before me this
day of Feb , 019
Commissioner ofDeeds
- No.4-6247
CRy of New York
Certificate
RIed in New York County
Term ExpiresJune 1,2‰
NOTARY PUBLIC
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FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019
STATE OF NEW YORK )
) SS.:
COUNTY OF NEW YORK )
I, Sharon L. Joseph, being sworn, says: I am not a party to the action, am over 18 years of
age and reside in the State of New York, County of Queens. On February 19, 2019, I served the
within
REPLY TO NOTICE TO ADMIT
upon:
STRADLEY RONON STEVENS & PERRY, VAN ETTEN, ROZANSKI &
YOUNG, LLP PRIMAVERA LLP
Attorney For Defendant: Attorney For Defendant:
WEST NEW YORK RESTORATION OF RNC INDUSTRIES, LLC
CT, INC. 60 Broad Street, Suite 3600A
100 Park Avenue, Suite 2000 New York, NY 10004
New York, NY 10017 Phone: (212) 406-9710
DEVITT SPELLMAN BARRETT, LLP RHEINGOLD GIUFFRA RUFFO &
Attorney For Defendant: HOUSING PLOTKIN, LLP
PARTNERSHIP DEVELOPLMENT Attorney For Plaintiff:
CORPORATION YVETTE McCLAMB
50 Route 111, Suite 314 551 Fifth Avenue, 29th Fl.
Smithtown, NY 11787 New York, NY 10176
Phone: (631) 724-8833 Phone: (212) 684-1880
being attorneys for the party(ies) named after his/her/their name, by depositing a true copy
thereof in the Branch Post Office Box at 200 Madison Avenue, New York, N. Y. 10016, the
same being one of the regular branch post-office boxes of the General Post Office, enclosed in a
securely sealed wrapper, with the postage thereon prepaid, addressed to said attorney at the
address designated by said attorney in the last papers served by him/her/them herein.
pursuant to Uniform Rule 202.5-b(f)(2)(ii) by e-filing the same to counsel for the parties herein
as detailed above who have consented and are fully participating in the NYSCEF program.
Sharon L. Joseph
Sworn to before me this
February 19, 2019
NOTARY PUBLIC
NANETTE GAROFALO
Notary Public-State of New York
No. 01GA5072812
Qualified irritings County
Commission Expires Feb. 10,
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FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019
Index No.: 154374/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
YVETTE McCLAMB,
Plaintiff,
-against-
HOUSING PARTNERSHIP DEVELOPLMENT 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.
REPLY TO NOTICE TO ADMIT
Law Offices of
MARGARET G. KLEIN & ASSOCIATES
for Defendants
Attorney
KALAHARI CONDOMINIUM, THE BOARD OF
MANAGERS OF KALAHARI CONDOMINIUM,
AND WALLACK MANAGEMENT CO., INC.
Office and Post Office Address
2"d
200 Madison Avenue, Floor
New York, New York 10016
Telephone (646) 392-9250
Fax (212) 779-1499
6 of 6
Preview
FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019 LO327 85101 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ====--=-==-------------------------X YVETTE McCLAMB Index No.: 154374/2018 Plaintiff, REPLY TO NOTICE TO -against- ADMIT HOUSING PARTNERSHIP DEVELOPLMENT 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. Defendant. ---------x C O U N S E L: PLEASE TAKE NOTICE, defendant, KALAHARI CONDOMIN1UM, THE BOARD OF MANAGERS OF KALAHARI CONDOMINIUM, and WALLACK MANAGEMENT CO., INC. by Margaret G. Klein & Assedates, as attorneys, pursuant to CPLR § 3123 and in REPLY TO NOTICE TO ADMIT, served by plaintiff, dated January 15, 2019, states as follows, upon information and belief: 1. The above referciicca defendants admit to the contents of paragraplis 1, 2,3, 4, 5, 6, 7, 8, 9,and 10. 