Preview
(FILED: NEW YORK COUNTY CLERK 0472372014) INDEX NO. 151650/2014
NYSCEF DOC. NO. 10 RECEIVED NYSCEF 04/23/2014
DAVID M. SANTORO.
ATTORNEY FOR
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
4 IRVING PLACE
NEW YORK, N.Y. 10003
TEL. NO. (212) 460-3355
Counselors:
Enclosed herein is Consolidated Edison Company of New York, Inc.’s:
Demand for a Verified Bill of Particulars
Demand for Medical Records and Employment Records
and Authorizations
Notice of Discovery and Inspection for Medicaid/Medicare Liens
Notice for Discovery and Inspection
Combined Demand
Notice for Discovery and Inspection of Plaintiff
Notice for Discovery and Inspection of The City of New York
Third Party Notice for Discovery and Inspection
Notice of Discovery and Inspection for Collateral Source Reimbursement
y Demand for Expert Witness Information
Notice of Refusal to Accept Service by Facsimile
Notice to Take Deposition Upon Oral Questions
Notice for Discovery and Inspection for Reimbursement for Property
Damage
a First Notice to Produce Documents
Demand Pursuant to CPLR 2103(e)
Q
The undersigned certifies that to the best of my knowledge, information and belief that, as
presented, served and/or filed, they are not frivolous as defined in Section 130-1.1(a) and (c) of
the Rules of the Chief Administrator of the Courts (22 N.Y.C.R.R.)
Very truly yours,
David M. Santoro 5
By: C Meri
170290
RCM:mb(LF) SUPREME COURT OF THE STATE OF NEW YORK
04/22/14 TY OF NEW YORK
SHELLEY KARTEN and MARK KARTEN
INDEX NO
Plaintiffs. 151650/14
- against -
500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB COMBINED
KNIGHT FRANK, CONSOLIDATED EDISON COMPANY DEMAND
OF NEW YORK, INC., GIBRALTAR CONTRACTING, INC.
and G&E REAL ESTATE MANAGEMENT SERVICES, INC
Defendants.
COUNSELORS
PLEASE TAKE NOTICE, that pursuant to CPLR Rule 3120, the undersigned
defendant herewith demands that you produce within twenty (20) days at the Law Offices of
David M. Santoro, located at 4 Irving Place, New York, NY 10003, the following information:
() Set forth in writing the name and address of each witness to the following
(a) The occurrence.
(b) Any act or condition causing the occurrence
(©) Any actual notice given to the defendants
@ The duration of the condition.
At the time of trial, an objection will be made to the testimony of any witnesses
not identified. State in the reply if the plaintiff knows of no witnesses
(2) Produce any statement of a party, or an officer, agent, or employee of the
defendant.
Q) Produce any photographs/pictures/films under the control of the plaintiff(s)
and/or defendant(s) or the attorneys or representatives of the defendant(s) showing the scene of the
OUR FILE #
S-0148-14/ occurrence alleged to represent the scene as of the time of accident, or of the plaintiff at any time.
FN0377283
At the time of trial, an objection will be made to the admissibility of any photographs/pictures/films
not produced. State in the reply ifno photographs/pictures/films are in your possession.
(4) Identify each person expected to be called as an expert witness at trial.
Disclose in reasonable detail:
(a) the subject matter on which each expert is expected to testify;
(b) the substance of the facts and opinions on which each expert is
expected to testify;
(c) the qualifications of each expert witness and,
@ a summary of the grounds for each expert's opinion.
In lieu of appearing at the stated time and place, you may send by the time
required copies of the documents and a statement that you are furnishing them pursuant to this
notice.
PLEASE TAKE FURTHER NOTICE, that this demand shall be deemed to
continue during the pendency of this action, including the trial thereof. In the event of refusal to
comply with this demand, the defendant shall seek to preclude the testimony of any parties in
relation to the information and documentation sought herein.
Dated: New York, New York
April 22, 2014.
Yours, etc.,
DAVID M. SANTORO
Attorney for Defendant
Consolidated Edison Company
of New York, Inc.
Address:
4 Irving Place, Room 1800
Borough of Manhattan
New York, New York 10003-3598
TO:
LAWRENCE B. SAFTLER, ESQ.
