PNC Bank, National Assoc. vs. Solomon Dwek
et al
Chancery Division, Monmouth County, Docket No.: Mon-C-133-06
DISCOVERY
PNC Bank, N.A. v. HSBC Bank USA, N.A., et al. - Docket No. MON-C-204-06
- Letter of January 5, 2007 from Carole Lynn Nowicki, Esq. adjourning Mark Adjmi and Eli Seruya’s deposition
- Letter of December 15, 2006 to all Counsel from Carole Lynn Nowicki, Esq. adjourning the deposition of Morris Levy and Ezra Erani
- Letter of November 30, 2006 to all Counsel from Carole Lynn Nowicki, Esq. regarding scheduling changes for depositions
- Letter of October 6, 2006 to Dennis T. Kearney, Esq. from Carlos G. Manalansan, Esq. regarding the discovery requests of defendant HSBC Bank USA, National Association
- First Notice to Produce to Plaintiff PNC Bank, N.A.
- First Set of Interrogatories to Plaintiff PNC Bank, N.A.
- Notice of Deposition, Pursuant to Rule 4:14-2(c), to PNC Bank, N.A.
- Notice of Deposition to Ben Berzin, Jr.
- Letter of October 20, 2006 to Donald M. Lomurro, Esq., Fiscal Agent from Carole Lynn Nowicki, Esq. enclosing request for production of documents directed to HSBC Bank USA, N.A., Joseph Dwek, Yeshuah, LLC, Isaac Franco and Ken Cayre
- Letter of October 20, 2006 to Mr. Reichman from Carole Lynn Nowicki, Esq. enclosing PNC Bank's Initial Request for Production of documents directed at Isaac Franco
- PNC Bank's initial request for production of documents directed to Defendant Isaac Franco
- Letter of October 20, 2006 to Mr. Usatine from Carole Lynn Nowicki, Esq. enclosing PNC Bank's Initial Request for Production of documents directed at Joseph Dwek and PNC Bank's Initial Request for Production of documents directed at Yeshuah, LLC
- PNC Bank's initial request for production of documents directed to Defendant Joseph Dwek
- PNC Bank's initial request for production of documents directed to Defendant Yeshuah, LLC
- Letter of October 20, 2006 to Mr. Goydan from Carole Lynn Nowicki, Esq. enclosing PNC Bank's Initial Request for Production of documents directed at HSBC Bank USA, N.A.
- PNC Bank's initial request for production of documents directed to HSBC Bank USA, N.A.
- Letter of October 20, 2006 to Mr. Afanador from Carole Lynn Nowicki, Esq. enclosing PNC Bank's Initial Request for Production of documents directed at Ken Cayre
- PNC Bank's initial request for production of documents directed to Ken Cayre
- Defendant Ken Cayre's initial interrogatories directed to Plaintiff PNC Bank
- Letter of October 23, 2006 to Steven Klein, Esq. from Carlos G. Manalansan, Esq. enclosing First Notice to Produce to Defendant Joseph Dwek and Yeshuah, LLC on behalf of HSBC Bank USA, N.A.
- First Notice to Produce directed to Defendant Joseph Dwek on behalf of HSBC Bank, N.A.
- First Notice to Produce directed to Defendant Yeshuah, LLC on behalf of HSBC Bank, N.A.
- Letter of October 23, 2006 to Dennis Kearney, Esq. from Carlos G. Manalansan, Esq. enclosing Substituted First Notice to Produce to Plaintiff PNC Bank, National Association on behalf of HSBC Bank USA, N.A.
- Substituted First Notice to Produce to Plaintiff PNC Bank, National Association on behalf of HSBC Bank USA, N.A.
- Letter of October 23, 2006 to Robert A. Weir, Esq. from Carlos G. Manalansan, Esq. enclosing First Notice to Produce to Defendant Solomon Dwek, SEM Realty Associates, LLC and Third-Party Defendant Corbett Holdings II, LLC on behalf of HSBC Bank USA, N.A.
