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COURT OF APPEALS OF THE STATE OF NEW YORK
----------------------------------------------------------------X
GRACE E. WEINBERG and JONAH WEINBERG,
Plaintiff-Appellant, NOTICE OF MOTION
FOR PERMISSION TO
APPEAL TO THE
COURT OF APPEALS
-against- Index Number 18673/98
County of Queens
THE CITY OF NEW YORK and
CONSOLIDATED EDISON COMPANY,TRI-MESSINE CONSTRUCTION, CO. and
SAFEWAY CONSTRUCTION ENTERPRISES,
INC. ,
Defendants-Respondents.
----------------------------------------------------------------X
S I R S :
PLEASE TAKE NOTICE that the undersigned will move this
Court at a Motion Part thereof to be held at the Courthouse located at Court of
Appeals Hall, 20 Eagle Avenue, Albany, New York on the day of July,
2012 for an Order granting the Plaintiff-Appellant permission to appeal to the
Court of Appeals from an Order of the Appellate Division Second
Department affirming a decision and order of the Supreme Court, Queens
County (Flug, J.S.C.) granting summary judgment to the City Of New York
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dismissing Plaintiff-Appellants action against the City Of New and for such
other and further relief as the Court may deem just and proper.
Dated: Queens, New York
July 2, 2012
YOURS, etc.
_________________________
ABRAHAM J. KATZ
Attorney for Plaintiff-Appellant
Office and P. O. Address1979 Marcus Avenue, Suite 210
Lake Success, New York 11042
718-747-0100
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TABLE OF CONTENTS
Page
Notice of Motion . . 1
Table of Contents ............... 2
Questions Presented for Review 3
Procedural History. . . .3
Jurisdiction .... 6
Argument . . 6
Conclusion .... . . 9
Exhibit1- New York Times Article Dated August 19, 2008 . . . . . . . .
Exhibit 2- Citys Response To Order Directing Production Of The
Digital Sewer Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Exhibit 3- Sample Digital Sewer Map. . . . . . . . . . . . 11
Exhibit 4- Appellate Division Decision and Order withNotice of Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Exhibit 5- Supreme Court Decision and Order (Flug, J.S.C.) . . . . . . 21
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QUESTIONS PRESENTED FOR REVIEW
Did the proof presented by the Plaintiff to the lower court
demonstrating that the Defendant, THE CITY OF NEW YORK, had not
complied with the lower court order requiring the production of the digital
sewer map for the location of the excavation that caused the Plaintiffs
accident raise a question of fact that precluded the lower court from granting
summary judgment to the Defendant, THE CITY OF NEW YORK?
PROCEDURAL HISTORY
This is an action for serious and permanent injuries suffered by
the Plaintiff, GRACE E. WEINBERG, when she was caused to fall to the
ground due to a defective condition on the roadway on 67th
Avenue, between
164th
Street and 165th
Street, Queens County, in the City and State of New
York. The City of New York was named as a Defendant because the City of
New York has the responsibility to provide water and sewer services to the
citizens of the City of New York and to maintain the pipes that deliver those
services. Throughout the lower court proceedings, the court was quite aware
that the Plaintiffs theory of liability was not that the City of New York had
written notice of the defect that had caused the Plaintiffs injury but that the
City of New York had created the defective condition by excavating on 67th
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Avenue, between 164th
Street and 165th
Street, Queens County, in the City
and State of New York to repair a water or sewer pipe. The Plaintiff through
discovery attempted to obtain records from the City of New York that would
reveal whether the City of New York had created the excavation that had
caused the Plaintiffs injuries. During those proceedings, the City of New
York did not produce any of those records voluntarily nor did the City of New
York produce witnesses with knowledge until the Plaintiff obtained a Court
order directing the production of those records. The question that remains
unanswered is whether the City of New York had complied with the order of
the lower court to produce the digital sewer map and repair records for the
location of the excavation that caused the Plaintiffs injuries.
On June 9, 2009, Justice Flug denied the initial motion of
summary judgment made by the City of New York on the grounds that
depositions and discovery still needed to be done including information and
records from the Sewer Department and the Department of Design and
Construction from the City on excavations at the site of the accident (R.
