Motion-Secondary: Armand Santaguida v. Gertrude Hennessy, Eugene Hennessy

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                                FILED:
      ---------   QUEENS        COUNTY         CLERK        09/24/2019
                                                                  -----------X     09:22 Index AMNo.:  703470/2018
                                                                                                                       INDEX    NO.   703470/2018
   NYSCEF
      ARMAND  DOC.   NO.   41
                     SANTAGUIDA,                                                                              RECEIVED      NYSCEF:     09/25/2019


                                           Plaintiff,                                    Affidavit   of
                                                                                         Eugene    Hennessy
                         -against-



      GERTRUDE         HENNESSY         and  EUGENE       HENNESSY,


                                           Defendants.
                                                                              X
      STATE      OF  NEW     YORK          )
                                           ) SS:
      COUNTY        OF                     )


                Eugene    Hennessy,    being   duly  sworn,   states the  following    to be  true under   penalties  of perjury:



                1.       I am  the owner   (along   with  my   wife) of the  single  family  house   located   at 61-23  81st  Street, County


      of  Queens,   City  and   State New    York   ("Property").



                2.       It is  my   understanding      that,  in  this   case,  plaintiff   Armand     Santaguida      ("Santaguida")     was



      delivering    mail  to my   Property   on  December     13,  2017   when   he  fell.



                3.       To  my   knowledge,     no one   saw  Santaguida's     fall.


                4.        At the  time  of the  alleged  fall, I had Christmas     lights placed   on the  bushes   outside  of the  Property.



                5.       At  the  time   of  the  alleged   fall, I had   duct   taped   down    an  extension    cord   that  connected     the



      Christmas     lights to an  outdoor   electrical  receptacle.



                6.       At  no  point  in  time  after  the  alleged  fall, did  I ever   have  to  re-secure   the  extension    cord  or  the



      Christmas     lights.




                                                                             Eugene    Hennessy


                         Sworn    to before  me  this




                         Nota   y Publi




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