1 of 6 FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019 PLEASE TAKE NOTICE that the defendant, KALAHARI CONDOMINIUM, ,THE BOARD OF MANAGERS OF KALAHARI CONDOMIN1UM, WALLACK MANAGEMENT CO., INC. reserve the right to amend and/or supplement theirresponses up to and including the time of trial. Dated: New York, New York February 14, 2019 Yours, etc. MARGARET G. KLEIN & ASSOCIATES BY: CAROL MORELL Electronic Sigñüturs Pursuant to STL §304(2) Attorneys for Defendant 2nd 200 Madison Avemie, FlOOr New York, New York 10016 (646) 392-9250 TO: STRADLEY RONON STEVENS & YOUNG, LLP Attorney For: WEST NEW YORK RESTORATION OF CT, INC. 100 Park Avenue, Suite 2000 New York, NY 10017 Phone: (212) 812-4124 2 of 6 FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019 . RHEINGOLD GIUFFRA RUFFO & PLOTKIN, LLP Attorney For: YVETTE McCLAMB 551 Fifth Avenue, 29th Fl. New York, NY 10176 Phone: (212) 684-1880 DEVITT SPELLMAN BARRETT, LLP Attorney For: HOUSING PARTNERSHIP DEVELOPLMENT CORPORATION 50 Route 111, Suite 314 Smithtown, NY 11787 Phone: (631) 724-8833 PERRY, VAN ETTEN, ROZANSKI & PRIMAVERA LLP Attorney For: RNC INDUSTRIES, LLC 60 Broad Street, Suite 3600A New York, NY 10004 Phone: (212) 406-9710 3 of 6 FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019 LO32785101 VERIFICATION STATE OF NEW YORK ) ) ss: COUNTY OF NEW YORK ) , being duly sworn, deposes and says that he/she is the Robert Schenk Assistant SCCretary of The Ka l a h a ri condnmi n i3nn , a partynamed in the within entitled action; that he/she has read the - foregoiñg REPLY TO NOTICE TO ADMIT and the contents there of, and thatthe same istrue to his/her own knowledge, except as t the mat s he seves itto be true. Sworn to before me this day of Feb , 019 Commissioner ofDeeds - No.4-6247 CRy of New York Certificate RIed in New York County Term ExpiresJune 1,2‰ NOTARY PUBLIC 4 of 6 FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019 STATE OF NEW YORK ) ) SS.: COUNTY OF NEW YORK ) I, Sharon L. Joseph, being sworn, says: I am not a party to the action, am over 18 years of age and reside in the State of New York, County of Queens. On February 19, 2019, I served the within REPLY TO NOTICE TO ADMIT upon: STRADLEY RONON STEVENS & PERRY, VAN ETTEN, ROZANSKI & YOUNG, LLP PRIMAVERA LLP Attorney For Defendant: Attorney For Defendant: WEST NEW YORK RESTORATION OF RNC INDUSTRIES, LLC CT, INC. 60 Broad Street, Suite 3600A 100 Park Avenue, Suite 2000 New York, NY 10004 New York, NY 10017 Phone: (212) 406-9710 DEVITT SPELLMAN BARRETT, LLP RHEINGOLD GIUFFRA RUFFO & Attorney For Defendant: HOUSING PLOTKIN, LLP PARTNERSHIP DEVELOPLMENT Attorney For Plaintiff: CORPORATION YVETTE McCLAMB 50 Route 111, Suite 314 551 Fifth Avenue, 29th Fl. Smithtown, NY 11787 New York, NY 10176 Phone: (631) 724-8833 Phone: (212) 684-1880 being attorneys for the party(ies) named after his/her/their name, by depositing a true copy thereof in the Branch Post Office Box at 200 Madison Avenue, New York, N. Y. 10016, the same being one of the regular branch post-office boxes of the General Post Office, enclosed in a securely sealed wrapper, with the postage thereon prepaid, addressed to said attorney at the address designated by said attorney in the last papers served by him/her/them herein. pursuant to Uniform Rule 202.5-b(f)(2)(ii) by e-filing the same to counsel for the parties herein as detailed above who have consented and are fully participating in the NYSCEF program. Sharon L. Joseph Sworn to before me this February 19, 2019 NOTARY PUBLIC NANETTE GAROFALO Notary Public-State of New York No. 01GA5072812 Qualified irritings County Commission Expires Feb. 10, 5 of 6 FILED: NEW YORK COUNTY CLERK 02/19/2019 03:29 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 92 RECEIVED NYSCEF: 02/19/2019 Index No.: 154374/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK YVETTE McCLAMB, Plaintiff, -against- HOUSING PARTNERSHIP DEVELOPLMENT 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. REPLY TO NOTICE TO ADMIT Law Offices of MARGARET G. KLEIN & ASSOCIATES for Defendants Attorney KALAHARI CONDOMINIUM, THE BOARD OF MANAGERS OF KALAHARI CONDOMINIUM, AND WALLACK MANAGEMENT CO., INC. Office and Post Office Address 2"d 200 Madison Avenue, Floor New York, New York 10016 Telephone (646) 392-9250 Fax (212) 779-1499 6 of 6