THE SAFTLER LAW FIRM
Attorneys for Plaintiffs
275 MADISON AVENUE - SUITE. 1605
NEW YORK, NEW YORK 10016
RCM:mb(LF) SUPREME COURT OF THE STATE OF NEW YORK
04/22/14 COUNTY OF NEW YORK
SHELLEY KARTEN and MARK KARTEN,
INDEX NO.
Plaintiffs, 151650/14
- against -
NOTICE OF
500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB REFUSAL TO
KNIGHT FRANK, CONSOLIDATED EDISON COMPANY OF ACCEPT
NEW YORK, INC., GIBRALTAR CONTRACTING, INC. and SERVICE BY
G&E REAL ESTATE MANAGEMENT SERVICES, INC., FACSIMILE
Defendants.
COUNSELORS:
PLEASE TAKE NOTICE that the undersigned, as attorney for Consolidated
Edison Company of New York, Inc. in the above captioned matter, will not accept service of
legal pleadings, proceedings or documents by facsimile in this matter.
Dated: New York, New York
April 22, 2014.
Yours, etc.,
DAVID M. SANTORO
Attorney for Defendant
Consolidated Edison Company
of New York, Inc.
Address:
4 Irving Place, Room 1800
Borough of Manhattan
New York, New York 10003-3598
TO:
OUR FILE #: LAWRENCE B. SAFTLER, ESQ.
S-0148-14/ THE SAFTLER LAW F TRA
ERM.
FN0377283 Attorneys for Plaintiffs
275 MADISON AVENUE - SUITE. 1605
NEW YORK, NEW YORK 10016
RCM:mb(LF) SUPREME COURT OF THE STATE OF NEW YORK
04/22/14 COUNTY OF NEW YORK
SHELLEY KARTEN and MARK KARTEN,
INDEX NO.:
Plaintiffs, 151650/14
- against -
DEMAND FOR
500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB EXPERT WITNESS
KNIGHT FRANK, CONSOLIDATED EDISON COMPANY OF INFORMATION
NEW YORK, INC., GIBRALTAR CONTRACTING, INC. and
G&E REAL ESTATE MANAGEMENT SERVICES, INC.,
wees wenn ese cece eee eee eee sence ee ee ec Defendants.
Bee
COUNSELORS:
PLEASE TAKE NOTICE, that pursuant to CPLR Rule 3101(d) of the Civil
Practice Law and Rules, the undersigned hereby requests that you produce at the Law Offices of
David M. Santoro, 4 Irving Place, Room 1800, New York, New York 10003-3598, the following
information:
Identify each person the party upon whom this request is served expects to
call as an expert witness at the time of the action.
The subject matter in reasonable detail on which each expert named above
is expected to testify at the trial of the action.
The substance of the facts and opinions on which each expert named
above is expected to testify at the trial of the action.
4 The qualifications of each expert named above.
5 A summary of the grounds for each expert's opinion.
PLEASE TAKE NOTICE, that this request shall be deemed to be a continuing
OUR FILE #:
S-0148-14/
FN0377283 request as to any matters or information requested herein which may become available for
discovery at a future time up to and including the time of trial.
PLEASE TAKE FURTHER NOTICE, that upon your failure to comply with
the foregoing requests the undersigned will move the Court to preclude the testimony of your
expert(s).
Dated: New York, New York
April 22, 2014.
Yours, etc.,
DAVID M. SANTORO
Attorney for Defendant
Consolidated Edison Company
of New York, Inc.
Address:
4 Irving Place, Room 1800
Borough of Manhattan
New York, New York 10003-3598
TO:
LAWRENCE B. SAFTLER, ESQ.
THE SAFTLER LAW FIRM.
Attorneys for Plaintiffs
275 MADISON AVENUE - SUITE. 1605
NEW YORK, NEW YORK 10016
RCM:mb(LF) SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
04/22/14
SHELLEY KARTEN and MARK KARTEN,
INDEX NO.:
Plaintiff, 151650/14
~ against -
500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB NOTICE TO TAKE
KNIGHT FRANK, CONSOLIDATED EDISON COMPANY DEPOSITION UPON
OF NEW YORK, INC., GIBRALTAR CONTRACTING, INC. ORAL QUESTIONS
and G&E REAL ESTATE MANAGEMENT SERVICES, INC.,
Defendants.
