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KATRINA ADAMSON v. RAJENDRA PERSAUD

Docket 700293/2025, New York State, Queens County, Supreme Court (Jan. 6, 2025)
Case TypeTorts - Other (Premises Liability)
TagsTort, Civil, Other, Premises Liability
Plaintiff Katrina Adamson
Defendant Rajendra Persaud
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ORDER - PRELIMINARY CONFERENCE

Document KATRINA ADAMSON v. RAJENDRA PERSAUD, 700293/2025, 8 (N.Y. Sup. Ct., Queens County Feb. 25, 2025)
(6) Other Disclosure: (a) Within ninety (90) days from the date hereof,all parties shall exchange names and addresses of all witnesses, and shall exchange statementsof opposing parties and photographs, or,if none, shall provide an ...
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ANSWER Verified Answer (PERSAUD)

Document KATRINA ADAMSON v. RAJENDRA PERSAUD, 700293/2025, 2 (N.Y. Sup. Ct., Queens County Jan. 31, 2025)
Defendant RAJENDRA PERSAUD, by his attorneys, HEIDELL, PITTONI, MURPHY & BACH, LLP, upon information and belief, answers the Verified Complaint herein as follows:
Denies knowledge or information sufficient to form a belief as to the allegations contained in the paragraphs of the Verified Complaint designated “1”, “2”, “7”, “8”, and “14”.
WHEREFORE, Defendant RAJENDRA PERSAUD demands judgment dismissing the Verified Complaint herein, together with the costs and disbursements of this action.
I, the undersigned, an attorney admitted to practice law in the Courts of New York State, state that I am a Partner of the firm of HEIDELL, PITTONI, MURPHY & BACH, LLP, the attorneys of record for Defendant RAJENDRA PERSAUD; that I have read the foregoing ANSWER and know the contents thereof; the same is true to my own knowledge, except as to the matters therein stated to be alleged upon information and belief, and as to those matters I believe them to be true.
The grounds of my belief as to all matters not stated upon my own knowledge are as follows: Papers and records of said Defendant.
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SUMMONS + COMPLAINT SUMMONS + COMPLAINT

Document KATRINA ADAMSON v. RAJENDRA PERSAUD, 700293/2025, 1 (N.Y. Sup. Ct., Queens County Jan. 6, 2025)
your failure to appear or answer, judgment will be taken against you by default for based upon the Dated: January 6, 2025 Garden City, NewYork Defendant's Address:
___-__________-_________.________________x by her attorneys, AJLOUNYINJURY LAW, complaining alleges, upon information and belief, Plaintiff, above named, respectfully of the defendants as follows:
That upon information and belief, at all times herein mentioned, the Defendant had or should have had actual and constructive notice of said dangerous condition.
That as a result of said incident, and the Defendants negligence, carelessness, and recklessness as described herein, Plaintiff sustained serious, protracted and permanent personal injuries, was rendered sick, sore, lame and disabled; was confined to bed and home; has been and will be prevented from attending his usual duties, did seek and still seeks medical attention and aid, has incurred and will incur great expense for medical care and attention, and sustained other injuries and damages.
WHEREFORE,Plaintiff respectfully demands judgment in an amount that exceeds the jurisdiction of the lower courts, together with costs and disbursements of this action.
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RJI -RE: REQUEST FOR PRELIMINARY CONFERENCE

Document KATRINA ADAMSON v. RAJENDRA PERSAUD, 700293/2025, 7 (N.Y. Sup. Ct., Queens County Jan. 31, 2025)
If none, leave blank.
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NOTICE OF DEPOSITION Notice of Deposition (PERSAUD)

Document KATRINA ADAMSON v. RAJENDRA PERSAUD, 700293/2025, 3 (N.Y. Sup. Ct., Queens County Jan. 31, 2025)
PLEASE TAKE NOTICE that, pursuant to Article 31 of the Civil Practice Law and Rules, the deposition upon oral questions of the Plaintiff and all parties, will be taken on the 3rd day of March, 2025 at 10:00 a.m. in the forenoon of that day, before a Notary Public of the State of New York at the office of HEIDELL, PITTONI, MURPHY & BACH, LLP, 99 Park Avenue, New York, New York.
That said party is to be examined on all evidence material and necessary in the defense of this action.
Dated: New York, New York January 31, 2025
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PRELIMINARY CONFERENCE REQUEST Request for PC

Document KATRINA ADAMSON v. RAJENDRA PERSAUD, 700293/2025, 5 (N.Y. Sup. Ct., Queens County Jan. 31, 2025)
The undersigned hereby respectfully requests a Preliminary Conference in this personal injury/ motor vehicle matter in which the following attorneys have appeared:
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DEMAND FOR: Letter Re: Comprehensive Insurance Disc. Act

Document KATRINA ADAMSON v. RAJENDRA PERSAUD, 700293/2025, 6 (N.Y. Sup. Ct., Queens County Jan. 31, 2025)
Dear Counselors: In regards to the above- mentioned matter, we are in receipt of the Answer filed on January 31, 2025, respectfully.
The disclosures include: • A complete copy of any insurance policy, contract, or agreement under which any person or entity may be liable to satisfy part or all of a judgment that may be entered in an action or to indemnify or reimburse for payments made to satisfy the entry of final judgment, insofar as these documents relate to the claim being litigated.
• • • The contact information, including only the name and email, of an assigned individual responsible for adjusting the claim at issue.
The total limits available under the policy, which is defined as the “actual funds, after taking into account erosion and any other offsets.” If the plaintiffs agree in writing, defendants may produce a declaration page of a policy, instead of a complete copy.
Additionally, Plaintiffs discovery responses, including the Bill of Particulars, will be provided upon receipt of demands.
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