EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (2024)

Table of Contents
Preview Related Contentin Kings County Case Case Case Case Case Case Case Case Case Ruling Ruling Ruling Ruling Ruling Ruling Ruling Ruling Document Document Document Document Document Document Document Document References

EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (1)

EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (2)

  • EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (3)
  • EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (4)
  • EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (5)
  • EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (6)
  • EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (7)
  • EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (8)
  • EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (9)
  • EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (10)
 
Preview
 FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0001 RECEIVED NYSCEF: 04/23/2024 -EXHIBIT J- -EXHIBIT J-FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0002 RECEIVED NYSCEF: 04/23/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------------X Index No: 500574/2021 DJHIERRY GOUSSE, Plaintiffs, -against- RESPONSE TO COMBINED DEMANDS BEDFORD 2150 LLC, LITTLELEAF PROPERTY MANAGEMENT LLC, HALT MANAGEMENT INC. and ROSEWOOD REALTY GROUP INC., Defendants. ------------------------------------------------------------------------X Defendants BEDFORD 2150 LLC., LITTLELEAF PROPERTY MANAGEMENT LLC and ROSEWOOD REALTY GROUP INC., by its attorneys, MOLOD SPITZ & DeSANTIS, P.C., hereinafter, ("Answering Defendant"), by and through their attorneys, MOLOD, SPITZ & DESANTIS, P.C., hereby respond to Plaintiff's Combined Demands and Notices, dated September 13, 2021, upon information and belief as follows: GENERAL OBJECTIONS 1. These general objections apply to all of the demands, and are made in.addition to the specific objections set forth in more detail below. 2. Answering Defendant objects to these demands to the extent that they call for the production of documents protected from disclosure by the attorney-client privilege or the qualified immunity offered by the work product doctrine. Should any privileged documents be inadvertently produced, Defendant reserves the right to withdraw the documents and assert the privilege. MOLOD SPITZ & DESANTIS, P.C.FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF Exhibit DOC. NO. 65 J bates # 0003 RECEIVED NYSCEF: 04/23/2024 3. Answering Defendant objects to these demands insofar as they call for the production of trial preparation materials or materials prepared in anticipation of litigation. 4. Answering Defendant objects to these demands to the extent they are vague and ambiguous, overly broad, unduly burdensome, duplicative, oppressive, not sufficiently tailored to the issues in this litigation, premature, and/or seek to impose obligations greater than those called for by the New York Civil Practice Law and Rules. 5. Answering Defendant objects to these demands to the extent that they are overly broad, overreaching, ambiguous, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence. 6. Answering Defendant objects to these demands to the extent that they call for the production of documents that contain confidential and/or proprietary information. 7. Answering Defendant objects to these demands to the extent that they are not limited to the relevant time period involved in this litigation and extend significantly prior to and beyond the applicable time period. 8. Answering Defendant objects to these demands to the extent that they call for Defendant to do anything more than conduct a good-faith and reasonable search of all files in which responsive documents are likely to be found. 10. Answering Defendant objects to these demands to the extent that they purport to require Defendant to locate or identify documents that are not within defendant's possession, custody or control. SPECIFIC RESPONSES & OBJECTIONS WITNESSES: Responding Defendants are not presently aware of any witnesses other than any witnesses listed by the plaintiff on his Response to Defendant's Discovery Demands. MOLOD SPITZ & DESANTIS, P.C.FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF Exhibit DOC. NO. 65 J bates # 0004 RECEIVED NYSCEF: 04/23/2024 STATEMENTS: Responding Defendants are not in possession of any party statements. INSURANCE COVERAGE: Defendants refer plaintiff to the following insurance information regarding insurance in effect at the time of plaintiffs alleged accident: Insurer: New York Marine & General Insurance Company Insured: Rosewood Realty Group Limit: $1,000,000.00 per occurrence Policy Number: GL2020F0446130 Policy Period: 4/18/2020 to 4/18/2021 ACCIDENT REPORTS: Responding Defendants are not in possession of any accident reports related to the subject incident. PHOTOSMDEOS: Responding Defendants are not in possession of any photos or videos related to the subject incident, other than those exchanged by the plaintiff. EXPERT WITNESSES: Responding Defendants have not retained an expert witness at the present time. Any and all expert information will be provided in compliance with the CPLR. SURVEILLANCE MATERIALS: Responding Defendants are not in possession of any surveillance materials. BUSINESS REPORTS/RECORDS, REP AIR, SERVICE, INSPECTION RECORDS AND PROPERTY DAMAGE RECORDS: a. Log books: Not applicable. b. Memo books: Not applicable. c. Ledgers/registers: Not applicable. d. Inspection reports, records: None. MoLOD SPITZ & DESANTIS, P.C.FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF Exhibit DOC. NO. 65 J bates # 0005 RECEIVED NYSCEF: 04/23/2024 e. Maintenance reports, records: None. f. Repair reports, records, orders, estimates, bills, receipts: All Repairs with respect to the subject condition were made by the building superintendent. There were no written records of the subject repairs. g. Service reports, records, orders, estimates, bills, receipts: None, see response "f'. h. Painting reports, records, orders, estimates, bills, receipts: None, see response "f'. i. Plastering reports, records, orders, estimates, bills, receipts: None, see response "f'. j. Plumbing reports, records, orders, estimates, bills, receipts: None, see response "f'. k. Work reports, records, orders: None, see response "f'. 1. Written complaints/notice: Responding defendant is not in possession of any written complaints/notice other than what has been provided by counsel for the plaintiff with the Response to Combined Demands, dated September 13, 2021. m. Oral complaints/notice: Responding defendant 1s not in possession of any oral complaints/notice other than what has been provided by counsel for the plaintiff with the Response to Combined Demands, dated September 13, 2021. n. Photographs: Responding defendant is not in possession of any photographs other than what has been provided by counsel for the plai1:1tiff with the Response to Combined Demands, dated September 13, 2021. o. Videos: None. MOLOD SPITZ & DESANTIS, P.C.FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF Exhibit DOC. NO. 65 J bates # 0006 RECEIVED NYSCEF: 04/23/2024 p. Diagrams: None. Defendant reserves its right to supplement this response as further discovery is conducted and additional information is obtained. Dated: New York, New York December 29, 2021 BY: /ltke Sfdt1 Alice Spitz, Esq. MOLOD SPITZ & DeSANTIS, P.C. Attorneys for Defendants BEDFORD 2150 LLC, LITTLELEAF PROPERTY MANAGEMENT LLC and ROSEWOOD REAL TY GROUP INC. 1430 Broadway, 2i'st Floor New York, NY 10018 Tel: (212) 869-3200 . File No.: PSS-713 Email: aspitz@molodspitz.com TO: Ira Gordon, Esq. WESER & WESER, P.C. Attorneys for Plaintiff 1392 Coney Island Avenue Brooklyn, NY 11230 Tel: (718) 338-3000 Email: igordon@weserandweser.com MOLOD SPITZ & DESANTIS, P.C.FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0007 RECEIVED NYSCEF: 04/23/2024 Index No.: 500574/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS DJHIERRY GOUSSE, Plaintiff, -against- BEDFORD 2150 LLC,LITTLELEAF PROPERTYMANAGEMENT LLC, HALT MANAGEMENT INC. and ROSEWOOD REALTY GROUP INC., Defendants. RESPONSE TO COMBINED DEMANDS - ----, ------ .---- .-- .- .- --- .----. --. - .--- .. ' .... .---------- .- .-- .--- -------------------------------------------------------------------------------- ---------. ·. . · MOLOD SPITZ &DeSANTIS, P.C. Attorneysfor Defendants 1430 Broadway, 2ist Floor New York, NY . I 0018-:-3617 Tel: (212) 8.69-3200 Fax: (212) 869-4242 www.molodspitz.com OUR FILE NO. PSS-713 . ---=-=--=====-==- --====--=----=--------------------------FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0008 RECEIVED NYSCEF: 04/23/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------------X Index No: 500574/2021 DJHIERRY GOUSSE, Plaintiffs, -against- AMENDED RESPONSE TO COMBINED DEMANDS BEDFORD 2150 LLC, LITTLELEAF PROPERTY MANAGEMENT LLC, HALT MANAGEMENT INC. and ROSEWOOD REALTY GROUP INC., Defendants. ------------------------------------------------------------------------X Defendants BEDFORD 2150 LLC., LITTLELEAF PROPERTY MANAGEMENT LLC and ROSEWOOD REALTY GROUP INC., by its attorneys, MOLOD SPITZ & DeSANTIS, P.C., hereinafter, ("Answering Defendant"), by and through their attorneys, MOLOD, SPITZ & DESANTIS, P.C., hereby respond to Plaintiff’s Combined Demands and Notices, dated September 13, 2021, upon information and belief as follows: CONDITIONS 1. Production of any document and/or thing in response to these demands is not to be construed as a waiver of any privilege, objection, stipulation of confidentiality, or protection under any protective order. 2. Answering defendants have conducted a good-faith and reasonable search of the files in which responsive documents are likely to be found. 3. Any statement that answering defendants will respond to and any given request by producing documents does not constitute an admission by defendant that it agrees with any characterization or definition contained therein, or that the requested information is likely to leadFILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0009 RECEIVED NYSCEF: 04/23/2024 to the discovery of admissible evidence, or that the requested documents exist. No admission of any nature whatsoever is to be implied by or inferred from any response stated anywhere in this document. 4. Answering defendants reserve the right to modify or supplement its responses to the requests if and when discovery progresses further in this action. 5. Answering defendants reserve all objections that may be available to it, at any hearing or trial or on any motion, to the use or admissibility of any material produced. 6. The production of any material does not constitute an admission by this defendant that such material or the information contained therein is relevant to this action or admissible in evidence. 7. Any failure by answering defendants to make a specific objection to a particular individual request is not, and shall not be construed as, an admission that responsive information exists. Likewise, any statement herein that defendant produces and any information or documents in response to an individual request does not mean that defendant in fact have any such information or documents, or that any such information or documents exist. GENERAL OBJECTIONS 1. These general objections apply to all of the demands and are made in addition to the specific objections set forth in more detail below. 2. Answering defendants object to these demands to the extent that they call for the production of documents protected from disclosure by the attorney-client privilege, or the qualified immunity offered by the work product doctrine. Should any privileged documents be inadvertently produced, defendant reserves the right to withdraw the documents and assert the privilege. 3. Answering defendants object to these demands insofar as they call for theFILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0010 RECEIVED NYSCEF: 04/23/2024 production of trial preparation materials or materials prepared in anticipation of litigation. 4. Answering defendants object to these demands to the extent that they are palpably improper, vague and ambiguous, overly broad, unduly burdensome, duplicative, unlimited in nature, oppressive, not sufficiently tailored to the issues in this litigation, premature, and/or seek to impose obligations greater than those called for by the New York Civil Practice Law and Rules. See, Accent Collections, Inc. v Cappelli Enters., Inc., 84 AD3d 1283 (2d Dept 2011); Harris v Pathmark Stores, Inc., 48 AD3d 631 (2d Dept 2008); In re GENE BARRY ONE HOUR PHOTO PROCESS, INC., 89 AD2d 537 (1st Dept 1982). 