COUNSELORS:
PLEASE TAKE NOTICE, that pursuant to CPLR Article 31 the deposition,
upon oral questions, will be taken of defendants, GIBRALTAR CONTRACTING, INC AND
G&E REAL ESTATE MANAGEMENT SERVICES, INC., by an officer having knowledge of
the facts, or one of their respective agents, servants and/or employees, before a person authorized
by the State of New York to administer oaths, at the offices of DAVID M. SANTORO, ESQ, 4
Irving Place, 18" Floor, New York, New York 10003, at 10:00 a.m. on a date to be agreed
upon between the parties, with respect to all evidence, material and necessary in the
prosecution or defense of this action.
This person to be examined is required to produce all relevant books, papers and
other things in his possession, custody or control, to be marked as exhibits and used on the
examination.
Dated: New York, New York
April 22, 2014.
OUR FILE #:
S-0148-14/
FN0377283
Yours, etc.,
DAVID M. SANTORO
Attorney for Defendant
Consolidated Edison Company
of New York, Inc.
Address:
4 Irving Place, Room 1800
Borough of Manhattan
New York, New York 10003-3598
TO:
LAWRENCE B. SAFTLER, ESQ.
THE SAFTLER LAW FIRM
Attorneys for Plaintiffs
275 MADISON AVENUE - SUITE. 1605
NEW YORK, NEW YORK 10016
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
SHELLEY KARTEN and MARK KARTEN, INDEX
151650/14
Plaintiffs,
- against — DEMAND PURSUANT
TO CPLR 2103(e)
500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB
KNIGHT FRANK, CONSOLIDATED EDISON COMPANY OF
NEW YORK, INC., GIBRALTAR CONTRACTING, INC. and
G&E REAL ESTATE MANAGEMENT SERVICES, INC.,
Defendants,
SIR):
PLEASE TAKE NOTICE, that demand is herewith made b y Consolidated Edison
Company of
New York, Inc., a party to this action, pursuant to CPLR 2103(e), that you furnish
to the undersigned a
list of the parties who appeared in this action and the names and addresses of their attorneys.
Dated: New York, New York
April 22, 2014
Yours etc.,
DAVID M. SANTORO, ESQ.
TO: Attorney for
Consolidated Edison Company of New York, Inc.
LAWRENCE B. SAFTLER, ESQ. 4 Irving Place
THE SAFTLER LAW FIRM New York, NY 10003
Attorneys for Plaintiffs Tel. No. (212) 460-3355
275 MADISON AVENUE - SUITE. 1605
NEW YORK, NEW YORK 10016
Defendant, GIBRALTAR CONTRACTING, INC. appears
By:
Esq.
Address:
Defendant, G&E REAL ESTATE MANAGEMENT, INC. appears
By:
Esq.
Address:
Defendant,
appears
By:
Esq.
Address:
AFFIDAVIT OF SERVICE BY MAIL
STATE OF NEW YORK )
) SS.:
COUNTY OF NEW YORK. )
The undersigned being duly sworn deposes and says: that I am over the age of 18
years; am not a party to this action; and am employed in the office of DAVID M. SANTORO,
the attorney for Consolidated Edison Company of New York, Inc.
That on the 29” day of April, 2014, I served the annexed Combined Demand;
Demand for Expert Witness Information; Notice of Refusal to Accept Service by Facsimile;
Notice to Take Deposition Upon Oral Questions and Demand Pursuant to CPLR 2103(e),
upon:
LAWRENCE B. SAFTLER, ESQ.
THE SAFTLER LAW FIRM
Attorneys for Plaintiffs
275 MADISON AVENUE - SUITE. 1605
NEW YORK, NEW YORK 10016
by depositing a true copy of the same enclosed in a post-paid wrapper in an official repository
under the exclusive care and custody of the United States Postal Service or by delivering a true
copy of the same in a post-paid wrapper to an authorized United States Postal Service employee,
directed to the said party/parties at the address(es) set forth above, such being the address(es)
designated by the said party/parties for that purpose.