254). In response to that order a deposition was taken of Anthony
Cammarata, an employee of the New York City Department of
Environmental Protection. Mr. Cammarata testified that he did not search for
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any records nor did he bring any records with him to the deposition (R. 261).
Mr. Cammarata was asked about the types of maps that were maintained by
the New York City Department of Environmental Protection. At no time did
he reveal that the City of New York had created digital sewer maps that
included information on repairs to sewer pipes.
In preparation to defend a second motion for summary judgment
made by the City of New York, Plaintiffs counsel discovered through a
Google search an article that had appeared in the New York Times on August
19, 2008, attached hereto as Exhibit 1 which reported on a news conference
held by James Roberts, Deputy Commissioner of the Bureau of Water and
Sewer Operations in which he announced the completion of a six year project
to create digital sewer maps covering all of the sewer pipes within the City of
New York. Deputy Commissioner Roberts further disclosed that the digital
maps included information on repair records for every location found on the
map. Upon learning of the availability of such sewer maps, the Plaintiff
moved to compel the City of New York to produce the digital sewer map for
the location of the excavation that had caused the Plaintiffs injury. By order
dated January 26, 2010 (R. 780), Justice Flug ordered the City of New York
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to produce the digital sewer map for the location of the excavation that had
caused the Plaintiffs injury.
The City of New York responded by producing standard non-
digital sewer maps. A copy of the City of New Yorks response is annexed
hereto as Exhibit 2. The Court should note that the production of the maps
was not accompanied by an affidavit of an employee with knowledge of the
maps. Instead, counsel for the City of New York represented that the maps
produced were the digital sewer maps. Plaintiffs counsel then proceeded to
visit the Sewer Department for the County of Queens and requested a sample
of a digital sewer map. The sample digital sewer map given to Counsel for
the Plaintiff by a clerk of the Sewer Department was attached to the Plaintiffs
opposition to the motion of the City of New York for Summary Judgment and
is attached hereto as Exhibit 3. The sample digital sewer map differs
greatly from the maps produced by counsel for the City of New York. In
particular, the sample digital sewer map includes the block and lot of each
property shown on the map, the standard manner by which the City of New
York keeps records of the properties within the City of New York. The maps
produced by Counsel for the City of New York had no markings identifying
the individual properties shown by the map. By producing a map that
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differed from the maps produced by Counsel for the City of New York, the
Plaintiff raised a simple question of fact: had the City of New York complied
with Justice Flugs order compelling the City of New York to produce the
digital sewer map for the location of the excavation that had caused the
Plaintiffs injury. Justice Flug in her decision accepted the representations of
counsel for the City of New York that the City of New York had produced the
digital sewer map. The failure of the City of New York to produce the digital
sewer map for the location of the excavation that had caused the Plaintiffs
injury deprived the Plaintiff of the opportunity to learn whether the City of
New York had created the excavation through repair work.
The Appellate Division completely ignored the issue raised in
Plaintiffs brief. The Court termed the possibility that the City of New York
created the excavation as mere speculation. By not reversing the lower
court and finding that a hearing must be held to determine whether the City of
New York had produced the digital sewer map, the Appellate Division left the
question of whether the City of New York had produced the digital sewer
map unanswered.
A copy of the Appellate Division Decision and Order with
Notice of Entry was served upon Plaintiffs counsel by Consolidated Edison
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on June 6, 2012 by regular mail and by City of New York on June 12, 2012
by regular mail. The within motion for leave to appeal was therefore timely
made. A copy of the Appellate Division Decision and Order is annexed
hereto as Exhibit 4. A copy of the Supreme Court Decision and Order is
annexed hereto as Exhibit 5.
JURISDICTION
This Court has jurisdiction on this motion and of the proposed
appeal. This is an appeal from a final determination granting the City of New
York summary judgment dismissing the Plaintiffs action.
