Scribd Logo
Upload

Welcome to Scribd!

  • 2K views

    Notice of Motion To Compel Disclosure From Defendant

    Uploaded by

    Christina Wilkinson
    This document is a notice of motion filed by the plaintiff KCM Realty Company, L.P. against the defendant New Ram Realty, LLC in a case in the Supreme Court of the State of New York, County of Queens. The plaintiff moves the court to compel the defendant to respond to the plaintiff's discovery requests and document production demands, and to provide names and statements of witnesses, as required by a previous court order. The plaintiff also requests any other relief the court deems just and proper.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Notice of Motion To Compel Disclosure From Defendant

    Uploaded by

    Christina Wilkinson
    2K views2 pages
    This document is a notice of motion filed by the plaintiff KCM Realty Company, L.P. against the defendant New Ram Realty, LLC in a case in the Supreme Court of the State of New York, County of Queens. The plaintiff moves the court to compel the defendant to respond to the plaintiff's discovery requests and document production demands, and to provide names and statements of witnesses, as required by a previous court order. The plaintiff also requests any other relief the court deems just and proper.

    Original Description:

    KCM REALTY COMPANY, L.P., Plaintiff, v. NEW RAM REALTY, LLC, Defendant. Index No. 712807/2016

    Original Title

    NOTICE OF MOTION TO COMPEL DISCLOSURE FROM DEFENDANT

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    This document is a notice of motion filed by the plaintiff KCM Realty Company, L.P. against the defendant New Ram Realty, LLC in a case in the Supreme Court of the State of New York, County of Queens. The plaintiff moves the court to compel the defendant to respond to the plaintiff's discovery requests and document production demands, and to provide names and statements of witnesses, as required by a previous court order. The plaintiff also requests any other relief the court deems just and proper.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    2K views2 pages

    Notice of Motion To Compel Disclosure From Defendant

    Uploaded by

    Christina Wilkinson
    This document is a notice of motion filed by the plaintiff KCM Realty Company, L.P. against the defendant New Ram Realty, LLC in a case in the Supreme Court of the State of New York, County of Queens. The plaintiff moves the court to compel the defendant to respond to the plaintiff's discovery requests and document production demands, and to provide names and statements of witnesses, as required by a previous court order. The plaintiff also requests any other relief the court deems just and proper.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    You are on page 1of 2

    FILED: QUEENS COUNTY CLERK 05/04/2017 01:07 PM INDEX NO.

    712807/2016
    NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/04/2017

    SUPREME COURT OF THE STATE OF NEW YORK


    COUNTY OF QUEENS

    KCM REALTY COMPANY, L.P., Index No. 712807/2016

    Plaintiff, Justice Leonard Livote


    IAS Part 33
    v. COMMERCIAL DIVISION
    PART A
    NEW RAM REALTY, LLC,
    NOTICE OF MOTION TO
    Defendant. COMPEL DISCLOSURE FROM
    DEFENDANT__________

    PLEASE TAKE NOTICE that, upon the accompanying Affirmation of Mitchell J. Geller,

    dated May 4, 2017, together with the exhibits annexed thereto, the accompanying Memorandum

    of Law and the prior pleadings and proceedings herein, Plaintiff KCM Realty Company, L.P., by

    its attorneys Holland & Knight LLP, will move this Court in Commercial Division, Part A,

    Courtroom 122, at the Courthouse, 88-11 Sutphin Blvd, Jamaica, New York, 11435, on May 23,

    2017 at 10:00 A.M. or as soon thereafter as counsel can be heard, for the following relief:

    (1) An Order, pursuant to CPLR 3124, to compel Defendant to serve its Response to

    Plaintiffs First Notice of Discovery and Inspection, dated December 16, 2016, and to produce

    the documents requested by Plaintiffs First Notice of Discovery and Inspection, dated December

    16, 2016, as required by the Preliminary Conference Order, dated February 28, 2017;

    (2) An Order, pursuant to CPLR 3124, to compel Defendant to serve its Statement of

    names and addresses of witnesses and statements of opposing parties, if any, as required by the

    Preliminary Conference Order, dated February 28, 2017; and

    (3) An Order granting such other and further relief as the Court deems just and

    proper.

    1 of 2
    FILED: QUEENS COUNTY CLERK 05/04/2017 01:07 PM INDEX NO. 712807/2016
    NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/04/2017

    PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering papers,

    if any, shall be served upon the undersigned no less than seven (7) days prior to the return date of

    this motion.

    Dated: May 4, 2017


    New York, New York HOLLAND & KNIGHT LLP

    By: A.
    Mitchell J. G^lar
    31 West 52nd Street
    New York, New York 10019
    (212) 513-3200

    Attorneys for Plaintiff


    KCM Realty Company, LP.

    TO: VIA NYSCEF


    CLIFFORD GREENE & ASSOCIATES
    700 White Plains Post Road, Suite 309
    Scarsdale, New York 10583
    (914) 738-5992
    Attn: Clifford H. Greene, Esq.
    Attorneys for Defendant New Ram Realty, LLC

    #51104935 vl

    2 of 2

    You might also like