5. Answering defendants object to these demands to the extent that they are overly broad, overreaching, ambiguous, lack specificity, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence. See, Accent Collections, Inc. v Cappelli Enters., Inc., 84 AD3d 1283 (2d Dept 2011); Harris v Pathmark Stores, Inc., 48 AD3d 631 (2d Dept 2008); In re GENE BARRY ONE HOUR PHOTO PROCESS, INC., 89 AD2d 537 (1st Dept 1982). 6. Answering defendants object to these demands to the extent that they call for the production of documents that contain confidential and/or proprietary information. 7. Answering defendants object to these demands to the extent that they are not limited to the relevant time period involved in this litigation and extend significantly prior to and beyond the applicable time period. See, Accent Collections, Inc. v Cappelli Enters., Inc., 84 AD3d 1283 (2d Dept 2011); Harris v Pathmark Stores, Inc., 48 AD3d 631 (2d Dept 2008); In re GENE BARRY ONE HOUR PHOTO PROCESS, INC., 89 AD2d 537 (1st Dept 1982). 8. Answering defendants object to these demands to the extent that they seek irrelevant, immaterial and unlimited disclosure. See, Accent Collections, Inc. v Cappelli Enters., Inc., 84 AD3d 1283 (2d Dept 2011); Harris v Pathmark Stores, Inc., 48 AD3d 631 (2d Dept 2008);FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0011 RECEIVED NYSCEF: 04/23/2024 In re GENE BARRY ONE HOUR PHOTO PROCESS, INC., 89 AD2d 537 (1st Dept 1982). 9. Answering defendants object to these demands to the extent that they seek “all” documents set forth in the requests and fail to specify the documents sought with particularity, as this is overly broad, vague, and unduly burdensome. 10. Answering defendants object to these demands to the extent that they call for defendant to do anything more than conduct a good-faith and reasonable search of all files in which responsive documents are likely to be found. 11. Answering defendants object to these demands to the extent that they purport to require defendant to locate or identify documents that are not within defendant’s possession, custody or control. SPECIFIC RESPONSES & OBJECTIONS 1. WITNESSES: Responding Defendants are not presently aware of any witnesses other than any witnesses listed by the plaintiff on his Response to Defendant’s Discovery Demands. 2. STATEMENTS: Responding Defendants are not in possession of any party statements. 3. INSURANCE COVERAGE: To be provided under separate cover in compliance with the Comprehensive Insurance Disclosure Act. 4. ACCIDENT REPORTS: Responding Defendants are not in possession of any accident reports related to the subject incident. 5. PHOTOS/VIDEOS: Please see the annexed photos that were provided by the superintendent, Jesus, of the condition when he first observed it in the subject bathroom after theFILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0012 RECEIVED NYSCEF: 04/23/2024 alleged accident (Exhibit A) and after he made the repair (Exhibit B) taken on his personal cell phone. Original jpegs with metadata are attached via email. He will testify at deposition as to when the photos were taken. a. of the situs of the accident or occurrence (whether taken on the date of the subject accident, prior to the subject accident or after the subject accident); See Exhibits A and B. b. the instrumentality(s) involved (whether taken on the date of the subject accident, prior to the subject accident or after the subject accident); Not applicable. c. the equipment involved (whether taken on the date of the subject accident, prior to the subject accident or after the subject accident); Not applicable. d. the safety devices involved (whether taken on the date of the subject accident, prior to the subject accident or after the subject accident); Not applicable. e. property damaged as a result of the accident or occurrence (whether taken on the date of the subject accident, prior to the subject accident or after the subject accident); None. f. any experiment simulating the accident, or any other relevant condition or circ*mstances existing at the time of the accident; None. g. the physical condition of the plaintiff(s) involved (whether taken on the date of the subject accident, prior to the subject accident or after the subject accident); None. h. true and accurate, full and complete duplicate original COLOR PHOTOGRAPHS depicting or capturing the happening of the subject accident on the date of the subject accident; None. i. true and accurate, full and complete duplicate original COLOR PHOTOGRAHS from cell phones and cameras of agents, servants and employees depicting or capturing the happening of the subject accident on the date of the subject accident; None. j. true and accurate, full and complete duplicate original COLOR PHOTOGRAPHS of the location of the subject accident, taken at or about the time of the occurrence or shortly thereafter; See Exhibits A and B. k. true and accurate, full and complete duplicate original COLOR PHOTOGRAHS from cell phones and cameras of agents, servants and employees of the location of the subject accident, taken at or about the time of the occurrence or shortly thereafter; See Exhibits A and B. l. true and accurate, full and complete duplicate original COLOR PHOTOGRAPHS of the location of the subject accident, taken during the period five (5) years prior to and including the date of the subject accident; None. m. true and accurate, full and complete duplicate original COLOR PHOTOGRAHS from cell phones and cameras of agents, servants and employees of the location of the subject accident, taken during the period five (5) years prior to and including the date of the subject accident; None. n. true and accurate, full and complete duplicate original COLOR PHOTOGRAPHS of the location of the subject accident, taken during the period six (6) months subsequent to and including the date of the subject accident; See Exhibits A and B. o. true and accurate, full and complete duplicate original COLOR PHOTOGRAHS from cell phones and cameras of agents, servants and employees of the location of the subject accident, taken during the period six (6) months subsequent to and including the date of the subject accident; See Exhibits A and B. p. true and accurate, full and complete duplicate original COLOR PHOTOGRAPHS from cellFILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0013 RECEIVED NYSCEF: 04/23/2024 phones and cameras of agents, servants and employees depicting or capturing the plaintiff at the scene of subject accident (or in the vicinity thereof) on the date of subject accident until such time as plaintiff was transported/left from the accident scene; None. q. true and accurate, full and complete duplicate original COLOR PHOTOGAPHS of each and every JOB PHOTOGRAPH and PROGRESS PHOTOGRAPH taken during the inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of the bathroom of Apartment # A4S of the subject premises taken during the period five (5) years prior to and including the date of the subject accident; None. r. true and accurate, full and complete duplicate original COLOR PHOTOGAPHS of each and every JOB PHOTOGRAPH and PROGRESS PHOTOGRAPH from cell phones and cameras of agents, servants and employees taken during the inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of the bathroom of Apartment # A4S of the subject premises taken during the period five (5) years prior to and including the date of the subject accident; None. s. true and accurate, full and complete duplicate original COLOR PHOTOGAPHS of each and every JOB PHOTOGRAPH and PROGRESS PHOTOGRAPH taken during the inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of the bathroom of Apartment # A4S of the subject premises taken during the period six (6) months subsequent to and including the date of subject accident; See Exhibits A and B. t. true and accurate, full and complete duplicate original COLOR PHOTOGAPHS of each and every JOB PHOTOGRAPH and PROGRESS PHOTOGRAPH from cell phones and cameras of agents, servants and employees taken during the inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of the bathroom of Apartment # A4S of the subject premises taken during the period six (6) months subsequent to and including the date of subject accident; See Exhibits A and B. u. true and accurate, full and complete duplicate original COLOR PHOTOGRAPHS of leaks, water damage, ceiling damage, ceiling collapse inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of each Apartment in the line of apartments above Apartment # A4S (i.e. Apartment #s B4S, C4S, D4S, E4S) of the subject premises taken during the period five (5) years prior to and including the date of the subject accident; None. v. true and accurate, full and complete duplicate original COLOR PHOTOGRAPHS from cell phones and cameras of agents, servants and employees of leaks, water damage, ceiling damage, ceiling collapse inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of each Apartment in the line of apartments above Apartment # A4S (i.e. Apartment #s B4S, C4S, D4S, E4S) of the subject premises taken during the period five (5) years prior to and including the date of the subject accident; None. w. true and accurate, full and complete duplicate original VIDEOS depicting or capturing the happening of the subject accident on the date of the subject accident; None. x. true and accurate, full and complete duplicate original VIDEOS from cell phones and video cameras of agents, servants and employees depicting or capturing the happening of the subject accident on the date of the subject accident; None. y. true and accurate, full and complete duplicate original VIDEOS of the location of the subject accident, taken at or about the time of the occurrence or shortly thereafter; None. z. true and accurate, full and complete duplicate original VIDEOS from cell phones and video cameras of agents, servants and employees of the location of the subject accident, taken at or about the time of the occurrence or shortly thereafter; None.FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0014 RECEIVED NYSCEF: 04/23/2024 aa. true and accurate, full and complete duplicate original VIDEOS from cell phones and video cameras of agents, servants and employees depicting or capturing the plaintiff at the scene of subject accident (or in the vicinity thereof) on the date of subject accident until such time as plaintiff was transported from the accident scene; None. bb. true and accurate, full and complete duplicate original VIDEOS of the location of the subject accident, taken during the period five (5) years prior to and including the date of the subject accident; None. cc. true and accurate, full and complete duplicate original VIDEOS from cell phones and video cameras of agents, servants and employees of the location of the subject accident, taken during the period five (5) years prior to and including the date of the subject accident; None. dd. true and accurate, full and complete duplicate original VIDEOS of the location of the subject accident, taken during the period six (6) months subsequent to and including the date of the subject accident; None. ee. true and accurate, full and complete duplicate original VIDEOS from cell phones and video cameras of agents, servants and employees of the location of the subject accident, taken during the period six (6) months subsequent to and including the date of the subject accident; None. ff. true and accurate, full and complete duplicate original VIDEOS of each and every JOB VIDEO and PROGRESS VIDEO taken during the inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of the bathroom of Apartment # A4S of the subject premises taken during the period five (5) years prior to and including the date of the subject accident; None. gg. true and accurate, full and complete duplicate original VIDEOS of each and every JOB VIDEO and PROGRESS VIDEO from cell phones and cameras of agents, servants and employees taken during the inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of the bathroom of Apartment # A4S of the subject premises taken during the period five (5) years prior to and including the date of the subject accident; None. hh. true and accurate, full and complete duplicate original VIDEOS of each and every JOB VIDEO and PROGRESS VIDEO taken during the inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of the bathroom of Apartment # A4S of the subject premises taken during the period six (6) months subsequent to and including the date of subject accident; None. ii. true and