Preview
FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020
NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 09/23/2021
EXHIBIT A
FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020
NYSCEF DOC.RICHMOND
NO. 74 INDEX
RECEIVED NO.
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09/23/2021
FILED: COUNTY CLERK 11/05/2020 12 : 59 PMJ
NY SCEF DOC . NO . 1 RECE IVED NY SCE F: 11/05/2020
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF RICHMOND
------------------------- --- ¬x SUMMONS
VICTOR CALDERON,
The basis of venue is:
Plaintiff, PlaintitPs residence
-against- Plaintiff's address:
401 Hett Avenue
HOLIDAY VILLAS AT OAKWOODHOMEOWNERS
Staten Island, NY 10306
ASSOCIATION, INC AND CHRISTINA FALGIANO,
Defendants.
_______............ .. -- -------X
To the above named Defendant(s):
You are hereby -rrnd to answer the complaint in this action, and to serve a copy
of your answer, or, if the cõmplaint is not served with this summ_ens3 to serve a notice of
appearmee on the Plaintiff's aticiscys within twenty days after the service of this sumacre,
exclesive of the day of service, where service is made by delivery upon you persemlly within
the state, or, within 30 days after completion of service where service is made in any other
manner. In case of your failure to appear or answer, judgment will be taken against you by
default for the reliefdemanded in the complaint.
Dated: Staten Island, NY
October 15, 2020
B :.io ph A. Agostino
CHELLI & BUSH
Attorney for Plaintiff
149 New Dorp Lane
Staten Island, N.Y., 10306
(718) 987-8444
To:
Holiday Villas Homeowners Association, Inc,
1610 Richmond Road
.
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Staten Island, New York 10304
Holiday Villas Houmowners Association, Inc.
42 Vedder Avenue
Staten Island, New York 10314
Christina Falgiano
21 Garth Court
Staten Island, New York 10306
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
-______.------.,--.--------------..x
VICTOR CALDERON, VERIFIED
COMPLAINT
Plaintiff,
Index No.:
-against-
HOLIDAY VILLAS AT OAKWOOD HOMEOWNERS
ASSOCIATION, INC. AND CHRISTINA FALGIANO,
Defendants.
---------------------------x
Plaintiff, by her attorneys, CHELLI & BUSH, corep'eng of the Defcadants herein,
respectfully sets forth and alleges to the Court as follows:
AS AND FOR A FIRST CAUSE OF ACTION:
L At the time of the commonvauent of this action, Plaintiff was a resident of the City and
State of New York, County of Richmond.
2. That this action falls within one or more of the exemptions set forth in CPLR section
1602.
3. The cause of action alleged herein arose in the County of Richmo¾ State of New York.
4. On May 25, 2020, and at alltimes e-cñ ñed herein there existed a premises located at
21 Garth Court, Staten Island, NY,
5. That at all times men%nad herein, there existed a corporation known as HOLIDAY
VILLAS AT OAKWOOD HOMEOWNERS ASSOCIATION, INC. which was orgsñir.ed and formed
pursuant to the laws of the stateof New York,
6. That, at all times mentioned herein, and on May 25, 2020, the Defcadant, HOLIDAY
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V1LLAS AT OAKWOOD HOMEOWNERS ASSOCIATION, INC. (hereinafter referred to as
"HOLIDAY"):rei-tained.its principal place of business in Richmond County, State of New York.
7. That at alltimes mentioned herein, and on May 25, 2020, the Defendant, HOLIDAY was
the owner of the land, sidewalks, wallcways and pathsand structures/pamises thereon, cer-êrly known
as 21 Garth Court, Staten Island, New York.
8. That at all times mentioned herein, and on May 25, 2020, Defcñ±ñt CHRISTINA
FALGIANO was and isa resident of Richmond county, city and stateof New York.