ARGUMENT
In granting summary judgment to the City of New York, the
lower court made two factual determinations. The Court first determined that
a search of Department of Environmental Protection records had been
undertaken by Anthony Cammarata, an employee of the New York City
Department of Environmental Protection and that he found that no
construction or excavation work was done by DEP on the subject roadway for
two years prior to plaintiffs accident. The record reveals that the contrary
was true. Mr. Cammarata testified at his deposition that he had performed no
record searches prior to appearing at the deposition (R. 261).
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The lower court made a second factual determination. The Court
found that the City had complied with the order of Justice Flug dated January
26, 2010 (R. 780) ordering the City of New York to produce the sewer
digital map for the location of the excavation which caused the Plaintiffs
injuries. The record reveals that the Plaintiff submitted in reply a copy of a
sample of the digital sewer map given to counsel for Plaintiff by a clerk of the
sewer department. That map differed greatly from the maps produced by the
City of New York. At a minimum, the lower court should have held a hearing
to determine whether the representation made by counsel for the City of New
York that the City of New had produced the digital sewer map for the location
of the excavation which caused the Plaintiffs injuries was true.
This Court should grant Plaintiff leave to appeal because this
case raises significant issues concerning the manner in which the City of New
York responds to discovery requests. In the within case, despite numerous
discovery requests, the City of New York never revealed that it maintained
digital sewer maps that include repair records to its sewer pipes. A witness
produced by the City of New York who claimed familiarity with the maps
maintained by the Sewer Department was deposed on December 11, 2008,
four months after the City of New York had announced that it had completed
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its project to create the digital sewer maps. He never revealed that the Sewer
Department maintained digital sewer maps. Even when ordered by the lower
Court to produce the digital sewer map for the location of the excavation that
had caused the Plaintiffs injury, the City of New York continued to withhold
those records. More importantly two attorneys for Corporation Counsels
office made representations to the Courts, once to the lower court and once to
the Appellate Division, that the maps produced by the City of New York were
the digital sewer maps for the location of the excavation that had caused the
Plaintiffs injury. Those representations are open to question. Finally,
despite being given a copy of a sample of a digital sewer map that differed
from the maps produced by the City of New York, two courts refused to
consider the possibility that the City of New York had misrepresented that it
had complied with the order to produce those maps and had withheld records
that may have shown that the City of New York had indeed created the
excavation that had caused the Plaintiffs injury.
The Appellate Division decision was particularly trouble in
upholding the dismissal of the case against the City of New York. The
Appellate Division intentionally omitted any reference to the question as to
whether the City of New York had produced the digital sewer map for the
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location of the excavation that that had caused the Plaintiffs injury. Instead,
the court described the Plaintiffs attempts to obtain records from the City of
New York to learn whether the City of New York had created the excavation
that had caused the Plaintiffs injury as mere speculation. It should not go
unnoticed by this court that the Appellate Division was careful not to disclose
to the legal community that a new discovery device was available to uncover
City of New York liability in the form of the digital sewer maps.
This court can choose to be the third court to refuse to consider
whether the City of New York failed to produce the digital maps and the
repair records included therein for the location of the excavation that had
caused the Plaintiffs injury or it can choose to protect the integrity of the
New York court system by granting this motion for leave to appeal. The
Court can then reverse that part of the order of the Appellate Division that
affirmed the Order granting summary judgment to the City of New York and
can order that a hearing be held to determine whether the City of New York
had produced the digitals sewer map and the repair records included therein
and whether the City of New York had misrepresented that it had produced
the digital sewer map for the location of the excavation that that had caused
the Plaintiffs injury.
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CONCLUSION
The Court of Appeals should grant the Plaintiff permission to
appeal the decision and order of the Appellate Division Second Department
affirming a decision and order of the Supreme Court, Queens County (Flug,
J.S.C.) dismissing Plaintiff-Appellants action pursuant to CPLR Section
3216 and for such other and further relief as the Court may deem just and
proper.
Dated: Queens, New York
July 9, 2012
Yours, etc.