accurate, full and complete duplicate original VIDEOS of each and every JOB VIDEO and PROGRESS VIDEO from cell phones and cameras of agents, servants and employees taken during the inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of the bathroom of Apartment # A4S of the subject premises taken during the period six (6) months subsequent to and including the date of subject accident; None. jj. true and accurate, full and complete duplicate original VIDEOS of leaks, water damage, ceiling damage, ceiling collapse inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of each Apartment in the line of apartments above Apartment # A4S (i.e. Apartment #s B4S, C4S, D4S, E4S) of the subject premises taken during the period five (5) years prior to and including the date of the subject accident; None. kk. true and accurate, full and complete duplicate original VIDEOS from cell phones and cameras of agents, servants and employees of leaks, water damage, ceiling, damage, ceiling collapse inspection, maintenance, repair, service, plumbing, sheet rocking and/or plastering of each Apartment in the line of apartments above Apartment # A4S (i.e. Apartment #s B4S, C4S,FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0015 RECEIVED NYSCEF: 04/23/2024 D4S, E4S) of the subject premises taken during the period five (5) years prior to and including the date of the subject accident; None. ll. true and accurate, full and complete duplicate original VIDEOS from the surveillance cameras and surveillance system depicting or capturing the happening of the subject accident on the date of the subject accident; None. mm. true and accurate, full and complete duplicate original VIDEOS from the surveillance cameras and surveillance system depicting or capturing the location of the subject accident on the date of the subject accident, taken during the period 24 hours prior to and including 24 hours subsequent to the date and time of the subject accident; None. nn. true and accurate, full and complete duplicate original VIDEOS from the surveillance cameras and surveillance system depicting or capturing the plaintiff at the scene of subject accident (or in the vicinity thereof) on the date of subject accident until such time as plaintiff was transported from the accident scene; None. i. The name, address, business association, and qualifications of each person(s) who took/made each photograph, movie, film, slide, videotape, image, visual reproduction and/or description. Superintendent Jesus. ii. The date, time and location when each photograph, movie, film, slide, videotape, image, visual reproduction and/or description was taken. All photographs were taken after plaintiff’s alleged accident in the bathroom of the subject apartment. The exact date and time is unknown. iii. The type, make and model number of each camera/device used to take each photograph, movie, film, slide, videotape, image, visual reproduction and/or description. iv. The type of film/media used and the speed at which each photograph, movie, film, slide, videotape, image, visual reproduction and/or description was shot. Phone camera. v. The manner in which each photograph, movie, film, slide, videotape, image, visual reproduction and/or description was developed and by whom each was developed. Not applicable. vi. The manner in which each photograph, movie, film, slide, videotape, image, visual reproduction and/or description was stored and by whom it was stored. Stored on the personal phone of superintendent Jesus. Digital transfer made to counsel and exchanged herein. vii. An affirmation as to the custody of each original photograph, movie, film, slide, videotape, image, visual reproduction and/or description have been maintained/stored from the time that each was taken until the present time. See response to “vi”. viii. The native file of each photograph, movie, film, slide, videotape, image, visual reproduction and/or description, including each file name, file location, file format, file type, file size, file dates that include dates of creation, each date of modification, last modification, each date of access, last access, etc. Annexed with this response. ix. The metadata of each photograph, movie, film, slide, videotape, image, visual reproduction and/or description, including all secondary material. Annexed. 6. EXPERT WITNESSES: Responding Defendants have not retained an expert witness at the present time. Any and all expert information will be provided in compliance with the CPLR.FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0016 RECEIVED NYSCEF: 04/23/2024 7. SURVEILLANCE MATERIALS: Responding Defendants are not in possession of any surveillance materials. 8. BUSINESS REPORTS/RECORDS, REPAIR, SERVICE, INSPECTION RECORDS AND PROPERTY DAMAGE RECORDS: a. Log books: Not applicable. b. Memo books: Not applicable. c. Ledgers/registers: Not applicable. d. Inspection reports, records: None. e. Maintenance reports, records: None. f. Repair reports, records, orders, estimates, bills, receipts: All Repairs with respect to the subject condition were made by the building superintendent. There were no written records of the subject repairs. g. Service reports, records, orders, estimates, bills, receipts: None. h. Painting reports, records, orders, estimates, bills, receipts: None. i. Plastering reports, records, orders, estimates, bills, receipts: None. j. Plumbing reports, records, orders, estimates, bills, receipts: None. k. Work reports, records, orders: None. l. Written complaints/notice: None. m. Oral complaints/notice: None. n. Photographs: Annexed hereto. o. Videos: None. p. Diagrams: None.FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0017 RECEIVED NYSCEF: 04/23/2024 9. PRESERVATION OF EVIDENCE Plaintiff has access to the subject apartment through plaintiff’s aunt and other relatives. Responding defendant will coordinate with plaintiff’s counsel and plaintiff’s relatives to allow a site inspection as requested with all parties present at a mutually convenient date and time. Responding defendants will preserve any and all evidence within its custody and control. Cellphone number (917) 335-3829 is the personal cell phone of the superintendent Jesus. The photographs annexed hereto as Exhibits A and B are from his cell phone. He has been advised to save all information that is on his cell phone regarding this lawsuit. A date can be coordinated for an inspection of the cell phone or it can be done at his deposition. Defendants reserve the right to supplement this response as further discovery is conducted and additional information is obtained. Dated: New York, New York February 17, 2022 BY:Dennis J. Monaco Dennis J. Monaco MOLOD SPITZ & DeSANTIS, P.C. Attorneys for Defendants BEDFORD 2150 LLC, LITTLELEAF PROPERTY MANAGEMENT LLC and ROSEWOOD REALTY GROUP INC. 1430 Broadway, 21st Floor New York, NY 10018 Tel: (212) 869-3200 File No.: PSS-713 Email: dmonaco@molodspitz.com TO: Ira Gordon, Esq. WESER & WESER, P.C. Attorneys for Plaintiff 1392 Coney Island Avenue Brooklyn, NY 11230 Tel: (718) 338-3000 Email: igordon@weserandweser.comFILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0018 RECEIVED NYSCEF: 04/23/2024 Exhibit AFILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0019 RECEIVED NYSCEF: 04/23/2024FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0020 RECEIVED NYSCEF: 04/23/2024FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM ------------------, - 1500574/2021 INDEX NO. .- MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0021 RECEIVED NYSCEF: 04/23/2024 l -,I I I 'FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0022 RECEIVED NYSCEF: 04/23/2024FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0023 RECEIVED NYSCEF: 04/23/2024 Exhibit BFILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0024 RECEIVED NYSCEF: 04/23/2024FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0025 RECEIVED NYSCEF: 04/23/2024FILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0026 RECEIVED NYSCEF: 04/23/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------------------X DJHIERRY GOUSSE, Index #: 500574/2021 Plaintiff(s), RESPONSE TO PLAINTAIFF’S NOTICE -against- FOR DISCOVERY AND INSPECTION BEDFORD 2150 LLC, LITTLELEAF PROPERTY MANAGEMENT LLC, HALT MANAGEMENT INC. and ROSEWOOD REALTY GROUP INC., Defendant(s). ----------------------------------------------------------------------------X Defendants BEDFORD 2150 LLC., LITTLELEAF PROPERTY MANAGEMENT LLC and ROSEWOOD REALTY GROUP INC., by its attorneys, MOLOD SPITZ & DeSANTIS, P.C., hereinafter "Answering Defendant"), by and through their attorneys, MOLOD, SPITZ & DESANTIS, P.C., hereby respond to Plaintiff’s Notice For Discovery and Inspection, dated September 13, 2021, upon information and belief as follows: CONDITIONS 1. Production of any document and/or thing in response to these demands is not to be construed as a waiver of any privilege, objection, stipulation of confidentiality, or protection under any protective order. 2. Answering defendants have conducted a good-faith and reasonable search of the files in which responsive documents are likely to be found. 3. Any statement that answering defendants will respond to and any given request by producing documents does not constitute an admission by defendant that it agrees with any characterization or definition contained therein, or that the requested information is likely to lead to the discovery of admissible evidence, or that the requested documents exist. No admissionFILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0027 RECEIVED NYSCEF: 04/23/2024 of any nature whatsoever is to be implied by or inferred from any response stated anywhere in this document. 4. Answering defendants reserve the right to modify or supplement its responses to the requests if and when discovery progresses further in this action. 5. Answering defendants reserve all objections that may be available to it, at any hearing or trial or on any motion, to the use or admissibility of any material produced. 6. The production of any material does not constitute an admission by this defendant that such material or the information contained therein is relevant to this action or admissible in evidence. 7. Any failure by answering defendants to make a specific objection to a particular individual request is not, and shall not be construed as, an admission that responsive information exists. Likewise, any statement herein that defendant produces and any information or documents in response to an individual request does not mean that defendant in fact have any such information or documents, or that any such information or documents exist. GENERAL OBJECTIONS 1. These general objections apply to all of the demands and are made in addition to the specific objections set forth in more detail below. 2. Answering defendants object to these demands to the extent that they call for the production of documents protected from disclosure by the attorney-client privilege, or the qualified immunity offered by the work product doctrine. Should any privileged documents be inadvertently produced, defendant reserves the right to withdraw the documents and assert the privilege. 3. Answering defendants object to these demands insofar as they call for theFILED: KINGS COUNTY CLERK 04/23/2024 02:39 PM INDEX NO. 500574/2021 MotionNYSCEF DOC. Exhibit NO. 65 J bates # 0028 RECEIVED NYSCEF: 04/23/2024 production of trial preparation materials or materials prepared in anticipation of litigation. 4. Answering defendants object to these demands to the extent that they are palpably improper, vague and ambiguous, overly broad, unduly burdensome, duplicative, unlimited in nature, oppressive, not sufficiently tailored to the issues in this litigation, premature, and/or seek to impose obligations greater than those called for by the New York Civil Practice Law and Rules. See, Accent Collections, Inc. v Cappelli Enters., Inc., 84 AD3d 1283 (2d Dept 2011); Harris v Pathmark Stores, Inc., 48 AD3d 631 (2d Dept 2008); In re GENE BARRY ONE HOUR PHOTO PROCESS, INC., 89 AD2d 537 (1st Dept 1982). 5. Answering defendants object to these demands to the extent that they are overly broad, overreaching, ambiguous, lack specificity, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence. See, Accent Collections, Inc. v Cappelli Enters., Inc., 84 AD3d 1283 (2d Dept 2011); Harris v Pathmark Stores, Inc., 48 AD3d 631 (2d Dept 2008); In re GENE BARRY ONE HOUR PHOTO PROCESS, INC., 89 AD2d 537 (1st Dept 1982). 6. Answering defendants object to these demands to the extent that they call for the production of documents that con