9. That at all times mantioned herein, and on 2020,
D#=±=± CHRISTINA
May 25,
FALGIANO, owned the land, sidewalks, walkways paths and structures/premises thereon, commerdy
known as 21 Garth Court, Staten Island, New York.
10. That at all times menticñed herein, the Defendant HOLIDAY leased the land, sidewãlis.
wãlkways and paths and stmctures/premises nercm commonly known as 21 Garth Court, Staten Island,
New York.
11. That at all times mentioned herein, the Defendant CHRISTINA FALGIANO leased the
land, sidewalks, walkways and paths and structures/premises thereon, commonly known as 21 Garth
Court, Staten Island, New York.
12. That at all times =_wndend herein, the Dcfcñdant, HOLIDAY, operated the land,
sideweis, walkways, paths and pa-d=cwpremises commerly known as 21 Garth Court, Staten Island,
New York.
13. That at alltimes mentioned the DAdan+ CHRISTINA FALGIANO operated the
herein,
land, sidcwalks, walkwaya, paths and structures/prcmiscs located at 21 Garth Court, Staten 1sland, New
York.
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14. That at all times mentioned herein, the Defendânt HOLIDAY mãnay,cd the land,
sidew c, walkways, paths and premises/structures -^-'y known as 21 Garth Court, Staten Island,
New York.
15. That at all times mentioned herein, the Defced ñ± CHRISTINA FALGIANO mâñagcd
the land, aldowmlin, walkways, paths and premises/structures commonly known as 21 Garth Court, Staten
Island, New York.
16. That at all times amuGened herein, the Deféñd=t, HOLIDAY, controlled the land,
sidewalks, wallcways, paths, and premises/structures co1rúñcñIy known as 21 Garth Court, Staten Island,
2New York.
17. That at alltimes mentioned herein, the Defendant, CHRISTINA FALGIANO, controlled
the land, sidewalka, walkways, paths, and premises/structures commonly known as 21 Garth Court,
Staten Island, New York.
18. That at all times mentioned herein, the Defendant, HOLIDAY, m +=had the land,
sidewalks, wallcways, paths, premises/structures cc==sly known as 21 Garth Court, Staten Island, New
York.
19. That at alltimes mentieñed herein, the Defendant, CHRISTINA ñ÷+=ª=2
FALGIANO,
the land, sidewâlis, walkways, paths and premises/stractüros c===ily known as 21 Garth Court, Staten
Island, New York.
20. That at alltimes mentioned herein, the Defendant HOLIDAY, possessed and/or occupied
the land, sidewalks, walkways, paths and premises/structures cerce-nôñ1y known as 21 Garth Court, Staten
Island, New York,
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21. That at alltitnes mentioned herein, the Dafendent CHRISTINA FALGIANO possessed
and/or occupied the land, sida=alks, waliways, paths, premiscs/stisesas cos=ôdy known as 21 Garth
Court, Staten Island, New York.
22. That on or about Maý 25, 2020 while lawfully walking on the external
walkway/sidewalk/pathway leading to defed=.at's premiscs located at 21 Garth Court, Staten Island,
New York, the Plaintiff was caused to slip,trip and fall on a negligcñtly =i-tained and defective
property at, on, or near the concrctc/cement sidewalk/walkway/path.
23. That the above occurrence was caused solely by and through the negligence of the
defedants, their agents, servants and/or emplayces, herein, without any negligcacc on the partof the
Plaintiffcontributing thereto.
