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Micheele Lebrecht v. Town of Smithtown et al

Docket 617686/2019, New York State, Suffolk County, Supreme Court
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15

Document Micheele Lebrecht v. Town of Smithtown et al, 617686/2019, 15 (N.Y. Sup. Ct., Suffolk County Mar. 17, 2020)
JONATHAN GILL, an attorney at law duly admitted to practice law before the Courts of the State of New York makes the following statements under penalty of perjury: 1.
I am a member of the firm of CREEDON & GILL, PC, attorneys for the defendant in Action #2 TOWN OF SMITHTOWN in the above captioned matter and as such I am fully familiar with the facts and circumstances surrounding this matter.
This Affirmation is submitted in support of the plaintiff’s motion seeking an order pursuant to CPLR section 602, consolidating the above captioned actions under index number 605725/2019.
It is further respectfully requested that upon the Order consolidating these actions for all purposes that the defendants be granted leave to serve amended in order to assert answers cross claims against one-another should they deem that to be appropriate.
section 602, consolidating the above captioned actions under Index No. 605725/2019 for all purposes and granting the defendants leave to serve amended answers in order to assert cross claims against one another should they deem that to be appropriate, together with such other and further relief as this Court deems just, proper and equitable.
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14

Document Micheele Lebrecht v. Town of Smithtown et al, 617686/2019, 14 (N.Y. Sup. Ct., Suffolk County Mar. 6, 2020)
Index/Case Number Court Judge (if assigned) If none, leave blank.
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7

Document Micheele Lebrecht v. Town of Smithtown et al, 617686/2019, 7 (N.Y. Sup. Ct., Suffolk County Oct. 2, 2019)
Defendant denies knowledge or information sufficient to form a belief as to any of the allegations contained in paragraph "1", "6", "7", "28" following numbers, "5", "27", "29", "30", "31", "32", "33", "34", "35", "36", "37", "38", "39", "40", "41", "42", "43", "44" "45" and of the Verified Complaint.
Defendant denies knowledge or information sufficient to firm a belief as to any of the following allegations contained in paragraph numbers, "3", "4" and "50", of the Verified Complaint and refers all questions of law to the Court.
All the risks and dangers connected with the situation at the time and place mentioned in the complaint were open, obvious and and were known to and assumed the plaintiff herein.
Plaintiff has failed to meet conditions precedent to the commencement of suit pursuant to the applicable sections of the General Municipal Law and/or Town of Smithtown Code.
Ljsk, said co-defendant shall be liable for and will indemnify and hold harmless this defendant for any and all amounts awarded to said plaintiff as well as all costs and disbursements associated with this litigation including attorney's fees.
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10

Document Micheele Lebrecht v. Town of Smithtown et al, 617686/2019, 10 (N.Y. Sup. Ct., Suffolk County Oct. 2, 2019)
Defendant denies each and every allegation contained in paragraph "13" asserting a cross claim against
demand judgement that the Verified Complaint be dismissed with costs and disbursements of this action.
By: O. Gill Jonatl for Defendant Attorneys of Smithtown Town 24 Woodbine Ave.,
(631) Dennis Suffolk Esq. M. Brown, Attorney County for Defendants Attorney of Suffolk County H. Lee Dennison 100 Veterans Building Memorial
Creedon Attorneys 24 Woodbine Northport, Tel: (631) & Gill, for Defendant
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11

Document Micheele Lebrecht v. Town of Smithtown et al, 617686/2019, 11 (N.Y. Sup. Ct., Suffolk County Oct. 2, 2019)

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9

Document Micheele Lebrecht v. Town of Smithtown et al, 617686/2019, 9 (N.Y. Sup. Ct., Suffolk County Oct. 2, 2019)

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4

Document Micheele Lebrecht v. Town of Smithtown et al, 617686/2019, 4 (N.Y. Sup. Ct., Suffolk County Sep. 27, 2019)

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