On April 09, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Charles Fredrick,
and
Joseph G Brown,
Lauren Beckstein,
for Torts - Motor Vehicle
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 08/20/2019 02:17 PM INDEX NO. 805595/2018
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/20/2019
STATE OF NEW YORK : SUPREME COURT
COUNTY OF ERIE
... ...............
NOTICE OF MOTION
CHARLES FREDRICK,
TO PRECLUDE OR COMPEL
Plaintiff
Assigned Justice:
Hon. Donna M. Siwek, JSC
LAUREN BECKSTEIN, JOSEPH G. BROWN,
Index No.: 805595/2018
Defendants.
MOTION MADE BY: Law Office of Daniel R. Archilla, attorneys for
defendant, Lauren Beckstein
DATE, TIME & PLACE: September 5, 2019 at 9:30 am before the
Hon. Donna Siwek, JSC, in Erie County Supreme
Court, 50 Delaware Ave., Part 29, Buffalo, New
York 14202.
SUPPORTING PAPERS: This Notice of Motion, Affirmation of Amy E.
Belmont, Esq., dated August 20, 2019 with Exhibits
attched thereto, and all prior papers and proceedings.
RELIEF DEMANDED: A. An Order pursuant to CPLR §3126
precluding the plaintiff from offering any testimony
in the above captioned matter, or in the alternative an
Order pursuant to CPLR 3042 and 3124 compelling
the plaintiff to amend his Bill of Particulars and
remove all claims related to the left knee and provide
authorizations requested by defendant,
B. For such other and further relief in favor of
the defendants as this Court deems just, proper and
equitable.
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering
affidavits, if any, are to be served upon the indersigned at least seven (7) days before the return of
this motion.
1 of 2
FILED: ERIE COUNTY CLERK 08/20/2019 02:17 PM INDEX NO. 805595/2018
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/20/2019
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering
affidavits, ifany, are to be served upon the undersigned at least seven (7) days before the return
of this motion.
DATED: Buffalo, New York
August 20, 2019
Yours, etc.,
BY: Amy . Be ont, Esq.
Law O ce of Daniel R. Archilla
eys for Defendant
LAUREN BECKSTEIN
170 Franklin Street, Suite 500
Buffalo, New York 14202
(716) 856-0875
TO: Rafael O. Gomez, Esq.
CC: Elizabeth A. Bruce, Esq.
2 of 2
Document Filed Date
August 20, 2019
Case Filing Date
April 09, 2018
Category
Torts - Motor Vehicle
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Preview
FILED: ERIE COUNTY CLERK 08/20/2019 02:17 PM INDEX NO. 805595/2018 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/20/2019 STATE OF NEW YORK : SUPREME COURT COUNTY OF ERIE ... ............... NOTICE OF MOTION CHARLES FREDRICK, TO PRECLUDE OR COMPEL Plaintiff Assigned Justice: Hon. Donna M. Siwek, JSC LAUREN BECKSTEIN, JOSEPH G. BROWN, Index No.: 805595/2018 Defendants. MOTION MADE BY: Law Office of Daniel R. Archilla, attorneys for defendant, Lauren Beckstein DATE, TIME & PLACE: September 5, 2019 at 9:30 am before the Hon. Donna Siwek, JSC, in Erie County Supreme Court, 50 Delaware Ave., Part 29, Buffalo, New York 14202. SUPPORTING PAPERS: This Notice of Motion, Affirmation of Amy E. Belmont, Esq., dated August 20, 2019 with Exhibits attched thereto, and all prior papers and proceedings. RELIEF DEMANDED: A. An Order pursuant to CPLR §3126 precluding the plaintiff from offering any testimony in the above captioned matter, or in the alternative an Order pursuant to CPLR 3042 and 3124 compelling the plaintiff to amend his Bill of Particulars and remove all claims related to the left knee and provide authorizations requested by defendant, B. For such other and further relief in favor of the defendants as this Court deems just, proper and equitable. PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering affidavits, if any, are to be served upon the indersigned at least seven (7) days before the return of this motion. 1 of 2 FILED: ERIE COUNTY CLERK 08/20/2019 02:17 PM INDEX NO. 805595/2018 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/20/2019 PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering affidavits, ifany, are to be served upon the undersigned at least seven (7) days before the return of this motion. DATED: Buffalo, New York August 20, 2019 Yours, etc., BY: Amy . Be ont, Esq. Law O ce of Daniel R. Archilla eys for Defendant LAUREN BECKSTEIN 170 Franklin Street, Suite 500 Buffalo, New York 14202 (716) 856-0875 TO: Rafael O. Gomez, Esq. CC: Elizabeth A. Bruce, Esq. 2 of 2