On December 16, 2016 a
Conference
was filed
involving a dispute between
Edna Skinner,
and
Alexander Parsol,
Daniel Ledven,
Igor,
Jacob Shimon,
James Lambright A K A Jim Lambright In Their Individual Capacities,
James Lambright
A K A Jim Lambright In Their Individual Capacities,
Pirs Capital, Llc,
Russell,
Unified Marketing Llc,
for Torts - Other (Employment Discrimination)
in the District Court of New York County.
Preview
(FILED: WESTCHESTER COUNTY CLERK 1172272017 05:15 PM) INDEX NO. 60992/2016
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 11/22/2017
EXHIBIT B
D: COUN 0h/22//2907 Ot a INDEX WO. 60992/2016
NYSCEF DOC. NO. &4 RECEIWED WYSCEF: 14/22/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
i
H&R RECRUITERS, LLC d/b/a THE
HAGAN-RICCI GROUP, Index No.: 60992/2016
Plaintiff, Hon. Alan D. Scheinkman, J.S.C.
- against - NOTICE TO TAKE AND COUNTER
NOTICE TO TAKE DEPOSITION
JOHN CARTER and TIBCO SOFTWARE UPON ORAL EXAMINATION
INC.,
Defendants.
|
PLEASE TAKE NOTICE, that pursuant to Section 3107 of the Civil Practice Law and
Rules, the testimony, upon oral examination of an officer, director, or employee of the Defendant
Tibco Software Inc. (“Tibco”), with knowledge of the facts, as an adverse party, will be taken
before a notary public or officer authorized by law to administer oaths, who is not an attorney, or
an employee of an attorney, for any party or prospective party herein and is not a person who
would be disqualified to act as a juror because of interests or because of consanguinity or affinity
to any party herein, at Dalco Reporting, 170 Hamilton Avenue, White Plains, New York at 10:00
am on the 4" day of May, 2017 or, pursuant to the last sentence of CPLR 3107, immediately
following the deposition of Plaintiff at the place Plaintiff is produced to be deposed by
Defendants with respect to evidence material and necessary to the prosecution of this action
including but not limited to the following matters: the hiring of Defendant John Carter
(“Carter”); Carter’s communications with third parties utilizing Tibco’s emails and telephones;
and Tibco’s production of documents responsive to Plaintiff’s prior document demands.
1 of 2
LEED :: CO) O1/ 2121//2? Ot a) TMWDEX IND.. 60992/2016
NVSCEF
DOC. NO. && FRECEMMED INKSOBF:: d4l/22/2017
The person to be examined is required to produce on or before the examination the
following: all books, papers, correspondence, and other records relative to the causes of action
alleged by the Plaintiff and any defenses and/or counterclaims asserted by the Defendants
Dated: Mineola, New York
April 10, 2017 MELTZER, Lip, B, GOLDSTEIN & BREITSTONE, LLP
D rw
Atorneys for, ARD
i
BY ht x cel Esq.
190 Willis Avenue
Mineola, New York 11501
(516) 747-0300
TO MICHAEL DIMATTIA, Esq.
McGuirEWoops LLP
Attorneys for Defendant Tibco
1345 Avenue of the Americas
7th Floor
New York, NY 10105-0106
(212) 548-7009
BRIANK. CONDON, EsQ
CONDON & ASSOCIATES, PLLC
Attorneys for Defendant John Carter
55 Old Turnpike Road, Suite 502
Nanuet, New York 10954
(845) 627.8500 x 101
786928-1
2 of 2
Document Filed Date
November 22, 2017
Case Filing Date
December 16, 2016
Category
Torts - Other (Employment Discrimination)
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(FILED: WESTCHESTER COUNTY CLERK 1172272017 05:15 PM) INDEX NO. 60992/2016 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 11/22/2017 EXHIBIT B D: COUN 0h/22//2907 Ot a INDEX WO. 60992/2016 NYSCEF DOC. NO. &4 RECEIWED WYSCEF: 14/22/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER i H&R RECRUITERS, LLC d/b/a THE HAGAN-RICCI GROUP, Index No.: 60992/2016 Plaintiff, Hon. Alan D. Scheinkman, J.S.C. - against - NOTICE TO TAKE AND COUNTER NOTICE TO TAKE DEPOSITION JOHN CARTER and TIBCO SOFTWARE UPON ORAL EXAMINATION INC., Defendants. | PLEASE TAKE NOTICE, that pursuant to Section 3107 of the Civil Practice Law and Rules, the testimony, upon oral examination of an officer, director, or employee of the Defendant Tibco Software Inc. (“Tibco”), with knowledge of the facts, as an adverse party, will be taken before a notary public or officer authorized by law to administer oaths, who is not an attorney, or an employee of an attorney, for any party or prospective party herein and is not a person who would be disqualified to act as a juror because of interests or because of consanguinity or affinity to any party herein, at Dalco Reporting, 170 Hamilton Avenue, White Plains, New York at 10:00 am on the 4" day of May, 2017 or, pursuant to the last sentence of CPLR 3107, immediately following the deposition of Plaintiff at the place Plaintiff is produced to be deposed by Defendants with respect to evidence material and necessary to the prosecution of this action including but not limited to the following matters: the hiring of Defendant John Carter (“Carter”); Carter’s communications with third parties utilizing Tibco’s emails and telephones; and Tibco’s production of documents responsive to Plaintiff’s prior document demands. 1 of 2 LEED :: CO) O1/ 2121//2? Ot a) TMWDEX IND.. 60992/2016 NVSCEF DOC. NO. && FRECEMMED INKSOBF:: d4l/22/2017 The person to be examined is required to produce on or before the examination the following: all books, papers, correspondence, and other records relative to the causes of action alleged by the Plaintiff and any defenses and/or counterclaims asserted by the Defendants Dated: Mineola, New York April 10, 2017 MELTZER, Lip, B, GOLDSTEIN & BREITSTONE, LLP D rw Atorneys for, ARD i BY ht x cel Esq. 190 Willis Avenue Mineola, New York 11501 (516) 747-0300 TO MICHAEL DIMATTIA, Esq. McGuirEWoops LLP Attorneys for Defendant Tibco 1345 Avenue of the Americas 7th Floor New York, NY 10105-0106 (212) 548-7009 BRIANK. CONDON, EsQ CONDON & ASSOCIATES, PLLC Attorneys for Defendant John Carter 55 Old Turnpike Road, Suite 502 Nanuet, New York 10954 (845) 627.8500 x 101 786928-1 2 of 2