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KENNETH MCCORMICK v. SULLIVAN LAND SERVICES LTD.

Docket 156030/2020, New York State, New York County, Supreme Court
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4

Document KENNETH MCCORMICK v. SULLIVAN LAND SERVICES LTD., 156030/2020, 4 (N.Y. Sup. Ct., New York County Nov. 10, 2020)
Defendant denies knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph “35” of the Complaint and refers all questions of law to the Court.
Defendant denies knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph “36” of the Complaint and refers all questions of law to the Court.
Defendant denies knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph “40” of the Complaint and refers all questions of law to the Court.
Defendant denies knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph “41” of the Complaint and refers all questions of law to the Court.
Affiant further says that the source of his information and the grounds of his belief are derived from the files, books and records maintained in the normal course of business of the Law Offices of Segal McCambridge Singer & Mahoney, Ltd. and statements made to him by Defendant SLSCO, Ltd. (incorrectly sued herein as “Sullivan Land Services Ltd.”).
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3

Document KENNETH MCCORMICK v. SULLIVAN LAND SERVICES LTD., 156030/2020, 3 (N.Y. Sup. Ct., New York County Oct. 9, 2020)
by and between the undersigned attorneys for the respective parties herein, that the time for defendant
Ltd. (sued herein as "Sullivan Land Services Ltd.") to answer, move, or otherwise appear in this matter is extended up to and including November 6.
A facsimile or PDF copy of this Stipulation shall be deemed an original.
Any party to this matter may file this Stipulation with the Court without further notice.
,\v Andrpf 850 /1 hird New York, 651-7500 (212) for Defendant Attomeys herein Land as "Sullivan hq, Esq. c,>' 1 100 Suite York 10022
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1

Document KENNETH MCCORMICK v. SULLIVAN LAND SERVICES LTD., 156030/2020, 1 (N.Y. Sup. Ct., New York County Aug. 4, 2020)
entered into an agreement and/or arrangement to provide and perform construction, renovation, demolition, rehabilitation and/or alteration work upon the aforementioned premises.
That at all times hereinafter alleged, and upon information and belief, prior to September 6, 2017, construction, renovation, demolition, rehabilitation and/or alteration work was underway and ongoing at the aforementioned premises.
entered into an agreement and contract construction to provide and perform work, labor, renovation, repairs, alteration and/or services upon the aforementioned premises
The area where plaintiff was injured was improperly and inadequately constructed, 1cpuhed, secured, guarded, supervised, inspected and maintained such that it constituted a severe hazard, a trap for the unwary, a public and private nuisance, and was in violation of applicable code.
repeats, reiterates and realleges each and every allegation contained in paragraphs numbered "1" through "38" with the same force and effect as though more fully set forth at length herein.
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5

Document KENNETH MCCORMICK v. SULLIVAN LAND SERVICES LTD., 156030/2020, 5 (N.Y. Sup. Ct., New York County Nov. 10, 2020)
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2

Document KENNETH MCCORMICK v. SULLIVAN LAND SERVICES LTD., 156030/2020, 2 (N.Y. Sup. Ct., New York County Aug. 19, 2020)
Felix Correa , being duly sworn, deposes and says: deponent is over the age of eighteen
years; that on August 12, 2020 , at 11:00 AM , at the office of the Secretary of State of the State of New York in the City of Albany, New York dep0ñéñt served the aññéxed Summons and Verified Complaint with NYSCEF Confirmation Notice Sullivan Land Services
Defendañt in this action, by delivering to and leaving with Nancy Dougherty on , the ,
2 true copies thereof and that at the time of making such service, deponent paid said Secretary of State a fee 49 dollars; That said service was made pursuant to Section 121-109 Revised Limited Partñérship Act.
Depcñêñt further says that deponent knew the person so served as aforesaid to be the age e Office of the Se etary of State of the State of New York, duly authorized to accept such serv on behalf of said defendant Descripticñ of th person served: Approx.
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