LUPRISCILLALS
Sworn,to before me this
DIAZ /
25d of Apr}
RNARD G. HERBERT
NOTARY PUBL of New York
No. 01 20125
Qualified in Orange County
Commission Expires April 12, 2018
Preview
(FILED: NEW YORK COUNTY CLERK 0472372014) INDEX NO. 151650/2014 NYSCEF DOC. NO. 10 RECEIVED NYSCEF 04/23/2014 DAVID M. SANTORO. ATTORNEY FOR CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. 4 IRVING PLACE NEW YORK, N.Y. 10003 TEL. NO. (212) 460-3355 Counselors: Enclosed herein is Consolidated Edison Company of New York, Inc.’s: Demand for a Verified Bill of Particulars Demand for Medical Records and Employment Records and Authorizations Notice of Discovery and Inspection for Medicaid/Medicare Liens Notice for Discovery and Inspection Combined Demand Notice for Discovery and Inspection of Plaintiff Notice for Discovery and Inspection of The City of New York Third Party Notice for Discovery and Inspection Notice of Discovery and Inspection for Collateral Source Reimbursement y Demand for Expert Witness Information Notice of Refusal to Accept Service by Facsimile Notice to Take Deposition Upon Oral Questions Notice for Discovery and Inspection for Reimbursement for Property Damage a First Notice to Produce Documents Demand Pursuant to CPLR 2103(e) Q The undersigned certifies that to the best of my knowledge, information and belief that, as presented, served and/or filed, they are not frivolous as defined in Section 130-1.1(a) and (c) of the Rules of the Chief Administrator of the Courts (22 N.Y.C.R.R.) Very truly yours, David M. Santoro 5 By: C Meri 170290 RCM:mb(LF) SUPREME COURT OF THE STATE OF NEW YORK 04/22/14 TY OF NEW YORK SHELLEY KARTEN and MARK KARTEN INDEX NO Plaintiffs. 151650/14 - against - 500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB COMBINED KNIGHT FRANK, CONSOLIDATED EDISON COMPANY DEMAND OF NEW YORK, INC., GIBRALTAR CONTRACTING, INC. and G&E REAL ESTATE MANAGEMENT SERVICES, INC Defendants. COUNSELORS PLEASE TAKE NOTICE, that pursuant to CPLR Rule 3120, the undersigned defendant herewith demands that you produce within twenty (20) days at the Law Offices of David M. Santoro, located at 4 Irving Place, New York, NY 10003, the following information: () Set forth in writing the name and address of each witness to the following (a) The occurrence. (b) Any act or condition causing the occurrence (©) Any actual notice given to the defendants @ The duration of the condition. At the time of trial, an objection will be made to the testimony of any witnesses not identified. State in the reply if the plaintiff knows of no witnesses (2) Produce any statement of a party, or an officer, agent, or employee of the defendant. Q) Produce any photographs/pictures/films under the control of the plaintiff(s) and/or defendant(s) or the attorneys or representatives of the defendant(s) showing the scene of the OUR FILE # S-0148-14/ occurrence alleged to represent the scene as of the time of accident, or of the plaintiff at any time. FN0377283 At the time of trial, an objection will be made to the admissibility of any photographs/pictures/films not produced. State in the reply ifno photographs/pictures/films are in your possession. (4) Identify each person expected to be called as an expert witness at trial. Disclose in reasonable detail: (a) the subject matter on which each expert is expected to testify; (b) the substance of the facts and opinions on which each expert is expected to testify; (c) the qualifications of each expert witness and, @ a summary of the grounds for each expert's opinion. In lieu of appearing at the stated time and place, you may send by the time required copies of the documents and a statement that you are furnishing them pursuant to this notice. PLEASE TAKE FURTHER NOTICE, that this demand shall be deemed to continue during the pendency of this action, including the trial thereof. In the event of refusal to comply with this demand, the defendant shall seek to preclude the testimony of any parties in relation to the information and documentation sought herein. Dated: New York, New York April 22, 2014. Yours, etc., DAVID M. SANTORO Attorney for Defendant Consolidated Edison Company of New York, Inc. Address: 4 Irving Place, Room 1800 Borough of Manhattan New York, New York 10003-3598 TO: LAWRENCE B. SAFTLER, ESQ. THE SAFTLER LAW FIRM Attorneys for Plaintiffs 275 MADISON AVENUE - SUITE. 