Related Contentin Kings County

Case

Shaqawn Davis v. The City Of New York, New York City Police Department

Aug 16, 2024 |Torts - Other (false arrest) |Torts - Other (false arrest) |522148/2024

Case

OLMO,DANIEL v. OLMO,GAVIEL

Feb 11, 2016 |Johnny Lee |Tort-Motor Vehicle |Tort-Motor Vehicle |10019/2015

Case

Krishanda Ann Padmore v. Frank Harold Santos Jacquez, F H Santosliranzo, V Jaquez-Estevez

Aug 21, 2024 |Torts - Motor Vehicle |Torts - Motor Vehicle |522554/2024

Case

Michael Y. Jacobi v. Jenry I. Martinez, Pci Contracting Inc.

Apr 05, 2024 |Joy Campanelli |Torts - Motor Vehicle |Torts - Motor Vehicle |509772/2024

Case

MICHEL,GUEI v. GULF OIL LIMITED PARTNERSHIP

Dec 05, 2012 |Jury Coordinating Part |Tort-Other Negligence |Tort-Other Negligence |15552/2012

Case

Shokhzod Jurakulov v. City Of New York, New York City Department Of Transportation, Department Of Education Of The City Of New York

Aug 16, 2024 |Torts - Other Negligence (Premises) |Torts - Other Negligence (Premises) |522095/2024

Case

SEABROOK,TIFFANY BEATRICE v. URENA,GIZELL A

Mar 03, 2015 |Jury Coordinating Part |Tort-Motor Vehicle |Tort-Motor Vehicle |16007/2014

Case

LEWIS,RACHEL O. v. SANCHEZ,RUPERTO HUERTA

Jun 08, 2016 |Wooten, Hon. Paul |Tort-Motor Vehicle |Tort-Motor Vehicle |1737/2016

Ruling

OLIVIA CASTANHO, AN INDIVIDUAL VS MAHAMED AHMAD M.A. AL-MARRI, AN INDIVIDUAL, ET AL.

Aug 19, 2024 |Renee C. Reyna |21STCV37827

Case Number: 21STCV37827 Hearing Date: August 19, 2024 Dept: 29 Castanho v. Al-Marri 21STCV37827 Defendants Motion to Compel the Deposition and Production of Documents of Non-Party Witness Ann Holabird Tentative The motion is denied without prejudice. Background On October 12, 2021, Olivia Castanho (Plaintiff) filed a complaint against Mahamed Ahmad M.A. Al-Marri, Avid Budget Group, Inc., Avis Budget Car Rental, LLC, Budget Rent A Car System, Inc., Payless Car Rental, Inc., Budget Truck Rental LLC, Zipcar, Inc., and Does 1 through 50 for motor vehicle negligence and general negligence arising out of an automobile accident occurring on October 28, 2019. On January 12, 2022, Avis Budget Group, Inc., Avis Budget Car Rental, LLC, Budget Rent A Car System, Inc., Payless Car Rental, Inc., Budget Truck Rental, LLC, and Zipcar, Inc. filed an answer. Avis Budget Car Rental, LLC, Budget Rent A Car System, Inc, Payless Car Rental, Inc. and Budget Truck Rental, LLC were dismissed on August 14, 2023. On July 14, 2023, Mahamed Ahmad M.Z. Al-Marri (Defendant) filed an answer. On May 10, 2024, Defendant filed this motion to compel the deposition and production of documents of Non-Party Witness, Ann Holabird. No opposition has been filed. This motion was initially set for hearing on July 11 and continued to August 19. Legal Standard Any party may obtain discovery & by taking in California the oral deposition of any person, including any party to the action. (Code Civ. Proc., § 2025.010.) The process by which a party may obtain discovery from a person who is not a party to the action is through a deposition subpoena. (Code Civ. Proc., § 2020.010, subd. (b).) Personal service of the deposition subpoena on the non-party is required. (Code Civ. Proc., § 2020.220, subd. (b).) A deposition subpoena may command any of the following: (a) Only the attendance and testimony of the deponent &. (b) Only the production of business records for copying &. (c) The attendance and the testimony of the deponent, as well as the production of business records, other documents, electronically stored information, and tangible things. (Code Civ. Proc., § 2020.020.) If a deponent on whom a deposition subpoena has been served fails to attend a deposition or refuses to be sworn as a witness, the court may impose on the deponent the sanctions described in Section 2020.240 [contempt and an action for civil damages under section 1992]. (Code Civ. Proc., § 2025.440, subd. (b).) If a deponent fails to answer any question or to produce any document, electronically stored information, or tangible thing under the deponents control that is specified in the deposition notice or a deposition subpoena, the party seeking discovery may move the court for an order compelling that answer or production. (Code Civ. Proc., § 2025.480, subd. (a).) This motion shall be made no later than 60 days after the completion of the record of the deposition, and shall be accompanied by a meet and confer declaration under Section 2016.040. (Id., subd. (b).) If the court determines that the answer or production sought is subject to discovery, it shall order that the answer be given or the production be made on the resumption of the deposition. (Id., subd. (i).) [T]he court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel an answer or production, unless it finds that the one subject to the sanction acted with substantial justification or that other circ*mstances make the imposition of the sanction unjust. (Id., subd. (j).) A written notice and all moving papers supporting a motion to compel an answer to a deposition question or to compel production of a document or tangible thing from a nonparty deponent must be personally served on the nonparty deponent unless the nonparty deponent agrees to accept service by mail or electronic service at an address or electronic service address specified on the deposition record. (Cal. Rules of Court, rule 3.1346.) Discussion Defendant seeks to compel the deposition and production of documents of Non-Party Witness, Ann Holabird (Holabird). Holabird did not appear for her deposition on March 1, 2024; Holabird alerted Defendant that she did not have a signed authorization from Plaintiff as Plaintiffs treating therapist, and thus would not appear for deposition. (Caponegri Decl., ¶¶ 4-6.) Holabird was personally served with the deposition subpoena on February 13, 2024. (Exh. C.) Holabird was not, however, personally served with this motion. (See Supp. Caponegri Decl., ¶¶ 2-5.) That is required by California Rules of Court, rule 3.1346. Absent such service on the non-party, the Court cannot grant the motion. Therefore, the Court DENIES without prejudice Defendants motion to compel the personal appearance and production of documents of Ann Holabird. Conclusion The Court DENIES without prejudice Defendants motion to compel the personal appearance and production of documents from Ann Holabird. Moving party to give notice.