_______________________
ABRAHAM J. KATZ
Attorney for Plaintiffs-Appellants
GRACE E. WEINBERG and
JONAH WEINBERG
1979 Marcus Avenue, Suite 210
Lake Success, New York 11042
718-747-0100
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COURT OF APPEALS OF THE STATE OF NEW YORK----------------------------------------------------------------X
GRACE E. WEINBERG and JONAH WEINBERG,
Plaintiff-Appellant, NOTICE OF MOTION FORPERMISSION TO APPEAL
-against- TO THE COURT OF APPEALS
THE CITY OF NEW YORK and CONSOLIDATED
EDISON COMPANY, TRI-MESSINE CONSTRUCTION,
CO. and SAFEWAY CONSTRUCTION ENTERPRISES,INC. , Index Number 18673/98
County of Queens
Defendant-Respondent.
----------------------------------------------------------------XS I R S :
PLEASE TAKE NOTICE that the undersigned will move this Court at a
Motion Part thereof to be held at the Courthouse located at Court of Appeals Hall, 20
Eagle Avenue, Albany, New York on the day of July, 2012 for an Order granting the
Plaintiff-Appellant permission to appeal to the Court of Appeals from an Order of the
Appellate Division Second Department affirming a decision and order of the Supreme
Court, Queens County (Flug, J.S.C.) granting summary judgment to the City Of New York
dismissing Plaintiff-Appellants action against the City Of New and for such other and
further relief as the Court may deem just and proper.
Dated: Queens, New York
July 2, 2012YOURS, etc.
______________________________ABRAHAM J. KATZ
Attorney for Plaintiff-Appellant
Office and P. O. Address
1979 Marcus Avenue, Suite 210Lake Success, New York 11042
718-747-0100
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TABLE OF CONTENTS
Page
Notice of Motion 1
Table of Contents ...............2
Questions Presented for Review 3
Procedural History .3
Jurisdiction ....6
Argument ..6
Conclusion ....9
Exhibit1- New York Times Article Dated August 19, 2008 . . . . . . . . . . . .
Exhibit 2- Citys Response To Order Directing Production Of TheDigital Sewer Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10
Exhibit 3- Sample Digital Sewer Map . . . . . . . . . . . . . . . . . .11
Exhibit 4- Appellate Division Decision and Order with Notice of Entry .19
Exhibit 5- Supreme Court Decision and Order (Flug, J.S.C.) ......... 21
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QUESTIONS PRESENTED FOR REVIEW
Did the proof presented by the Plaintiff to the lower court demonstrating
that the Defendant, THE CITY OF NEW YORK, had not complied with the lower court
order requiring the production of the digital sewer map for the location of the excavation
that caused the Plaintiffs accident raise a question of fact that precluded the lower court
from granting summary judgment to the Defendant, THE CITY OF NEW YORK?
PROCEDURAL HISTORY
This is an action for serious and permanent injuries suffered by the Plaintiff,
GRACE E. WEINBERG, when she was caused to fall to the ground due to a defective
condition on the roadway on 67th Avenue, between 164th Street and 165th Street, Queens
County, in the City and State of New York. The City of New York was named as a
Defendant because the City of New York has the responsibility to provide water and sewer
services to the citizens of the City of New York and to maintain the pipes that deliver those
services. Throughout the lower court proceedings, the court was quite aware that the
Plaintiffs theory of liability was not that the City of New York had written notice of the
defect that had caused the Plaintiffs injury but that the City of New York had created the
defective condition by excavating on 67th
Avenue, between 164th
Street and 165th
Street,
Queens County, in the City and State of New York to repair a water or sewer pipe. The
Plaintiff through discovery attempted to obtain records from the City of New York that
would reveal whether the City of New York had created the excavation that had caused the
Plaintiffs injuries. During those proceedings, the City of New York did not produce any
of those records voluntarily nor did the City of New York produce witnesses with
knowledge until the Plaintiff obtained a Court order directing the production of those
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records. The question that remains unanswered is whether the City of New York had
complied with the order of the lower court to produce the digital sewer map and repair
records for the location of the excavation that caused the Plaintiffs injuries.