- First Notice to Produce directed to Defendant Solomon Dwek on behalf of HSBC Bank USA, N.A.
- First Notice to Produce directed to Defendant SEM Realty Associates, LLC on behalf of HSBC Bank USA, N.A.
- First Notice to Produce directed to Third-Party Defendant Corbett Holdings II, LLC on behalf of HSBC Bank USA, N.A.
- Yeshuah Defendants' Interrogatories to Isaac Franco
- Yeshuah Defendants' Interrogatories to Ken Cayre
- Yeshuah Defendants' Interrogatories to Solomon Dwek and SEM Realty Associates
- Yeshuah Defendants' Interrogatories to HSBC Bank
- Yeshuah Defendants' Interrogatories to PNC Bank
- Letter of November 13, 2006 to Steven R. Klein, Esq. from Carlos G. Manalansan, Esq. enclosing first set of interrogatories to Defendant Joseph Dwek on behalf of HSBC Bank USA, N.A.
- First set of interrogatories to Defendant Joseph Dwek on behalf of HSBC Bank USA, N.A.
- Letter of November 13, 2006 to John H. Reichman, Esq. from Carlos G. Manalansan, Esq. enclosing first set of interrogatories to Defendant Isaac Franco and first set of interrogatories to Third-Party Defendant Elyse Franco on behalf of HSBC Bank USA, N.A.
- First set of interrogatories to Defendant Isaac Franco on behalf of HSBC Bank USA, N.A.
- First set of interrogatories to Third-Party Defendant Elyse Franco on behalf of HSBC Bank USA, N.A.
- Letter of November 13, 2006 to Robert A. Weir, Jr., Esq. from Carlos G. Manalansan, Esq. enclosing first set of interrogatories to Defendant Solomon Dwek, SEM Realty Associates, LLC and first set of interrogatories to Third-Party Defendant Corbett Holdings II, LLC on behalf of HSBC Bank USA, N.A.
- First set of interrogatories to Defendant Solomon Dwek on behalf of HSBC Bank USA, N.A.
- First set of interrogatories to Defendant SEM Realty Associates, LLC on behalf of HSBC Bank USA, N.A.
- First set of interrogatories to Third-Party Defendant Corbett Holdings II, LLC on behalf of HSBC Bank USA, N.A.
- Letter of November 13, 2006 to Dennis T. Kearney, Esq. from Carlos G. Manalansan, Esq. enclosing substituted first set of interrogatories to Plaintiff PNC Bank, National Association on behalf of HSBC Bank USA, N.A.
- Substituted first set of interrogatories to Plaintiff PNC Bank, National Association
- Notice to take Deposition and Produce Documents directed to George Commander
- Notice to take Deposition and Produce Documents directed to Mary Pan
- Yeshuah Defendants' Initial Disclosures
- Letter of November 21, 2006 to Carole Lynn Nowicki, Esq. from Victor A. Afanador, Esq. enclosing Ken Cayre's Initial Disclosure
- Initial Disclosures of Defendant, Ken Cayre
- Subpoena Duces Tecum directed to Murray Huberfield
- Subpoena Duces Tecum directed to Eli Seruya
- Subpoena Duces Tecum directed to David Bodner
- Subpoena Duces Tecum directed to Ezra Erani
- Subpoena Duces Tecum directed to Thomas Kasulka
- Subpoena Duces Tecum directed to Morris Levy
- Subpoena Duces Tecum directed to Mark Adjmi
- Letter of November 13, 2006 to Carole Lynn Nowicki, Esq. from Victor A. Afanador, Esq. enclosing Ken Cayre’s initial Interrogatories upon PNC Bank, N.A.
- Defendant Ken Cayre’s Initial Interrogatories upon PNC Bank, N.A.
