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 03/05/2020 04:49 PM INDEX NO. 805595/2018
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 03/05/2020
STATE OF NEW YORK
SUPREME COURT: COUNTY OF ERIE
CHARLES FREDRICK,
Plaintiff,
v.
Index No.: 805595/2018
LAUREN BECKSTEIN, and
JOSEPH G. BROWN
Defendants.
NOTICE OF MOTION
Motion made by: The Law Office of Victor M. Wright, attorneys for
the Defendant, Joseph G. Brown.
Date, Time and Place: On March 25, 2020 at 9:30 a.m. before the Honorable
Donna M. Part 29 - Eighth Floor. 50
Siwek, J.S.C.,
Delaware Avenue, Buffalo, New York, 14202.
Supporting Papers: Affirmation of Elizabeth A. Bruce, Esq.. with
attachments thereto.
Relief Sought: Order pursuant to CPLR §§ 3042 and 3124,
precluding plaintiff from giving evidence at trial for
failure to comply with discovery demands. or in the
alternative compelling plaintiff to comply with
discovery demands, together with such other and
further relief as this Court deems just and proper.
Oral Argument: Requested.
Dated: March 5, 2020
Orchard Park, NY
ElizabetlfA. Bruce, isq.
LAW OFFICE OF \ R M. WRIGHT
3815 California Road, Suite Two
Orchard Park, NY 14127-2239
1 of 2
FILED: ERIE COUNTY CLERK 03/05/2020 04:49 PM INDEX NO. 805595/2018
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 03/05/2020
(716) 667-1681
TO: Rafael O. Gomez, Esq.
GOMEZ & BECKER LLP
2746 Delaware Avenue
The Eberhardt Mansion
Buffalo, NY 14217
(716) 873-0333
AFFIRMATION OF SERVICE
I, Elizabeth A. Bruce, Esq., affirm under penalties of perjury that I served 11 lin Motion via
clectronic filing on March 5, 2020.
Eli ab A. Bruc , E q.
2 of 2
Document Filed Date
March 05, 2020
Case Filing Date
April 09, 2018
Category
Torts - Motor Vehicle
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FILED: ERIE COUNTY CLERK 03/05/2020 04:49 PM INDEX NO. 805595/2018 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 03/05/2020 STATE OF NEW YORK SUPREME COURT: COUNTY OF ERIE CHARLES FREDRICK, Plaintiff, v. Index No.: 805595/2018 LAUREN BECKSTEIN, and JOSEPH G. BROWN Defendants. NOTICE OF MOTION Motion made by: The Law Office of Victor M. Wright, attorneys for the Defendant, Joseph G. Brown. Date, Time and Place: On March 25, 2020 at 9:30 a.m. before the Honorable Donna M. Part 29 - Eighth Floor. 50 Siwek, J.S.C., Delaware Avenue, Buffalo, New York, 14202. Supporting Papers: Affirmation of Elizabeth A. Bruce, Esq.. with attachments thereto. Relief Sought: Order pursuant to CPLR §§ 3042 and 3124, precluding plaintiff from giving evidence at trial for failure to comply with discovery demands. or in the alternative compelling plaintiff to comply with discovery demands, together with such other and further relief as this Court deems just and proper. Oral Argument: Requested. Dated: March 5, 2020 Orchard Park, NY ElizabetlfA. Bruce, isq. LAW OFFICE OF \ R M. WRIGHT 3815 California Road, Suite Two Orchard Park, NY 14127-2239 1 of 2 FILED: ERIE COUNTY CLERK 03/05/2020 04:49 PM INDEX NO. 805595/2018 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 03/05/2020 (716) 667-1681 TO: Rafael O. Gomez, Esq. GOMEZ & BECKER LLP 2746 Delaware Avenue The Eberhardt Mansion Buffalo, NY 14217 (716) 873-0333 AFFIRMATION OF SERVICE I, Elizabeth A. Bruce, Esq., affirm under penalties of perjury that I served 11 lin Motion via clectronic filing on March 5, 2020. Eli ab A. Bruc , E q. 2 of 2