Party Statement: Jose Rivas AND, Margarita Rivas INDIVIDUALLY AND AS HUSBAND AND WIFE v. Bowling Green Associates, L.P. AND, Berkshire Bank, Braun Management, Inc.

• 
• 

						
                                
Preview
                                FILED:         NEW     YORK       COUNTY        CLERK        07/08/2013                                             INDEX    NO.   158832/2012
   NYSCEF     DOC.   NO.   9                                                                                  RECEIVED      NYSCEF:     07/08/2013




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF NEW YORK

                  JOSE RIVAS and MARGARITA RIVAS, Individually
                  and as Husband and Wife,                                              Index No.:        158832/2012

                                                      Plaintiffs,                       DEMAND FOR STATEMENT OF
                                                                                        DAMAGES PURSUANT TO CPLR
                                               -against-                                3017

                  BOWLING GREEN ASSOCIATES, L.P., and BRAUN
                  MANAGEMENT, INC.,

                                                      Defendants.


                  COUNSEL:

                           PLEASE       TAKE     NOTICE,       that pursuant    to Section   3017(c)    of the  Civil  Practice   Law

                  and   Rules   (“CPLR”),     demand    is  hereby   made    that within   fifteen  (15)   days  of  service   hereof,

                  plaintiff  furnish   a supplemental     demand     to  the undersigned     setting   forth  the total  damages     to

                  which   plaintiff  deems    herself  entitled  by  reason   of  the  claims   set forth  in the  above   captioned

                  action.

                           PLEASE TAKE FURTHER NOTICE, that upon plaintiff’s failure to comply with this

                  demand     in  a timely   fashion,   an   application   will   be  made    to the   within   Court   for  an  Order

                  compelling service of such a supplemental demand and awarding costs, including attorneys’ fees,

                  pursuant   to  Part  130  of  the  Uniform    Court   Rules,  and   furthermore    granting   such   other,  further

                  and different relief as the Court deems just and proper.

                  Dated:   New York, NY
                           July 8, 2013

                                                                                 THE CHARTWELL LAW OFFICES, LLP
                                                                                 By:
                                                                                          William H. Grae, Esq.
                                                                                 Attorneys for Defendants
                                                                                 BOWLING         GREEN       ASSOCIATES,          L.P.
                                                                                 and BRAUN MANAGEMENT SERVICES,
                                                                                 INC.,    i/s/h/a  “BRAUN        MANAGEMENT,
                                                                                 INC.”
                                                                                 One Battery Park Plaza, 35th Floor
                                                                                 New York, NY 10004
                                                                                 (212) 968-2300
                  TO:

                  CELLINO & BARNES, P.C.
                  Attn:    Steven M. Fleckner, Esq.
                  420 Lexington Ave, Ste 930
                  New York, NY 10170
                  (800) 621-2020
                  Served Via NYS E-Filing System