- Letter of December 5, 2006 to all Counsel from Carole Lynn Nowicki, Esq. adjourning deposition scheduled for December 6, 2006
- Notice to take deposition and produce documents directed to Third-Party Defendant Elyse Franco
- Notice to take deposition and produce documents directed to Andrew Drolet
- Notice to take deposition and produce documents directed to Diane D'Erasmo
- Notice to take deposition and produce documents directed to Ann Hagan
- Notice to take deposition and produce documents directed to Ignatius J. Marotta
- Letter of December 6, 2006 to Mr. Kearney from Carlos G. Manalansan, Esq. enclosing amended Notices of Depositions
- Amended Notice of Deposition, pursuant to Rule 4:14-2©, to PNC Bank, National Association
- Amended Notice of Deposition of Allen Duffin
- Amended Notice of Deposition of Chris Cocozza
- Amended Notice of Deposition of Debbie Lenden
- Amended Notice of Deposition of Dorothy Lassik
- Amended Notice of Deposition of Michelle Penix
- Amended Notice of Deposition of Adrienne Joseph
- Amended Notice of Deposition Pursuant to Rule 4:14-2(c), to PNC Bank, National Association on behalf of HSBC Bank USA, National Association
- Letter of January 8, 2007 from Carole Lynn Nowicki, Esq. regarding deposition schedule for the week of January 8, 2007
- Letter of January 16, 2007 to Mr. Lomurro from Ms. Nowicki regarding deposition of Ezra Erani
- Letter of January 16, 2007 to Mr. Lomurro from Ms. Nowicki regarding deposition of Andrew Drolet, Ann Hagan and Diane D’Erasmo
- Letter of January 18, 2007 to Mr. Needle from Denise R. Rosenhaft, Esq. regarding subpoena duces tecum directed to Jerome Shapiro, Esq.
- Subpoena Duces Tecum directed to Jerome Shapiro on behalf of PNC Bank, NA
- Letter of January 19, 2007 to Mr. Lomurro from Ms. Nowicki regarding Franco depositions
- Letter of January 19, 2007 to Mr. Kearney from Nancy A Del Pizzo, Esq. enclosing Supplemental Notice to Produce directed to Plaintiff PNC Bank, N.A.
- Supplemental Notice to Produce directed to Plaintiff PNC Bank, National Association on behalf of HSBC Bank USDA, National Association
PNC Bank, N.A. - Docket No. MON-C-133-06
- Subpoena Ad Testificandum directed to Kenneth A. Rosen, Esq.
- Letter of September 25, 2006 to Honorable Alexander D. Lehrer from Dennis T. Kearney, Esq. requesting intervention on a discovery dispute
- Subpoena Dueces Tecum directed to Mitchell Abrahams, Esq.
- Subpoena Dueces Tecum directed to George Wendler
- Subpoena Dueces Tecum directed to HSBC Bank USA, National
Association
- Subpoena Dueces Tecum directed to Mark Hershey
- Subpoena Dueces Tecum directed to Joseph Kipper
- Subpoena Dueces Tecum directed to Antonio Cammalleri, Esq.
- Subpoena Dueces Tecum directed to Isaac Franco
- Subpoena Dueces Tecum directed to Ivette P. Alvarado, Esq.
- Subpoena Dueces Tecum directed to Jordan Fisch, Esq.
- Subpoena Dueces Tecum directed to Joseph Dwek
- Subpoena Dueces Tecum directed to Ken Cayre
- Subpoena Dueces Tecum directed to Lisamarie Kaspar
- Letter of September 26, 2006 to Donald M. Lomurro, Esq., Fiscal Agent, from Carole Lynn Nowicki, Esq. notifying of the changes to the scheduled deposition
- Letter of October 20, 2006 to Donald M. Lomurro, Esq., Fiscal Agent from Carole Lynn Nowicki, Esq. enclosing PNC Bank's initial request for production of documents directed to Defendant Jersey Shore Radiology Associates, P.A.
- Letter of October 20, 2006 to Mr. McGann from Carole Lynn Nowicki, Esq. enclosing PNC Bank's Initial Request for Production of documents directed at Jersey Shore Radiology Associates, P.A.
- PNC Bank's initial request for production of documents directed to Defendant Jersey Shore Radiology Associates, P.A.