1605 NEW YORK, NEW YORK 10016 RCM:mb(LF) SUPREME COURT OF THE STATE OF NEW YORK 04/22/14 COUNTY OF NEW YORK SHELLEY KARTEN and MARK KARTEN, INDEX NO. Plaintiffs, 151650/14 - against - NOTICE OF 500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB REFUSAL TO KNIGHT FRANK, CONSOLIDATED EDISON COMPANY OF ACCEPT NEW YORK, INC., GIBRALTAR CONTRACTING, INC. and SERVICE BY G&E REAL ESTATE MANAGEMENT SERVICES, INC., FACSIMILE Defendants. COUNSELORS: PLEASE TAKE NOTICE that the undersigned, as attorney for Consolidated Edison Company of New York, Inc. in the above captioned matter, will not accept service of legal pleadings, proceedings or documents by facsimile in this matter. Dated: New York, New York April 22, 2014. Yours, etc., DAVID M. SANTORO Attorney for Defendant Consolidated Edison Company of New York, Inc. Address: 4 Irving Place, Room 1800 Borough of Manhattan New York, New York 10003-3598 TO: OUR FILE #: LAWRENCE B. SAFTLER, ESQ. S-0148-14/ THE SAFTLER LAW F TRA ERM. FN0377283 Attorneys for Plaintiffs 275 MADISON AVENUE - SUITE. 1605 NEW YORK, NEW YORK 10016 RCM:mb(LF) SUPREME COURT OF THE STATE OF NEW YORK 04/22/14 COUNTY OF NEW YORK SHELLEY KARTEN and MARK KARTEN, INDEX NO.: Plaintiffs, 151650/14 - against - DEMAND FOR 500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB EXPERT WITNESS KNIGHT FRANK, CONSOLIDATED EDISON COMPANY OF INFORMATION NEW YORK, INC., GIBRALTAR CONTRACTING, INC. and G&E REAL ESTATE MANAGEMENT SERVICES, INC., wees wenn ese cece eee eee eee sence ee ee ec Defendants. Bee COUNSELORS: PLEASE TAKE NOTICE, that pursuant to CPLR Rule 3101(d) of the Civil Practice Law and Rules, the undersigned hereby requests that you produce at the Law Offices of David M. Santoro, 4 Irving Place, Room 1800, New York, New York 10003-3598, the following information: Identify each person the party upon whom this request is served expects to call as an expert witness at the time of the action. The subject matter in reasonable detail on which each expert named above is expected to testify at the trial of the action. The substance of the facts and opinions on which each expert named above is expected to testify at the trial of the action. 4 The qualifications of each expert named above. 5 A summary of the grounds for each expert's opinion. PLEASE TAKE NOTICE, that this request shall be deemed to be a continuing OUR FILE #: S-0148-14/ FN0377283 request as to any matters or information requested herein which may become available for discovery at a future time up to and including the time of trial. PLEASE TAKE FURTHER NOTICE, that upon your failure to comply with the foregoing requests the undersigned will move the Court to preclude the testimony of your expert(s). Dated: New York, New York April 22, 2014. Yours, etc., DAVID M. SANTORO Attorney for Defendant Consolidated Edison Company of New York, Inc. Address: 4 Irving Place, Room 1800 Borough of Manhattan New York, New York 10003-3598 TO: LAWRENCE B. SAFTLER, ESQ. THE SAFTLER LAW FIRM. Attorneys for Plaintiffs 275 MADISON AVENUE - SUITE. 