On December 10, 2015 a
Exhibit,Appendix
was filed
involving a dispute between
Andres Rodriguez Vii,
Damariz Rodriguez,
and
City Of New York,
Long Island Rail Road,
Metropolitan Transportation Authority,
Metropolitan Transportation Authority Capital Construction Company,
New York City Transit Authority,
for Torts - Other (PREMISES)
in the District Court of New York County.
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FABIANI COHEN & HALL, LLP
ATTORNEYS AT LAW
570 LEXINGTON AVENUE
NEW YORK, NEW YORK 10022
(212) 644-4420
FAX (212) 207-8182
January 13, 2016
Via NYSECF
Hon. Michael D. Stallman
Supreme Court, State of New York
County of New York
80 Centre Street-Room 278
New York, New York
Re: In the Matter of Andres Rodriguez v. MTA et al.
Index No. 162629/15
Dear Honorable Stallman:
We are counsel for the Respondents in the above-captioned matter. We are writing with
regards to Petitioners’ Order to Show Cause seeking leave to file a Late Notice of Claim. As
stated in our Sur-Reply filed with the Court on January 12, 2016, at the time of filing we were
awaiting the fully executed Affidavit of Respondent Long Island Railroad (“LIRR”). Enclosed
herein is the signed and sworn affidavit of Vivien Oliver-Taylor on behalf of the LIRR.
Respondents respectfully request that Your Honor accept the attached affidavit as a supplemental
exhibit to replace Exhibit “B” of our January 12, 2016 Sur-Reply. Thank you for your
consideration.
Anita D. Bowen
KJK/tac
Enclosure
ce:
Eliot Schaktman, Esq.
Bern Ripka, LLP
Counsel for Petitioners
Tel: (212) 702-5000
9483211
Document Filed Date
January 13, 2016
Case Filing Date
December 10, 2015
Category
Torts - Other (PREMISES)
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FABIANI COHEN & HALL, LLP ATTORNEYS AT LAW 570 LEXINGTON AVENUE NEW YORK, NEW YORK 10022 (212) 644-4420 FAX (212) 207-8182 January 13, 2016 Via NYSECF Hon. Michael D. Stallman Supreme Court, State of New York County of New York 80 Centre Street-Room 278 New York, New York Re: In the Matter of Andres Rodriguez v. MTA et al. Index No. 162629/15 Dear Honorable Stallman: We are counsel for the Respondents in the above-captioned matter. We are writing with regards to Petitioners’ Order to Show Cause seeking leave to file a Late Notice of Claim. As stated in our Sur-Reply filed with the Court on January 12, 2016, at the time of filing we were awaiting the fully executed Affidavit of Respondent Long Island Railroad (“LIRR”). Enclosed herein is the signed and sworn affidavit of Vivien Oliver-Taylor on behalf of the LIRR. Respondents respectfully request that Your Honor accept the attached affidavit as a supplemental exhibit to replace Exhibit “B” of our January 12, 2016 Sur-Reply. Thank you for your consideration. Anita D. Bowen KJK/tac Enclosure ce: Eliot Schaktman, Esq. Bern Ripka, LLP Counsel for Petitioners Tel: (212) 702-5000 9483211