On June 9, 2009, Justice Flug denied the initial motion of summary
judgment made by the City of New York on the grounds that depositions and discovery
still needed to be done including information and records from the Sewer Department and
the Department of Design and Construction from the City on excavations at the site of the
accident (R. 254). In response to that order a deposition was taken of Anthony
Cammarata, an employee of the New York City Department of Environmental Protection.
Mr. Cammarata testified that he did not search for any records nor did he bring any records
with him to the deposition (R. 261). Mr. Cammarata was asked about the types of maps
that were maintained by the New York City Department of Environmental Protection. At
no time did he reveal that the City of New York had created digital sewer maps that
included information on repairs to sewer pipes.
In preparation to defend a second motion for summary judgment made by
the City of New York, Plaintiffs counsel discovered through a Google search an article
that had appeared in the New York Times on August 19, 2008, annexed hereto as Exhibit
1, which reported on a news conference held by James Roberts, Deputy Commissioner
of the Bureau of Water and Sewer Operations in which he announced the completion of a
six year project to create digital sewer maps covering all of the sewer pipes within the City
of New York. Deputy Commissioner Roberts further disclosed that the digital maps
included information on repair records for every location found on the map. Upon learning
of the availability of such sewer maps, the Plaintiff moved to compel the City of New York
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to produce the digital sewer map for the location of the excavation that had caused the
Plaintiffs injury. By order dated January 26, 2010 (R. 780), Justice Flug ordered the City
of New York to produce the digital sewer map for the location of the excavation that had
caused the Plaintiffs injury.
The City of New York responded by producing standard non-digital sewer
maps. A copy of the City of New Yorks response is annexed hereto as Exhibit 2. The
Court should note that the production of the maps was not accompanied by an affidavit of
an employee with knowledge of the maps. Instead, counsel for the City of New York
represented that the maps produced were the digital sewer maps. Plaintiffs counsel then
proceeded to visit the Sewer Department for the County of Queens and requested a sample
of a digital sewer map. The sample digital sewer map given to Counsel for the Plaintiff by
a clerk of the Sewer Department was attached to the Plaintiffs opposition to the motion of
the City of New York for Summary Judgment and is attached hereto as Exhibit 3. The
sample digital sewer map differs greatly from the maps produced by counsel for the City of
New York. In particular, the sample digital sewer map includes the block and lot of each
property shown on the map, the standard manner by which the City of New York keeps
records of the properties within the City of New York. The maps produced by Counsel for
the City of New York had no markings identifying the individual properties shown by the
map. By producing a map that differed from the maps produced by Counsel for the City of
New York, the Plaintiff raised a simple question of fact: had the City of New York
complied with Justice Flugs order compelling the City of New York to produce the digital
sewer map for the location of the excavation that had caused the Plaintiffs injury. Justice
Flug in her decision accepted the representations of counsel for the City of New York that
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the City of New York had produced the digital sewer map. The failure of the City of New
York to produce the digital sewer map for the location of the excavation that had caused
the Plaintiffs injury deprived the Plaintiff of the opportunity to learn whether the City of
New York had created the excavation through repair work.
The Appellate Division completely ignored the issue raised in Plaintiffs
brief. The Court termed the possibility that the City of New York created the excavation
as mere speculation. By not reversing the lower court and finding that a hearing must
be held to determine whether the City of New York had produced the digital sewer map,
the Appellate Division left the question of whether the City of New York had produced the
digital sewer map unanswered.
A copy of the Appellate Division Decision and Order with Notice of Entry
was served upon Plaintiffs counsel by Consolidated Edison on June 6, 2012 by regular
mail and by City of New York on June 12, 2012 by regular mail. The within motion for
leave to appeal was therefore timely made. A copy of the Appellate Division Decision and
Order is annexed hereto as Exhibit 4. A copy of the Supreme Court Decision and Order
is annexed hereto as Exhibit 5.
JURISDICTION
This Court has jurisdiction on this motion and of the proposed appeal. This
is an appeal from a final determination granting the City of New York summary judgment
dismissing the Plaintiffs action.