1605 NEW YORK, NEW YORK 10016 RCM:mb(LF) SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK 04/22/14 SHELLEY KARTEN and MARK KARTEN, INDEX NO.: Plaintiff, 151650/14 ~ against - 500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB NOTICE TO TAKE KNIGHT FRANK, CONSOLIDATED EDISON COMPANY DEPOSITION UPON OF NEW YORK, INC., GIBRALTAR CONTRACTING, INC. ORAL QUESTIONS and G&E REAL ESTATE MANAGEMENT SERVICES, INC., Defendants. COUNSELORS: PLEASE TAKE NOTICE, that pursuant to CPLR Article 31 the deposition, upon oral questions, will be taken of defendants, GIBRALTAR CONTRACTING, INC AND G&E REAL ESTATE MANAGEMENT SERVICES, INC., by an officer having knowledge of the facts, or one of their respective agents, servants and/or employees, before a person authorized by the State of New York to administer oaths, at the offices of DAVID M. SANTORO, ESQ, 4 Irving Place, 18" Floor, New York, New York 10003, at 10:00 a.m. on a date to be agreed upon between the parties, with respect to all evidence, material and necessary in the prosecution or defense of this action. This person to be examined is required to produce all relevant books, papers and other things in his possession, custody or control, to be marked as exhibits and used on the examination. Dated: New York, New York April 22, 2014. OUR FILE #: S-0148-14/ FN0377283 Yours, etc., DAVID M. SANTORO Attorney for Defendant Consolidated Edison Company of New York, Inc. Address: 4 Irving Place, Room 1800 Borough of Manhattan New York, New York 10003-3598 TO: LAWRENCE B. SAFTLER, ESQ. THE SAFTLER LAW FIRM Attorneys for Plaintiffs 275 MADISON AVENUE - SUITE. 1605 NEW YORK, NEW YORK 10016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK SHELLEY KARTEN and MARK KARTEN, INDEX 151650/14 Plaintiffs, - against — DEMAND PURSUANT TO CPLR 2103(e) 500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB KNIGHT FRANK, CONSOLIDATED EDISON COMPANY OF NEW YORK, INC., GIBRALTAR CONTRACTING, INC. and G&E REAL ESTATE MANAGEMENT SERVICES, INC., Defendants, SIR): PLEASE TAKE NOTICE, that demand is herewith made b y Consolidated Edison Company of New York, Inc., a party to this action, pursuant to CPLR 2103(e), that you furnish to the undersigned a list of the parties who appeared in this action and the names and addresses of their attorneys. Dated: New York, New York April 22, 2014 Yours etc., DAVID M. SANTORO, ESQ. TO: Attorney for Consolidated Edison Company of New York, Inc. LAWRENCE B. SAFTLER, ESQ. 4 Irving Place THE SAFTLER LAW FIRM New York, NY 10003 Attorneys for Plaintiffs Tel. No. (212) 460-3355 275 MADISON AVENUE - SUITE. 1605 NEW YORK, NEW YORK 10016 Defendant, GIBRALTAR CONTRACTING, INC. appears By: Esq. Address: Defendant, G&E REAL ESTATE MANAGEMENT, INC. appears By: Esq. Address: Defendant, appears By: Esq. Address: AFFIDAVIT OF SERVICE BY MAIL STATE OF NEW YORK ) ) SS.: COUNTY OF NEW YORK. ) The undersigned being duly sworn deposes and says: that I am over the age of 18 years; am not a party to this action; and am employed in the office of DAVID M. SANTORO, the attorney for Consolidated Edison Company of New York, Inc. That on the 29” day of April, 2014, I served the annexed Combined Demand; Demand for Expert Witness Information; Notice of Refusal to Accept Service by Facsimile; Notice to Take Deposition Upon Oral Questions and Demand Pursuant to CPLR 2103(e), upon: LAWRENCE B. SAFTLER, ESQ. THE SAFTLER LAW FIRM Attorneys for Plaintiffs 275 MADISON AVENUE - SUITE. 1605 NEW YORK, NEW YORK 10016 by depositing a true copy of the same enclosed in a post-paid wrapper in an official repository under the exclusive care and custody of the United States Postal Service or by delivering a true copy of the same in a post-paid wrapper to an authorized United States Postal Service employee, directed to the said party/parties at the address(es) set forth above, such being the address(es) designated by the said party/parties for that purpose. LUPRISCILLALS Sworn,to before me this DIAZ / 25d of Apr} RNARD G. HERBERT NOTARY PUBL of New York No. 01 20125 Qualified in Orange County Commission Expires April 12, 2018