Ruling

PROGRESSIVE WEST INSURANCE COMPANY VS REGINA STIBLEY, ET AL.

Aug 21, 2024 |22STCV38200

Case Number: 22STCV38200 Hearing Date: August 21, 2024 Dept: 28 Having considered the documents submitted in support of the request for default judgment, the Court rules as follows. BACKGROUND On December 7, 2022, Plaintiff Progressive West Insurance Company (Plaintiff) filed this action against Defendants Regina Stibley (Stibley), Edwin Brown (Brown), and Does 1-20 for motor vehicle tort and subrogation under California Insurance Code section 11580.2, subdivision (g). The complaint demanded $59,064.98. On January 17, 2023, Plaintiff filed a proof of service showing substituted service of the summons, complaint, statement of damages, and other documents on Stibley on January 9, 2023. On February 2, 2023, the Court dismissed Brown without prejudice at Plaintiffs request. On May 20, 2024, the Court dismissed the Doe defendants without prejudice at Plaintiffs request. On May 17, 2024, the clerk entered Stibleys default. Also on May 17, 2024, Plaintiff filed a request for Court judgment. PARTYS REQUEST Plaintiff Progressive West Insurance Company asks the Court to enter a default judgment against Defendant Regina Stibley and award Plaintiff $59,583.98, consisting of $59,064.98 as the demand of the complaint and $519.00 in costs. LEGAL STANDARD A. Default judgment [With exceptions that do not apply here,] [a] party seeking a default judgment on declarations must use mandatory Request for Entry of Default (Application to Enter Default) (form CIV-100) . . . The following must be included in the documents filed with the clerk: (1) Except in unlawful detainer cases, a brief summary of the case identifying the parties and the nature of plaintiff's claim; (2) Declarations or other admissible evidence in support of the judgment requested; (3) Interest computations as necessary; (4) A memorandum of costs and disbursem*nts; (5) A declaration of nonmilitary status for each defendant against whom judgment is sought; (6) A proposed form of judgment; (7) A dismissal of all parties against whom judgment is not sought or an application for separate judgment against specified parties under Code of Civil Procedure section 579, supported by a showing of grounds for each judgment; (8) Exhibits as necessary; and (9) A request for attorney fees if allowed by statute or by the agreement of the parties. (Cal. Rules of Court, rule 3.1800(a).) B. Damages On a request for default judgment, [w]here a cause of action is stated in the complaint, plaintiff merely needs to introduce evidence establishing a prima facie case for damages. (L. Edmon & C. Karnow, Cal. Practice Guide: Civil Procedure Before Trial (Rutter 2023) ¶ 5:213.1, p. 5-56 (Cal. Practice Guide), citing Johnson v. Stanhiser (1999) 72 Cal.App.4th 357, 361 [trial court erred in applying preponderance of the evidence standard].) The relief granted to a plaintiff upon entry of a defendant's default cannot exceed the amount demanded in the complaint or, for personal injury cases where damages may not be stated in the complaint, the amount listed in the statement of damages. (Code Civ. Proc., §§ 580, subd. (a), 585, subd. (b).) The notice requirement of section 580 was designed to insure fundamental fairness. (Becker v. S.P.V. Construction Co. (1980) 27 Cal.3d 489, 494.) The statute insures that defendants in cases which involve a default judgment have adequate notice of the judgments that may be taken against them. [Citation.] If a judgment other than that which is demanded is taken against him, [the defendant] has been deprived of his day in courta right to a hearing on the matter adjudicated. (Id. at p. 493.) A trial court exceeds its jurisdiction if it awards damages in excess of the amount specified in the complaint or statement of damages. (Id. at p. 494.) DISCUSSION Plaintiff has submitted a complete default judgment application with all required information. The Court grants the application. CONCLUSION The Court GRANTS Plaintiff Progressive West Insurance Companys application for default judgment against Defendant Regina Stibley filed on May 17, 2024. The Court awards Plaintiff Progressive West Insurance Company $59,583.98 against Defendant Regina Stibley. Plaintiff is ordered to give notice of this ruling.

Ruling

MARTA VELASCO VS NUESTRA SENORA DE GUADALUPE, INC.

Aug 20, 2024 |Renee C. Reyna |21STCV35122

Case Number: 21STCV35122 Hearing Date: August 20, 2024 Dept: 29 Velasco v. Nuestra Senora de Guadalupe, Inc. 21STCV35122 Plaintiffs Motion to Set Aside Dismissal Tentative The motion is granted. Background On September 22, 2021 Plaintiff Marta Velasco (Plaintiff) filed a complaint against Nuestra Senora De Guadalupe, Inc. (Defendant) and Does 1 to 30 for premises liability and general negligence arising out of a fall on September 26, 2019. Default was entered against Defendant on June 5, 2023. On November 29, 2023, Plaintiff amended the complaint to correct the name of Defendant. The correct name is Our Lady of Guadalupe Church. On February 13, 2024, Plaintiff did not appear at an OSC re Dismissal. Plaintiffs complaint was dismissed without prejudice. On June 11, 2024, Plaintiff filed this motion to set aside the dismissal. No opposition has been filed. This motion was initially scheduled for July 24 and continued to August 20. Legal Standard Code of Civil Procedure section 473, subdivision (b) provides for both discretionary and mandatory relief from dismissal. As to discretionary relief, the statute states: The court may, upon any terms as may be just, relieve a party or his or her legal representative from a judgment, dismissal, order, or other proceeding taken against him through his or her mistake, inadvertence, surprise, or excusable neglect. (Code of Civil Procedure § 473, subd. (b).) Where such an application for discretionary relief is made, the motion must be accompanied by a copy of the answer or pleading proposed to be filed; otherwise the application shall not be granted. (Ibid.) The application for relief must be made within a reasonable time, and in no case exceeding six months after the judgment. (Ibid.) The statute also provides for mandatory relief from dismissal, default, or default judgment: whenever an application for relief is made no more than six months after entry of judgment, is in proper form, and is accompanied by an attorneys sworn affidavit attesting to his or her mistake, inadvertence, surprise, or neglect & unless the court finds that the default or dismissal was not in fact caused by the attorneys mistake, inadvertence, surprise, or neglect. (Ibid.) Discussion Plaintiff seeks to have the dismissal of her complaint set aside. Plaintiffs counsel Dean Hakkak states that he failed to appear at the OSC hearing on February 13, 2024, because of an inadvertent scheduling mistake. (Hakkak Decl., ¶¶ 5-6.) The Court finds that the dismissal was entered as a result of counsels mistake, inadvertence, surprise, or neglect. Accordingly, the motion is granted. Pursuant to Code of Civil Procedure section 473, subdivision (c)(1)(B), the Court ORDERS counsel of record Dean Hakkak to pay $150 to the State Bar Client Security Fund, and to file proof of payment with the Court by no later than September 20, 2024. Conclusion Plaintiffs motion to set aside the dismissal is GRANTED. The Court SETS ASIDE the dismissal order entered on February 13, 2024. The Court SETS a hearing in approximately 60 days on an Order to Show Cause re Dismissal for failure to obtain entry of default against the Defendant or, in the alternative, a Trial Setting Conference. The Court SETS a hearing in approximately 60 days on an Order to Show Cause re proof of payment by counsel of record Dean Hakkak of the amount of $150 to the State Bar Client Security Fund. Moving party to give notice.

See Also
9 WiscNews-area girls volleyball players to watch in 2024

Ruling

MINA BOKTOR VS RETZEL GLENN HILL, ET AL.