ARGUMENT
In granting summary judgment to the City of New York, the lower court
made two factual determinations. The Court first determined that a search of Department
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of Environmental Protection records had been undertaken by Anthony Cammarata, an
employee of the New York City Department of Environmental Protection and that he
found that no construction or excavation work was done by DEP on the subject roadway
for two years prior to plaintiffs accident. The record reveals that the contrary was true.
Mr. Cammarata testified at his deposition that he had performed no record searches prior to
appearing at the deposition (R. 261).
The lower court made a second factual determination. The Court found that
the City had complied with the order of Justice Flug dated January 26, 2010 (R. 780)
ordering the City of New York to produce the sewer digital map for the location of the
excavation which caused the Plaintiffs injuries. The record reveals that the Plaintiff
submitted in reply a copy of a sample of the digital sewer map given to counsel for
Plaintiff by a clerk of the sewer department. That map differed greatly from the maps
produced by the City of New York. At a minimum, the lower court should have held a
hearing to determine whether the representation made by counsel for the City of New York
that the City of New had produced the digital sewer map for the location of the excavation
which caused the Plaintiffs injuries was true.
This Court should grant Plaintiff leave to appeal because this case raises
significant issues concerning the manner in which the City of New York responds to
discovery requests. In the within case, despite numerous discovery requests, the City of
New York never revealed that it maintained digital sewer maps that include repair records
to its sewer pipes. A witness produced by the City of New York who claimed familiarity
with the maps maintained by the Sewer Department was deposed on December 11, 2008,
four months after the City of New York had announced that it had completed its project to
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create the digital sewer maps. He never revealed that the Sewer Department maintained
digital sewer maps. Even when ordered by the lower Court to produce the digital sewer
map for the location of the excavation that had caused the Plaintiffs injury, the City of
New York continued to withhold those records. More importantly two attorneys for
Corporation Counsels office made representations to the Courts, once to the lower court
and once to the Appellate Division, that the maps produced by the City of New York were
the digital sewer maps for the location of the excavation that had caused the Plaintiffs
injury. Those representations are open to question. Finally, despite being given a copy of
a sample of a digital sewer map that differed from the maps produced by the City of New
York, two courts refused to consider the possibility that the City of New York had
misrepresented that it had complied with the order to produce those maps and had withheld
records that may have shown that the City of New York had indeed created the excavation
that had caused the Plaintiffs injury.
The Appellate Division decision was particularly trouble in upholding the
dismissal of the case against the City of New York. The Appellate Division intentionally
omitted any reference to the question as to whether the City of New York had produced the
digital sewer map for the location of the excavation that that had caused the Plaintiffs
injury. Instead, the court described the Plaintiffs attempts to obtain records from the City
of New York to learn whether the City of New York had created the excavation that had
caused the Plaintiffs injury as mere speculation. It should not go unnoticed by this
court that the Appellate Division was careful not to disclose to the legal community that a
new discovery device was available to uncover City of New York liability in the form of
the digital sewer maps.
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This court can choose to be the third court to refuse to consider whether the
City of New York failed to produce the digital maps and the repair records included therein
for the location of the excavation that had caused the Plaintiffs injury or it can choose to
protect the integrity of the New York court system by granting this motion for leave to
appeal. The Court can then reverse that part of the order of the Appellate Division that
affirmed the Order granting summary judgment to the City of New York and can order that
a hearing be held to determine whether the City of New York had produced the digitals
sewer map and the repair records included therein and whether the City of New York had
misrepresented that it had produced the digital sewer map for the location of the excavation
that that had caused the Plaintiffs injury.
CONCLUSION
The Court of Appeals should grant the Plaintiff permission to appeal the
decision and order of the Appellate Division Second Department affirming a decision and
order of the Supreme Court, Queens County (Flug, J.S.C.) dismissing Plaintiff-Appellants
action pursuant to CPLR Section 3216 and for such other and further relief as the Court
may deem just and proper
Dated: Queens, New YorkJuly 5, 2012
Yours, etc.
______________________________
ABRAHAM J. KATZ
Attorney for Plaintiffs-AppellantsGRACE E. WEINBERG and
JONAH WEINBERG
1979 Marcus Avenue, Suite 210
Lake Success, New York 11042718-747-0100
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