24. That the Defendsn+.a, had both actual and constructive notice of the dangcrous and
defective condi*ions and practices cerp=1=ed of herein,
25. That the defendants created the defective and dangerous condition.
26. That the defbada-t, and/or their agents, servants, a=sociates and/or employccs were
negligent, careless and reckless,in that they/it:
a) Negligently, carelessly and recklessly,failed and omitted to properly, shore, equip, guard,
arrange, operate and conduct itsactives at the aforemennoned premises; so as to provide reasonable and
adequate protection and safety to the panom therein,and more particularly to the Plaintiff herein;
b) Failed and omitted to provide the Plaintiffwith a safe place to walk;
c) Failed and omitted to insure that the area Plaintiffwas walking on at the aforanentioned
location was kept freeof hazardous conditions;
d) Failed and emitted to properly train & inspect their/itsemplayces at the aforementioned
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premises;
e) Failed and omitted to properly and adeqetely coordinate the activities of their/its
cmploycca with the public at large and more particularly the Plaintiff,
f) Failed and emined to construct and/or install barricades and/or other warnings so as to
apprise the public at large, and more particularly the Plaintiffherein, of the dangerous cc:2T::G existing
thereat;
g) Failed and omitted to properly secure the public areas so that Plaintiff could walk in
safety;
h) Failed to properly maintain and repair the aforesaid location;
i) Negligcidly and improperly =±th:d the concrete/cement sidewalk/walkway/path and
surróüñdir.g dirt/grass adjciiaiñg the sidewalk/walkway/path causing an unlevel and dangerous difference
in elevation, which created a dangerõüs and/or trap-like ceñdifies leading to the severe and permanent
injuries of the plaintiffherein.
27, That as a result of the negligcñcc of the defend=±, the Plaintiff,VICTOR CALDERON,
became, stillis and for a long time to come, will be sick, sore, lame, bruised, injured, disabled and
wounded in and about the various parts of his head, limbs, body, blood vessels and surrcsd's tissues,
and has suffered severe and extreme mental shock, añgaish and psychic injuries, and that Plaintiff was
other wise injured, and upon information and belief,said injuries are perm=nt That by reason of the
foregoing, the Plaintiff was obligated to and did acesssãrily employ medical aid, hospital services,
reediciñals and medical supplica in an attempt to cure the afarcsaid injuries, and has been prevented
from his usual duties and will be so prevented for a long time to come.
28. That by reason of the foregoing, the Plaintiff,VICTOR CALDBRON, has been damaged
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in an amount that exceeds the jurisdictional limits of alllower courts.
WHEREFORE, the Plaintiff VICTOR CALDERON, descris judgnicat against theDefenda_nts,
HOLIDAY VlLLAS AT OAKWOOD HOMEOWNERS ASSOCIATION, INC. AND CHRISTINA
FALGIANO, in an amount that exceeds the jurisdicticñal limits of all lower courts which would
otlierwise have jurisdiction, together with costs and disbursements of this action.
Dated: Staten Island, NewYork
October 15, 2020
f: Jd ph A. I Ago t o q.
CHELLI & BUSH
Attorneys for Plaintiff
149 New Dorp Lane
Staten Island, New York 10306
Tel. (718) 987-8444
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CLIENT VERIFICATION
STATE OF NEW YORK )
} as
COUNTY OF RICHMOND )
VICTOR CALDERON, being duty swom, deposes and states the following under the
penalties of perjury:
1 am the plaintiffin thewithin action.
1 have read the Verified Billof Part|cü¡sis and know the contents thereof. The same is
true to my know!edge.except as to those mattars herein stated to be alleged upon information
and belief,and upon those matters, 1 believe same to be true.
