Preview
1650/2014
NYSCEF BOC. NO. 30 RECEIVED NYSCEF 10/30/2015
RCM:am*
10/29/15
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
INDEX NO.
SHELLEY KARTEN, and MARK KARTEN, 151650/2014
Plaintiff(s),
- against -
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.
Defendant(s).
INDEX NO.
CONSOLIDATED EDISON COMPANY OF NEW YORK, 595637/2015
INC.,
Third Party Plaintiff,
VERIFIED REPLY TO
COUNTERCLAIM
- against -
NAMOW, INC.,
Third Party Defendant.
Third party plaintiff, Consolidated Edison Company of New York, Inc., (“Con
defendant,
Edison”) by its attorney, David M. Santoro, answering the counterclaim of third party
Namow, Inc., alleges:
AS TO THE ALLEGED COUNTERCLAIM AGAINST
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
FIRST: Denies upon information and belief each allegation contained in the first
alleged counterclaim.
WHEREFORE, defendant, Consolidated Edison Company of New York, Inc.,
demands judgment dismissing the complaint as to it together with costs and disbursements.
Our File No.:
S-0148-14
FN0377283
open
By:
Attorney for Defendant/
Third Party Plaintiff
Consolidated Edison Company
of New York, Inc.
Address:
4 Irving Place, Room 1800
New York, NY 10003-3598
RIDER
TO:
GIALLEONARDO MCDONALD &
TURCHETTI, ESQS
Attomeys for Third Party Defendants
NAMOW, INC.
One Whitehall Street
New York, New York 10004
Matter No.: 15-022560
LAWRENCE B. SAFTLER, ESQ.
THE SAFTLER LAW FIRM
Attorneys for Plaintiffs
275 Madison Avenue, Suite 1605
New York, New York 10016
LAW OFFICES OF CRISCI, WEISER & McCARTHY
Attorneys for Defendant
500-512 SEVENTH AVENUE, LP, LLC
17 State Street, 8" Floor
New York, New York 10004
CONWAY, GOREN & BRANDMAN
Attorneys for Defendant
G&E REAL ESTATE MANAGEMENT SERVICES, INC.
58 South Service Road, Suite 350
Melville, New York 11747
CORPORATE VERIFICATION
STATE OF NEW YORK )
)Ss.:
COUNTY OF NEW YORK )
The undersigned, being duly sworn, deposes and says: That I am an officer of
Consolidated Edison Company of New York, Inc.; that the foregoing is true to my knowledge
except as to the matters therein stated to be alleged upon information and belief, and that as to those
matters I believe it to be true.
(cv im
Sarole So
An Officer of Consolidated Edison Company
of New York, Inc.
Sworn to before me this
EY
day 0
nr
Notary Public
BERNARD C. HERBERT
NOTARY PUBLIC, State of New York
No, 01HE6220125
Qualified in Orange County
Commission Expires April 12, 2018
Our File No.:
S-0148-14
FN0377283
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 D) day of October, 2015, I served the within Verified Reply to
Counterclaim upon:
GIALLEONARDO MCDONALD & LAWRENCE B. SAFTLER, ESQ.
TURCHETTI, ESQS THE SAFTLER LAW FIRM
Attorneys for Third Party Defendant(s) Attorneys for Plaintiffs
NAMOW, INC., 275 Madison Avenue, Suite 1605
One Whitehall Street New York, New York 10016
New York, New York 10004-2109
Matter No.: 15-022560
LAW OFFICES OF CRISCI, CONWAY, GOREN & BRANDMAN
WEISER & McCARTHY Attorneys for Defendant
Attorneys for Defendant G&E REAL ESTATE MANAGEMENT
500-512 SEVENTH AVENUE, LP, LLC SERVICES, INC.
17 State Street, 8" Floor 58 South Service Road, Suite 350
New York, New York 10004 Melville, New York 11747
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 purpos
Swe to beforf/me
day of Ogtober/ 261
CL.
RNARI
. State of New York
No. O1HE6220126
Qualified in Orange County
Commission Expires April 12, 2018
INDEX NO. 151650/2014
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
SHELLEY KARTEN, and MARK KARTEN,
Plaintiff
-against-
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.
Defendant(s)
and THIRD PARTY ACTION
VERIFIED REPLY TO COUNTERCLAIM
DAVID M. SANTORO
Attorney for
Consolidated Edison Company of New York, Inc.
4 Irving Place, Room 1800
New York, New York 10003-3598
Tel. No. (212) 460-3355
FAX No. (212) 677-5849
To Service ofa copy of the within
is hereby admitted.
Dated: 20
Attorney(s) for
PLEASE TAKE NOTICE:
[] NOTICE OF ENTRY
that the within is a true copy of an entered in the office of the clerk of the within named court on 20:
[] NOTICE OF SETTLEMENT
that an Order of which the within is a true copy will be presented for settlement to the HON. one of the judges of the
within named Court, at on 20 at M.
