FILED: KINGS COUNTY CLERK 12/31/ :59 AM

Transcription

1 FILED: KINGS COUNTY CLERK 12/31/ :59 AM INDE NO /2014 NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/31/2015 EHIBIT I

2 Calendar No.: Index No.: /2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Name of Judge Assi: ed NOTE OF ISSUE For use of clerk SOFIA TYLO, an Infant Under the Age of 18 by her mother and natural guardian, TATYANA TYLO, and TATYANA TYLO, Individually, Plaintiff, --against SEACREST TOWERS, TOWER OWNERS, INC., AND COOPER SQUARE REALTY, LLC, Defendants. NOTICE FOR TRIAL Trial by jury demanded Of all issues Of issues specified below Or attached hereto Trial without jury Filed by attorney for plaintiff Date summons served 07/29/2014 Date service completed 08/05/2014 Date issue joined 09/10/2014 NATURE OF ACTION OR SPECIAL PROCEEDING Tort: Motor vehicle negligence Medical malpractice Other tort Contract Contested matrimonial Uncontested matrimonial Tax certiorari Condemnation Other (not itemized above) (specify) Indicate if this action is brought as a class action Amount demanded $ Other relief Insurance carriers, if known: Chubb Group of Insurance Companies: : Special preference claimed under on the ground that LAW OFFICE OF YURIY PRAKHIN, P. C. Attorneys for Plaintiff(s) SOFIA TYLO th Street, 2nd Floor Brooklyn, New York Goldberg Segalla LLP Attorneys for Defendant(s) COOPER SQUARE REALTY, LLC, TOWER OWNERS AND INC. 200 Garden City Plaza Suite 520 Garden City, NY (516) NOTE: Clerk will not accept this note of issue unless accompanied by a certificate of readiness.

3 CERTIFICATE OF READINESS FOR TRIAL (Items 1-7 must be checked) 1. All pleadings served 2. Bill of Particulars served 3. Physical examinations completed 4, Medical reports exchanged 5. Appraisal reports exchanged 6. Compliance with section of the Rules of the Chief Administrator (22NYCRR ) in matrimonial actions 7. Discovery proceedings known to be necessary completed Completed Waived Not required 8. There are no outstanding requests for discovery. 9. There has been a reasonable opportunity to complete the fo regoing proceedings. 10, -Them has been compliancewith any order issued-pursuant To section of the Rules of the Chief Administrator (22NYCRR ). 11. If a medical malpractice action, there has been compliance with any order issued pursuant to section of the Rules of the Chief Administrator. ( 22 NYCRR ) 12. The case is ready for trial. Dated: December 21, 2015 (Signature) YURIY PRAKI,A, ESQ. LAW OFFICE OF YURIY PRAKHIN, P. C. Attorney(s) for Plaintiff(s) th Street, 2nd Floor Brooklyn, New York

4 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS SOFIA TYLO, an Infant Under the Age of 18 by her mother and natural guardian, TATYANA TYLO, and TATYANA TYLO, Individually, Plaintiff, --against AFFIRMATION OF COMPLIANCE Index No.: /2014 SEACREST TOWERS, TOWER OWNERS, INC., AND COOPER SQUARE REALTY, LLC, Defendants. YURIY PRAKIIIN, ESQ., an attorney admitted to practice before the Courts of this State affirms the truth of the following under the penalty of perjury: 1. I am fully familiar with the facts and circumstances of this action based upon a review of the case file and the investigation materials contained therein. 2. This affirmation is submitted in connection with the filing of a Note of Issue. 3. All directives of the Central Compliance Part Order of September 24, 2015 have been complied with. 4. Depositions of all parties have been conducted. A physical examination of Plaintiff was waived. 5. All relevant witness information, party statements and medical records, reports and/or authorizations have been exchanged. WHEREFORE, Plaintiff respectfully requests that the instant matter be promptly placed on the trial calendar.

5 Dated: BROOKLYN, NEW YORK December 21, 2015 YuriyIcakhin, Esq.

6 FILED: KINGS COUNTY CLERK 09/29/ :42 AM NYSCEF DOC. NO. 19 PRESENT: -Oyu 1-C A -against- Plaintiff(s), r Z OW-9,r1 Defendant(s), JHOMSe INDE NO /2014 RECEIVED NYSCEF: 09/29/2015 At the Central Compliance Part of The Supreme Court of the State of New York, held in and for the County of Kings, at the Courthouse located at 360 Mare! Street, Brooklyn New York on the rasit day of 4-e." Ltd 20 t r CAL. NO. CENTRAL COMPLIANCE PART ORDER INDE NO. -.STOQ,r ri / I -k o QN DEFAULT ON CONSENT o AFTER ORAL ARGUMENT Plaintiff to provide all outstanding authorizations within twenty (20) days. (Enumerate if necessary on Page 2) All outstanding respoct3 Discovery and Inspection requests within twenty (20) days. Depositions of A must be held on or before Independent Medical Examinations to be held.on or before.t ( within thirty (30) days after the plaintiff's depositions). Defendant to designate Doctor(s) by I / 1.5 / II-- Medical Reports must be exchanged within J days of the exam. Plaintiff shall file a Note of Issue on or before /7-(2::/// or action may be dismissed. Plaintiffmust comply with the Uniform Rules of Kings County for placing action on the Calendar. If the Note of Issue is filed prernaturel motions to strike Note of Issue must be made within the time-period required in the CPER. Further d: V i C.) (A0-4- ir,r-j111 3a 14' Unjustified failure of any party to comply with the terms of this Order will result in the striking of a pleading. This order does not constitute a CPIS 3216 notice. For Clerk's Use Only ENTER: Retracked: Standard Complex N. MARTIN SCAEI JHO/REFRC PRINT FIRM NAME IGNATURE co ATTORNEY FIRM `inn rkritte1 /4... QC, by FOR PLAINTIFF(S) y.,,. 7 ATTORNEY FIRM egold '55,Alkt by A h - FOR DEFENDANT(S) /... - n ATTORNEY FIRM by FOR DEFENDANT(S) ma ATTORNEY FIRM by FOR DEFENDANTS? ATTORNEY FIRM by FOR DEFENDANT(S) CS/ Cora. 09/2014

7 Index No /2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ICINGS SOFIA TYLO, an Infant Under the Age of 18 by her mother and natural guardian, TATYANA TYLO, and TATYANA TYLO, Individually, Plaintiff, --against SEACREST TOWERS, TOWER OWNERS, INC., AND COOPER SQUARE REALTY, LLC, Defendants. NOTE OF ISSUE AND CERTIFICATE OF READINESS LAW OFFICE OF YURIY PRAKIIIN, P. C. Attorneys for Plaintiff th Street, 2nd Floor Brooklyn, New York TO: Goldberg Segalla LLP Attorneys for Defendant(s) COOPER SQUARE REALTY, LLC, TOWER OWNERS AND INC. 200 Garden City Plaza Suite 520 Garden City, NY (516)