Aug 21, 2024 |Renee C. Reyna |22STCV32473

Case Number: 22STCV32473 Hearing Date: August 21, 2024 Dept: 29 Boktor v. Hill 22STCV32473 Defendants Motion to Compel Deposition of Plaintiff Tentative The motion is granted. The request for sanctions is granted in part. Background On October 4, 2022, Mina Boktor (Plaintiff) filed a complaint against Retzel Glenn Hill, Specialized Services Transportation Inc. (collectively Defendants), and Does 1 through 50 for negligence arising out of an automobile accident occurring on November 12, 2020. Defendants filed their answers on November 9 and 16, 2023. On July 24, 2024, Defendants filed this motion to compel the deposition of Plaintiff. Defendants also seek sanctions. On August 12, 2024, Plaintiffs counsel filed a document labelled a declaration of non-opposition. In the non-opposition, Plaintiff consents to the order compelling the deposition but opposes Defendants request for sanctions, arguing that Defendants did not properly meet and confer and did not schedule and complete an Informal Discovery Conference (IDC). The Court notes that this non-opposition, which is in fact an opposition to the sanctions request, was not timely filed. Defendants filed a reply on August 14. Legal Standard Any party may obtain discovery & by taking in California the oral deposition of any person, including any party to the action. (Code Civ. Proc., § 2025.010.) Code of Civil Procedure sections 2025.210 through 2025.280 provide the requirements for (among other things) what must be included in a deposition notice, when and where depositions may be taken, and how and when the notice must be served. The service of a deposition notice & is effective to require any deponent who is a party to the action or an officer, director, managing agent, or employee of a party to attend and to testify, as well as to produce any document, electronically stored information, or tangible thing for inspection and copying. (Id., § 2025.280, subd. (a).) Section 2025.230 provides: If the deponent named is not a natural person, the deposition notice shall describe with reasonable particularity the matters on which examination is requested. In that event, the deponent shall designate and produce at the deposition those of its officers, directors, managing agents, employees, or agents who are most qualified to testify on its behalf as to those matters to the extent of any information known or reasonably available to the deponent. Section 2025.410, subdivision (a), requires any party to serve a written objection at least three days before the deposition if the party contends that a deposition notice does not comply with the provisions of sections 2025.210 through 2025.280. Section 2025.450, subdivision (a), provides: If, after service of a deposition notice, a party to the action or an officer, director, managing agent, or employee of a party, or a person designated by an organization that is a party under Section 2025.230, without having served a valid objection under Section 2025.410, fails to appear for examination, or to proceed with it, or to produce for¿inspection any document, electronically stored information, or tangible thing described in the deposition notice, the party giving the notice may move for an order compelling the deponents attendance and testimony, and the production for inspection of any document, electronically stored information, or tangible thing described in the deposition notice. Any such motion to compel must show good cause for the production of documents and, when a deponent has failed to appear, the motion must be accompanied by a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. (Id., subd. (b).) When a motion to compel is granted, the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) in favor of the party who noticed the deposition and against the deponent or the party with whom the deponent is affiliated, unless the court finds that the one subject to the sanction acted with substantial justification or that other circ*mstances make the imposition of the sanction unjust. (Id., § 2025.450, subd. (g)(1).) In Chapter 7 of the Civil Discovery Act, section 2023.010, subdivision (d), defines [m]isuses of the discovery process to include [f]ailing to respond to or to submit to an authorized method of discovery. Where a party or attorney has engaged in misuse of the discovery process, the court may impose a monetary sanction in the amount of the reasonable expenses, including attorneys fees, incurred by anyone as a result of that conduct. (Id., § 2023.030, subd. (a).) Discussion Defendants noticed Plaintiffs deposition for April 17, 2024. (Glass Decl., ¶ 2 & Exh. A.) Plaintiff objected on the grounds that counsel was not contacted regarding the date and that the deposition should be conducted remotely rather than in person. (Id., ¶ 3 & Exh. B.) Defendants reached out to Plaintiff regarding scheduling, but Plaintiff did not respond. (Id., ¶¶ 4-5 & Exhs. C-D.) Defendants then noticed Plaintiffs deposition for June 18, 2024. (Id., ¶ 6 & Exh. E.) Plaintiff did not object but emailed Plaintiffs counsel at 4:39 p.m. on June 17 stating that the deposition could not go forward due to a scheduling conflict. (Id., ¶¶ 7-8 & Exhs. F-G.) Plaintiff did not appear, and Defendants took a certificate of non-appearance. (Id., ¶ 17 & Exh. O.) Counsel then discussed new dates for the deposition and settled on July 24. (Id., ¶¶ 9-10 & Exhs. H-I.) But counsel disagreed as to whether the deposition should be taken in the office of Plaintiffs counsel or Defendants counsel. (Id., ¶¶ 11-12, 14 & Exhs. J-K, M) Defendants noticed Plaintiffs deposition for July 24, at the offices of Defendants counsel. (Id., ¶ 13 & Exh. L.) Plaintiff objected on the grounds that counsel was not contacted regarding the date and that the deposition should be conducted remotely rather than in person. (Id., ¶ 15 & Exh. N.) The Court finds that Defendants have satisfied all substantive and procedural requirements in connection with their motion. Defendants noticed a deposition for June 18, 2024. Plaintiff did not object and did not appear. Defendants inquired about the nonappearance but the parties have not been able to resolve their disagreements about deposition scheduling. The Court exercises its discretion to consider Plaintiffs opposition to the motion, which Plaintiff labels as a non-opposition. First, Plaintiff contends that Defendants did not meet and confer adequately. The Court has reviewed the record and finds that there was no failure to meet and confer. Moreover, in connection with a motion under Code of Civil Procedure section 2025.450, it is sufficient for the moving party to inquire about the nonappearance, which Defendants plainly did. Second, Plaintiff contends that Defendants did not satisfy the requirement for an IDC. Under the Eighth Amended Standing Order for Procedures in the Personal Injury Hub Courts, an IDC is required for a motion to compel further discovery responses; there is no IDC requirement for a motion to compel a deposition. Turning now to sanctions, the Court grants in part Defendants request for monetary sanctions. Plaintiff contends that sanctions may be awarded only against a party, person, or attorney who unsuccessfully makes or opposes a motion to compel and that since Plaintiff has filed only a non-opposition, sanctions cannot be awarded. It is true, of course, that a number of statutes within the Civil Discovery Act authorize sanctions only against a party, person, or attorney who unsuccessfully makes or opposes a motion to compel. (See, e.g., Code Civ. Proc., § 2030.290, subd. (c) & § 2031.300, subd. (c).) But this motion is brought under section 2025.450, subdivision (a). And the applicable sanctions provision, contained in subdivision (g)(1), does not limit the authority to award sanctions to those who unsuccessfully make or oppose a motion to compel. To the contrary, subdivision (g)(1) provides: If a motion under subdivision (a) is granted, the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) in favor of the party who noticed the deposition and against the deponent or the party with whom the deponent is affiliated, unless the court finds that the one subject to the sanction acted with substantial justification or that other circ*mstances make the imposition of the sanction unjust. Accordingly, even if the Court accepted the argument that Plaintiffs non-opposition is not an opposition in substance (which the Court does not), sanctions are still authorized under section 2025.450, subdivision (g)(1), in these circ*mstances. The Court finds that a motion under subdivision (a) has been granted, that Plaintiff and counsel have not acted with substantial justification, and that other circ*mstances do not make the imposition of the sanction unjust. Based on the relatively straightforward nature of a motion to compel a deposition of a party, the Court sets sanctions in the amount of $1,604.50, calculated based on 2.5 hours of attorney time, multiplied by counsels reasonable billing rate of $295 per hour, plus $867 in costs. (See Glass Decl., ¶¶ 17-20 & Exh. O.) Sanctions are awarded against Plaintiff. No sanctions are requested against counsel. Conclusion The Court GRANTS Defendants motion to compel the deposition of Plaintiff. The Court ORDERS Plaintiff Mina Boktor to appear for deposition and answer questions under oath on September __, 2024, at 10:00 am, at the offices of Harrington Foxx Dubrow & Canter LLP, 535 North Brand Boulevard, Suite 800, Glendale, California 91203. The Court ORDERS Plaintiff Mina Boktor pay $1,604.50 in monetary sanctions under the Civil Discovery Act to Defendants within 30 days of notice of this order. Moving party is ORDERED to give notice.