Dated:
Yours, etc.,
DAVID M. SANTORO
Refer all communications to: RITA C. MARIN
Preview
1650/2014 NYSCEF BOC. NO. 30 RECEIVED NYSCEF 10/30/2015 RCM:am* 10/29/15 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK INDEX NO. SHELLEY KARTEN, and MARK KARTEN, 151650/2014 Plaintiff(s), - against - 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. Defendant(s). INDEX NO. CONSOLIDATED EDISON COMPANY OF NEW YORK, 595637/2015 INC., Third Party Plaintiff, VERIFIED REPLY TO COUNTERCLAIM - against - NAMOW, INC., Third Party Defendant. Third party plaintiff, Consolidated Edison Company of New York, Inc., (“Con defendant, Edison”) by its attorney, David M. Santoro, answering the counterclaim of third party Namow, Inc., alleges: AS TO THE ALLEGED COUNTERCLAIM AGAINST CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. FIRST: Denies upon information and belief each allegation contained in the first alleged counterclaim. WHEREFORE, defendant, Consolidated Edison Company of New York, Inc., demands judgment dismissing the complaint as to it together with costs and disbursements. Our File No.: S-0148-14 FN0377283 open By: Attorney for Defendant/ Third Party Plaintiff Consolidated Edison Company of New York, Inc. Address: 4 Irving Place, Room 1800 New York, NY 10003-3598 RIDER TO: GIALLEONARDO MCDONALD & TURCHETTI, ESQS Attomeys for Third Party Defendants NAMOW, INC. One Whitehall Street New York, New York 10004 Matter No.: 15-022560 LAWRENCE B. SAFTLER, ESQ. THE SAFTLER LAW FIRM Attorneys for Plaintiffs 275 Madison Avenue, Suite 1605 New York, New York 10016 LAW OFFICES OF CRISCI, WEISER & McCARTHY Attorneys for Defendant 500-512 SEVENTH AVENUE, LP, LLC 17 State Street, 8" Floor New York, New York 10004 CONWAY, GOREN & BRANDMAN Attorneys for Defendant G&E REAL ESTATE MANAGEMENT SERVICES, INC. 58 South Service Road, Suite 350 Melville, New York 11747 CORPORATE VERIFICATION STATE OF NEW YORK ) )Ss.: COUNTY OF NEW YORK ) The undersigned, being duly sworn, deposes and says: That I am an officer of Consolidated Edison Company of New York, Inc.; that the foregoing is true to my knowledge except as to the matters therein stated to be alleged upon information and belief, and that as to those matters I believe it to be true. (cv im Sarole So An Officer of Consolidated Edison Company of New York, Inc. Sworn to before me this EY day 0 nr Notary Public BERNARD C. HERBERT NOTARY PUBLIC, State of New York No, 01HE6220125 Qualified in Orange County Commission Expires April 12, 2018 Our File No.: S-0148-14 FN0377283 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 D) day of October, 2015, I served the within Verified Reply to Counterclaim upon: GIALLEONARDO MCDONALD & LAWRENCE B. SAFTLER, ESQ. TURCHETTI, ESQS THE SAFTLER LAW FIRM Attorneys for Third Party Defendant(s) Attorneys for Plaintiffs NAMOW, INC., 275 Madison Avenue, Suite 1605 One Whitehall Street New York, New York 10016 New York, New York 10004-2109 Matter No.: 15-022560 LAW OFFICES OF CRISCI, CONWAY, GOREN & BRANDMAN WEISER & McCARTHY Attorneys for Defendant Attorneys for Defendant G&E REAL ESTATE MANAGEMENT 500-512 SEVENTH AVENUE, LP, LLC SERVICES, INC. 17 State Street, 8" Floor 58 South Service Road, Suite 350 New York, New York 10004 Melville, New York 11747 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 purpos Swe to beforf/me day of Ogtober/ 261 CL. RNARI . State of New York No. O1HE6220126 Qualified in Orange County Commission Expires April 12, 2018 INDEX NO. 151650/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK SHELLEY KARTEN, and MARK KARTEN, Plaintiff -against- 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. Defendant(s) and THIRD PARTY ACTION VERIFIED REPLY TO COUNTERCLAIM DAVID M. SANTORO Attorney for Consolidated Edison Company of New York, Inc. 4 Irving Place, Room 1800 New York, New York 10003-3598 Tel. No. (212) 460-3355 FAX No. (212) 677-5849 To Service ofa copy of the within is hereby admitted. Dated: 20 Attorney(s) for PLEASE TAKE NOTICE: [] NOTICE OF ENTRY that the within is a true copy of an entered in the office of the clerk of the within named court on 20: [] NOTICE OF SETTLEMENT that an Order of which the within is a true copy will be presented for settlement to the HON. one of the judges of the within named Court, at on 20 at M. Dated: Yours, etc., DAVID M. SANTORO Refer all communications to: RITA C. MARIN