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  • Mildred Villano v. Mutual Redevelopment Houses, Inc., Hercules Corp.Torts - Other Negligence (Premises Liability) document preview
  • Mildred Villano v. Mutual Redevelopment Houses, Inc., Hercules Corp.Torts - Other Negligence (Premises Liability) document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 06/19/2018 12:46 PM INDEX NO. 154224/2017 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 06/19/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK —— ——- ———-- ——-- —— -------------------------------------------------------------------X MILDRED VILLANO, Index No.: 154224/2017-E Plaintiff(s), -against- NOTICE OF MOTION MUTUAL REDEVELOPMENT HOUSES, INC. and HERCULES CORP., Defendant(s). - —- — —- —- —-- ——--- ———- —— — -------------------------------------------------------------------X COUNSELORS: PLEASE TAKE NOTICE that, upon the affirmation of Roy Itzkowitz dated June 15, 2018 and all the pleadings and documentation annexed herewith, a motion will be made at Room 130 at the Courthouse thereof, located at 60 Centre Street, New 10th York, New York 10013 on the day of August 2018 at 9:30 a.m. in the forenoon of that day or as soon thereafter as counsel can be heard, for an Order pursuant to CPLR 3124 precluding defendant Hercules Corp. from offering any evidence at the time of trial any discovery that has not been provided and as for such other and further relief as may be just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to Rule 2214(b) of the CPLR, affidavits, if any, are required to be served at least seven (7) days answering before the return date of this motion. Dated: New York, New York June 15, 2018 1 of 2 FILED: NEW YORK COUNTY CLERK 06/19/2018 12:46 PM INDEX NO. 154224/2017 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 06/19/2018 Yours, etc., Roy Itzkowitz WEISER 2 McCARTHY Attorneys for the Defendant- MUTUAL REDEVELOPMENT HOUSES, INC. 8th 17 State Street, ElOOr New York, New York 10004 212- 943-8940 Our File #: 15-00578421-02 TO: CARTAFALSA, SLATTERY, TURPlN & LENOFF for Defendant- HERCULES CORP. Attorney 4 World Trade Center 52nd 150 Greenwich Street, FlOOr New York, New York 10007 212-225-7700 File No.: 444436 SULLIVAN 4 GALLESHAW, LLP Attorneys for Plaintiff 108-15 Crossbay Blvd. Queens, New York 11417 718-843-0300 2 of 2