- PNC Bank's Initial Interrogatories directed to Defendant HSBC Bank, USA, National Association
- PNC Bank's Initial Interrogatories directed to Defendant Joseph Dwek
- PNC Bank's Initial Interrogatories directed to Defendant Yeshuah, LLC.
- PNC Bank's Initial Interrogatories directed to Defendant Isaac Franco
- PNC Bank's Initial Interrogatories directed to Defendant Ken Cayre
- PNC Bank's Initial Interrogatories directed to Defendant Jersey Shore Radiology Associates, P.A.
- PNC Bank's Initial Interrogatories directed to Plaintiffs Jack Hakim & AJH Investments, Inc.
- Initial Disclosures of Plaintiff PNC Bank, N.A.
- Letter of November 29, 2006 from Dennis Kearney, Esq. on behalf of PNC Bank, NA supplementing its initial Disclosure
Jack Hakim and AJH Investments, Inc. - Docket No. MON-C-136-06
- Notice to Produce to Defendant's on behalf of Jack Hakim and AJH Investments, Inc., submitted for posting September 26, 2006
- Deposition Notice for Solomon Dwek, submitted for posting September 26, 2006
- Letter of October 20, 2006 to Donald M. Lomurro, Esq., Fiscal Agent from Carole Lynn Nowicki, Esq. enclosing PNC Bank's initial request for production of documents directed to Plaintiffs Jack Hakim and AJH Investments, Inc.
- Letter of October 20, 2006 to Mr. Manning from Carole Lynn Nowicki, Esq. enclosing PNC Bank's Initial Request for Production of documents directed to Plaintiffs Jack Hakim and AJH Investments, Inc.
- PNC Bank's initial request for production of documents directed to Plaintiffs Jack Hakim and AJH Investments, Inc.
- Letter of November 10, 2006 to Peter Forgash, Esq. from Vincent P. Manning, Esq. enclosing Jack Hakim and AJH Investment's Demand for answers to Interrogatories
- Demand for Interrogatories on behalf of Jack Hakim & AJH Investments, Inc.
- Disclosure on behalf of Jack Hakim & AJH Investments, Inc.
Rachel Adjmi v. Sovereign Bank and Solomon Dwek - Docket No. MON-C-256-06
- Letter of January 4, 2007 to James Kim, Esq. from Thomas W. Halm, Jr., Esq. scheduling deposition of Rachel Adjmi
- Plaintiff Rachel Adjmi's Initial Request for production of documents to Sovereign Bank
- Letter of November 15, 2006 to Steven R. Klein, Esq. from Thomas W. Halm, Jr, Esq. enclosing Sovereign Bank's Interrogatories directed to Plaintiff, Rachel Adjmi and Sovereign Bank's Second set of requests for production of documents directed to Plaintiff, Rachel Adjmi
- Sovereign Bank's Interrogatories directed to Plaintiff, Rachel Adjmi
- Sovereign Bank's Second set of requests for production of documents directed to Plaintiff, Rachel Adjmi
- Letter of October 17, 2006 to James Kim, Esq. from Thomas W. Halm, Jr., Esq. enclosing Notice of Deposition of Plaintiff Rachel Adjmi and First set of Document Requests on behalf of Defendant Sovereign Bank
- Sovereign Bank's Notice of deposition of Plaintiff Rachel Adjmi and first set of document requests
- Initial Disclosures Submitted by Sovereign Bank
- Plaintiff Rachel Adjmi's Interrogatories to Sovereign Bank
- Letter of December 8, 2006 to Steven R. Klein, Esq and Louis T DeLucia, Esq. from Robert J. Rohrberger, Esq. enclosing Demand for Documents on behalf of Third-Party Defendant Deal Yeshiva, Inc.
- Certification of Service by Robert J. Rohrberger, Esq.
- Demand for Documents directed to Defendant Rachel Adjmi and Defendant and Third-Party Plaintiff Sovereign Bank
- First set of requests for production of documents directed to Defendant, Solomon Dwek on behalf of Sovereign Bank
Isaac Franco - Docket No. MON-C-133-06
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