Ruling

John Roe 927 D.W. vs. County of Fresno / COMPLEX

Aug 20, 2024 |22CECG03958

Re: John Roe 927 D.W. v. County of Fresno Case No. 22CECG03958Hearing Date: August 20, 2024 (Dept. 501)Motion: by Defendant County of Fresno for an Order Compelling Initial Responses to Interrogatories and Request for Production of Documents, and for SanctionsTentative Ruling: To grant defendant County of Fresno’s motion to compel plaintiff John Roe 868D.M. to serve responses to defendant’s form interrogatories, set one, specialinterrogatories, set one, and requests for production of documents, set one. Plaintiff shallserve his verified responses without objections within 10 days of the date of service of thisorder. To grant defendant’s request for monetary sanctions against plaintiff for hisunjustified failure to serve responses to discovery, in the amount of $300. Plaintiff shall paythe sanctions to defense counsel within 30 days of the date of service of this order. To deny defendant’s request for an order dismissing plaintiff’s Complaint, asdefendant has not served or filed a motion for terminating sanctions, nor has defendantshown that plaintiff has engaged in a pattern of willfully refusing to respond to discoveryor disobeyed court orders to provide discovery responses. If oral argument is timely requested, such argument will be entertained on August21, 2024, at 3:30 p.m.Explanation: The court intends to grant the motion to compel plaintiff John Roe 868 D.M. toprovide initial responses to the form interrogatories, special interrogatories, and requestsfor production of documents, set one. (See Code Civ. Proc., §§ 2030.290, 2031.300.)Plaintiff has failed to respond to the discovery requests despite being given an extensionof time to respond. His responses are now about five months overdue. He is no longerrepresented by counsel, but he is still obligated to respond to discovery as a party to theaction regardless of his legal representation. Also, he is apparently no longer respondingto phone calls, letters, or emails, and defense counsel has been unable to contact himabout the unanswered discovery. Therefore, the court will order him to provide responseswithout objections to the pending discovery requests. In addition, the court intends to order plaintiff to pay sanctions to defendant forhis unjustified refusal to respond to the discovery. Defendant seeks $620 in sanctionsbased on 3.1 hours of attorney time billed at $200 per hour. While defendant is entitled tosanctions, the requested amount of sanctions appears to be excessive based on thesimple, unopposed nature of the motion. The court will grant sanctions of $300 basedon 1.5 hours of attorney time billed at $200 per hour. To the extent defendant seeks an order dismissing the entire action, the courtintends to deny the request. Granting terminating sanctions against plaintiff at this stageof the proceedings would be premature and excessively punitive, especially sincedefendant has not properly noticed its motion for terminating sanctions. Nor has plaintiffdefied a court order requiring him to respond to discovery. Therefore, terminatingsanctions are not yet proper here. “Although in extreme cases a court has the authorityto order a terminating sanction as a first measure a terminating sanction should generallynot be imposed until the court has attempted less severe alternatives and found them tobe unsuccessful and/or the record clearly shows lesser sanctions would be ineffective.”(Lopez v. Watchtower Bible & Tract Society of New York, Inc. (2016) 246 Cal.App.4th 566,604–605, citations omitted.) However, if plaintiff continues to refuse to respond todiscovery after being ordered to do so, the court will consider granting terminatingsanctions against him. Pursuant to California Rules of Court, rule 3.1312(a), and Code of Civil Proceduresection 1019.5, subdivision (a), no further written order is necessary. The minute orderadopting this tentative ruling will serve as the order of the court and service by the clerkwill constitute notice of the order.Tentative RulingIssued By: DTT on 8/9/2024 . (Judge’s initials) (Date)

Ruling

ROCHA, FERNANDO vs TRUJILLO, DIANA LISBBETH HERNANDEZ

Aug 19, 2024 |CV-22-002302

CV-22-002302 – ROCHA, FERNANDO vs TRUJILLO, DIANA LISBBETH HERNANDEZ – Plaintiff’s Motion for Order Compelling Further Verified Responses from Defendant Ontrac to Special Interrogatories, Set Two; Request for Sanctions – GRANTED, in part, DENIED, in part.The Court finds that Plaintiff is entitled to further responses to its Special Interrogatories Set Two, Nos. 2 to 6 and that the objections raised by Defendant to same are without merit. (Civ. Proc Code § 2017.010; Civ. Proc. Code § 2030.240).Further, claims of attorney client privilege or protected work product privilege require the production of sufficient factual information for other parties to evaluate the merits of that claim, including, if necessary, a privilege log. (Civ. Proc. Code § 2031.240) Defendant made bare assertions of said privileges without supporting them with sufficient factual information or a privilege log.The Court also frowns upon Defendant’s Counsel’s conduct in making repeated assertions and undertakings to Plaintiff’s Counsel that supplementary responses were forthcoming, only to oppose this motion without any regard or reference to said assertions and undertakings.Accordingly, Plaintiff’s motion is granted. Defendant is hereby ordered to produce Code- compliant verified responses without objection to Plaintiff’s Special Interrogatories, Set Two, Nos. 2-6 within fourteen (14) days of the date of this order.Objections based on work product or attorney client privilege shall be supported by a privilege log.Plaintiff’s request for monetary sanctions is denied for failure to notice his request for monetary sanctions and the party against whom said sanctions are sought. (Mattco Forge, Inc. v. Arthur Young & Co. (1990), 223 Cal.App.3d 1429; Cal. Rules of Court, rule 311(a); Alliance Bank v. Murray (1984) 161 Cal.App.3d 1, 6; O'Brien v. Cseh, 148 Cal.App. 3d 957, at p. 961

Ruling

Manpreet Gill vs. Community Medical Centers, Inc.

Aug 21, 2024 |23CECG05021

Re: Gill v. Community Medical Centers, Inc. et al. Superior Court Case No. 23CECG05021Hearing Date: August 21, 2024 (Dept. 503)Motions: (1) By Defendant Charles Sohn, M.D. for an Order Compelling Initial Responses to Form Interrogatories, Set One From Plaintiff Yadwinder Singh, and Request for Sanctions (2) By Defendant Charles Sohn, M.D. for an Order Compelling Initial Responses to Special Interrogatories, Set One From Plaintiff Yadwinder Singh, and Request for Sanctions (3) By Defendant Charles Sohn, M.D. for an Order Compelling Initial Responses to Request for Production of Documents, Set One From Plaintiff Yadwinder Singh, and Request for Sanctions If oral argument is timely requested, it will be entertained on Thursday, August 22, 2024, at 3:30 p.m. in Department 503.Tentative Ruling: To grant each of the motions to compel initial responses to form and specialinterrogatories, and request for production of documents. Within ten (10) days of serviceof the order by the clerk, plaintiff Yadwinder Singh shall serve verified responses, withoutobjections, to Form Interrogatories, Set One; Special Interrogatories, Set One; andRequest for Production, Set One, and produce all documents responsive to the Requestfor Production of Documents. To impose monetary sanctions in the total amount of $547.50 against plaintiffYadwinder Singh, in favor of defendant Charles Sohn, M.D. Within thirty (30) days ofservice of the order by the clerk, plaintiff Yadwinder Singh shall pay sanctions todefendant Charles Sohn, M.D.’s counsel.Explanation: On January 30, 2024, defendant Charles Sohn, M.D. (“Defendant”) served thediscovery at issue on plaintiff Yadwinder Singh (“Plaintiff”). (E.g., Thelen Decl., ¶ 3, and Ex.A thereto.) As of the filing of the motions to compel, no responses have been served. (Id.,¶ 7.) No opposition was filed. Within 30 days of service of interrogatories, the party to whom the interrogatoriesare propounded shall serve the original of the response to them on the propoundingparty. (Code Civ. Proc. § 2030.260.) Within 30 days of service of a demand for inspection,the party to whom the requests are propounded shall serve the original of the responseto them on the propounding party. (Code Civ. Proc. § 2031.260.) To date, Defendanthas received no response to interrogatories and demands for inspection. Accordingly,an order compelling Plaintiff to provide initial responses is warranted. (Code Civ. Proc. §2030.290, subd. (b), 2031.300 subd. (b).) All objections are waived. (Id., §§ 2030.290, subd.(a), 2031.300, subd. (a).) Sanctions Sanctions are mandatory unless the court finds that the party acted “withsubstantial justification” or other circ*mstances that would render sanctions “unjust.” (Id.,§§ 2030.290, subd. (c), 2031.300, subd. (c).) As no opposition was filed, the court finds nocirc*mstances that would render the mandatory sanctions unjust. The court findscounsel’s rate of $245 per hour as reasonable, and imposes sanctions in $367.50 reflecting1.5 hours of attorney time in preparation of the present motion and $180.00 in filing fees,in favor of Defendant, and against Plaintiff. The sanctions imposed total to $547.50. Pursuant to California Rules of Court, rule 3.1312(a), and Code of Civil Proceduresection 1019.5, subdivision (a), no further written order is necessary. The minute orderadopting this tentative ruling will serve as the order of the court and service by the clerkwill constitute notice of the order.Tentative RulingIssued By: jyh on 8/20/24 . (Judge’s initials) (Date)

Ruling

VIACHESLAV PEVCHENKO, ET AL. VS JOSHUA ROMERO

Aug 21, 2024 |11/28/2022 |24SMCV01260

Case Number: 24SMCV01260 Hearing Date: August 21, 2024 Dept: N TENTATIVE RULING Defendant Joshua Romeros Demurrer to Plaintiffs First Amended Complaint is SUSTAINED with thirty (30) days leave to amend. Defendant Joshua Romeros Motion to Strike Portions of Plaintiffs First Amended Complaint is DENIED as MOOT. Plaintiffs Viacheslav Pevchenko and Labazangadzhi Kurbanov may amend their complaint only as authorized by the Courts order and may not amend the complaint to add a new party or cause of action without having obtained permission to do so. (Harris v. Wachovia Mortgage, FSB (2010) 185 Cal.App.4th 1018, 1023.) Defendant Joshua Romero to give notice. REASONING Legal Standard [A] demurrer tests the legal sufficiency of the allegations in a complaint. (Lewis v. Safeway, Inc. (2015) 235 Cal.App.4th 385, 388.) A demurrer can be used only to challenge defects that appear on the face of the pleading under attack or from matters outside the pleading that are judicially noticeable. (See Donabedian v. Mercury Ins. Co. (2004) 116 Cal.App.4th 968, 994 [in ruling on a demurrer, a court may not consider declarations, matters not subject to judicial notice, or documents not accepted for the truth of their contents].) For purposes of ruling on a demurrer, all facts pleaded in a complaint are assumed to be true (Aubry v. Tri-City Hosp. Dist. (1992) 2 Cal.4th 962, 967), but the Court does not assume the truth of contentions, deductions, or conclusions of fact or law (Moore v. Regents of University of California (1990) 51 Cal.3d 120, 125). Further, the court may, upon motion, or at any time in its discretion, and upon terms it deems proper, strike any irrelevant, false, or improper matter inserted in any pleading. (Code Civ. Proc., § 436, subd. (a).) The court may also strike all or any part of any pleading not drawn or filed in conformity with the laws of this state, a court rule, or an order of the court. (Code Civ. Proc., § 436, subd. (b).) The grounds for a motion to strike are that the pleading has irrelevant, false, or improper matter, or has not been drawn or filed in conformity with laws. (Code Civ. Proc., § 436.) The grounds for moving to strike must appear on the face of the pleading or by way of judicial notice. (Code Civ. Proc., § 437.) Leave to amend must be allowed where there is a reasonable possibility of successful amendment. (See Goodman v. Kennedy (1976) 18 Cal.3d 335, 349 [court shall not sustain a demurrer without leave to amend if there is any reasonable possibility that the defect can be cured by amendment]; Kong v. City of Hawaiian Gardens Redevelopment Agency (2002) 108 Cal.App.4th 1028, 1037 [A demurrer should not be sustained without leave to amend if the complaint, liberally construed, can state a cause of action under any theory or if there is a reasonable possibility the defect can be cured by amendment.]; Vaccaro v. Kaiman (1998) 63 Cal.App.4th 761, 768 [When the defect which justifies striking a complaint is capable of cure, the court should allow leave to amend.].) The burden is on the complainant to show the Court that a pleading can be amended successfully. (Blank v. Kirwan (1985) 39 Cal.3d 311, 318.) Analysis Defendant Joshua Romero (Defendant) demurs to the complaint on the ground there is another action pending in the small claims court (Los Angeles Superior Court Case No. 24BHSC00972 (Kurbanov v. Romero)). While Defendant has not properly requested judicial notice of this action or the filings therein, the Court may take judicial notice of the court records on its own motion pursuant to Evidence Code section 452, subdivision (d). The complaint in that action shows that Plaintiffs Viacheslav Pevchenko and Labazangadzhi Kurbanov (Plaintiffs) brought an action against Defendant, seeking $12,500, based on allegations that Defendant hits Plaintiffs automobile on February 19, 2024, which mirrors the allegations of the present action, except Plaintiffs allege here that Defendant hit the vehicle on February 18, 2024. Notably, the small claims action went to trial on July 3, 2024, a judgment was entered in Plaintiffs favor, and the minute order specifically notes that Plaintiffs acknowledge[d] that they have filed a superior court case as well and were advised that the jurisdictional maximum of small claims court is $12,500 and elected to proceed anyway. The action is currently the subject of an appeal by Defendant. Plaintiff provide several citations to case law and statutes, none of which indicate that a party may proceed in both unlimited civil and small claims for the same harm arising out of the same conduct. Accordingly, Defendant Joshua Romeros Demurrer to Plaintiffs First Amended Complaint is SUSTAINED with thirty (30) days leave to amend. While the Court is not convinced that Plaintiffs can amend the complaint to cure the deficiencies, the Court will allow Plaintiffs the opportunity to so amend. Given the Courts ruling on demurrer, Defendant Joshua Romeros Motion to Strike Portions of Plaintiffs First Amended Complaint is DENIED as MOOT.

Document

Miguel Tacuri-Torres v. Cs 393 Llc, Jmw 88 Llc, Firstservice Residential New York, Inc., Simon Baron Construction Llc, Press Builders, Inc., Preserv Building Restoration Managemment Incorporated

Oct 12, 2022 |Devin P. Cohen |Torts - Other Negligence (Labor Law) |Torts - Other Negligence (Labor Law) |529627/2022

Document

Nataliya Pochtar v. The City Of New York, Oceangate L.P.

Feb 04, 2018 |JURY COORDINATING PART 1 |Torts - Other (premises) |Torts - Other (premises) |504373/2018

Document

Moriam Agoro v. Living Room Restaurant And Lounge Inc., John Doe the name being fictitious the person intended being the perpetrator

Aug 29, 2018 |Joy Campanelli |Torts - Other Negligence (security) |Torts - Other Negligence (security) |517633/2018

Document

Tyler Joseph Mercado v. Ian A. Smith

Nov 01, 2021 |Debra Silber |Torts - Motor Vehicle |Torts - Motor Vehicle |527824/2021

Document

Ford Trojanowski v. Long Island Railroad, Metropolitan Transportation Authority

Nov 19, 2018 |Francois A. Rivera |Torts - Other (Slip and Fall) |Torts - Other (Slip and Fall) |523362/2018

Document

Natalie Matthews v. Verizon New York Inc., Timothy Taylor

Nov 10, 2020 |Peter Paul |Torts - Motor Vehicle |Torts - Motor Vehicle |522135/2020

Document

Mendel Neuman v. Machne Of Richmond And, Yaakov S. Schwartz

May 07, 2021 |Anne Swern |Torts - Motor Vehicle |Torts - Motor Vehicle |510820/2021

Document

Ruby Grannum v. Tanais'S Deli Grocery Corp., Rzg Realty Corp., Fzbiskie Realty Corp., E.N.Y.I.P. Realty Corp., Laurelton 224 Realty Corp., 679 Sutter Ave. Realty Corp, Carlos Rodriguez

Oct 30, 2017 |Lawrence Knipel |Torts - Other (Premises) |Torts - Other (Premises) |520939/2017

EXHIBIT(S) - J (Motion #4) - Exhibit J - Defendants Discovery Responses April 23, 2024 (2024)

References

Top Articles
Cucumber Ribbon Salad with Yogurt Herb Dressing Recipe - Rachel Cooks®
Mushroom Toast Recipe from Inside The Gjelina Cookbook
Amc Near My Location
O'reilly's Auto Parts Closest To My Location
Quick Pickling 101
Robot or human?
Chelsea player who left on a free is now worth more than Palmer & Caicedo
THE 10 BEST Women's Retreats in Germany for September 2024
A Complete Guide To Major Scales
<i>1883</i>'s Isabel May Opens Up About the <i>Yellowstone</i> Prequel
Https Www E Access Att Com Myworklife
Snowflake Activity Congruent Triangles Answers
Es.cvs.com/Otchs/Devoted
Nonuclub
Meritas Health Patient Portal
Accuradio Unblocked
Interactive Maps: States where guns are sold online most
The Cure Average Setlist
Simpsons Tapped Out Road To Riches
Wausau Marketplace
Cta Bus Tracker 77
Sussur Bloom locations and uses in Baldur's Gate 3
Georgia Cash 3 Midday-Lottery Results & Winning Numbers
Village
Galaxy Fold 4 im Test: Kauftipp trotz Nachfolger?
Dark Entreaty Ffxiv
Naya Padkar Gujarati News Paper
Shoe Station Store Locator
L'alternativa - co*cktail Bar On The Pier
Vistatech Quadcopter Drone With Camera Reviews
MethStreams Live | BoxingStreams
About | Swan Medical Group
Car Crash On 5 Freeway Today
Natashas Bedroom - Slave Commands
Google Chrome-webbrowser
D-Day: Learn about the D-Day Invasion
Trap Candy Strain Leafly
Gifford Christmas Craft Show 2022
Mytime Maple Grove Hospital
Doordash Promo Code Generator
Immobiliare di Felice| Appartamento | Appartamento in vendita Porto San
Acts 16 Nkjv
Quick Base Dcps
Love Words Starting with P (With Definition)
Toomics - Die unendliche Welt der Comics online
Walmart 24 Hrs Pharmacy
Youravon Com Mi Cuenta
Paradise leaked: An analysis of offshore data leaks
Otter Bustr
Best brow shaping and sculpting specialists near me in Toronto | Fresha
Cheryl Mchenry Retirement
Stone Eater Bike Park
Latest Posts
35+ Meatless Thanksgiving Recipes
Sweet Potato Wedges with Chinese Five Spice Recipe - Rachel Cooks®
Article information

Author: Ray Christiansen

Last Updated:

Views: 6271

Rating: 4.9 / 5 (49 voted)

Reviews: 88% of readers found this page helpful

Author information

Name: Ray Christiansen

Birthday: 1998-05-04

Address: Apt. 814 34339 Sauer Islands, Hirtheville, GA 02446-8771

Phone: +337636892828

Job: Lead Hospitality Designer

Hobby: Urban exploration, Tai chi, Lockpicking, Fashion, Gunsmithing, Pottery, Geocaching

Introduction: My name is Ray Christiansen, I am a fair, good, cute, gentle, vast, glamorous, excited person who loves writing and wants to share my knowledge and understanding with you.