VICTOR CALDERON
Sworn to me this _
day of Octo¼gn 2020
tary Public, State of New Yo
MARVINO. UWANGUE
Notmy Public, stateof New York
Not 02UW6338770
Qualified in Richmond County
Commission Expires May16,2024
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Preview
FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 09/23/2021 EXHIBIT A FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF DOC.RICHMOND NO. 74 INDEX RECEIVED NO. NYSCEF:152018/2020 09/23/2021 FILED: COUNTY CLERK 11/05/2020 12 : 59 PMJ NY SCEF DOC . NO . 1 RECE IVED NY SCE F: 11/05/2020 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF RICHMOND ------------------------- --- ¬x SUMMONS VICTOR CALDERON, The basis of venue is: Plaintiff, PlaintitPs residence -against- Plaintiff's address: 401 Hett Avenue HOLIDAY VILLAS AT OAKWOODHOMEOWNERS Staten Island, NY 10306 ASSOCIATION, INC AND CHRISTINA FALGIANO, Defendants. _______............ .. -- -------X To the above named Defendant(s): You are hereby -rrnd to answer the complaint in this action, and to serve a copy of your answer, or, if the cõmplaint is not served with this summ_ens3 to serve a notice of appearmee on the Plaintiff's aticiscys within twenty days after the service of this sumacre, exclesive of the day of service, where service is made by delivery upon you persemlly within the state, or, within 30 days after completion of service where service is made in any other manner. In case of your failure to appear or answer, judgment will be taken against you by default for the reliefdemanded in the complaint. Dated: Staten Island, NY October 15, 2020 B :.io ph A. Agostino CHELLI & BUSH Attorney for Plaintiff 149 New Dorp Lane Staten Island, N.Y., 10306 (718) 987-8444 To: Holiday Villas Homeowners Association, Inc, 1610 Richmond Road . 1 of 9 FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF FILED DOC. : NO. RICHMOND74 COUNTY CLERK 12:59 PM1 RECEIVED INDEX NYSCEF: NO. 09/23/2021 152018/2020 11/05/2020_ NYSCEF DOC. NO. 1 . RECEIVED NYSCEF: 11/05/20 20 Staten Island, New York 10304 Holiday Villas Houmowners Association, Inc. 42 Vedder Avenue Staten Island, New York 10314 Christina Falgiano 21 Garth Court Staten Island, New York 10306 2 of 9 FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF DOC.RÌC-HMOND NO. 74 INDEX RECEIVED NYSCEF: NO. 152018 /2020 09/23/2021 FILED COUNTY CLERK 11/05/2020 12: 5 9 PM1 NY,SCEF DOC. NO. 1 RECEIVED NYSCEF: 11/05/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND -______.------.,--.--------------..x VICTOR CALDERON, VERIFIED COMPLAINT Plaintiff, Index No.: -against- HOLIDAY VILLAS AT OAKWOOD HOMEOWNERS ASSOCIATION, INC. AND CHRISTINA FALGIANO, Defendants. ---------------------------x Plaintiff, by her attorneys, CHELLI & BUSH, corep'eng of the Defcadants herein, respectfully sets forth and alleges to the Court as follows: AS AND FOR A FIRST CAUSE OF ACTION: L At the time of the commonvauent of this action, Plaintiff was a resident of the City and State of New York, County of Richmond. 2. That this action falls within one or more of the exemptions set forth in CPLR section 1602. 3. The cause of action alleged herein arose in the County of Richmo¾ State of New York. 4. On May 25, 2020, and at alltimes e-cñ ñed herein there existed a premises located at 21 Garth Court, Staten Island, NY, 5. That at all times men%nad herein, there existed a corporation known as HOLIDAY VILLAS AT OAKWOOD HOMEOWNERS ASSOCIATION, INC. which was orgsñir.ed and formed pursuant to the laws of the stateof New York, 6. That, at all times mentioned herein, and on May 25, 2020, the Defcadant, HOLIDAY 3 of 9 FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF DOC. NO. 74 INDEX RECEIVED NYSCEF: NO. 09/23/2021 152018/2020 ILED : RICHMOND COUNTY CLERK 11/05/2020 12 : 59 PM| NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/05/2020 V1LLAS AT OAKWOOD HOMEOWNERS ASSOCIATION, INC. (hereinafter referred to as "HOLIDAY"):rei-tained.its principal place of business in Richmond County, State of New York. 7. That at alltimes mentioned herein, and on May 25, 2020, the Defendant, HOLIDAY was the owner of the land, sidewalks, wallcways and pathsand structures/pamises thereon, cer-êrly known as 21 Garth Court, Staten Island, New York. 8. That at all times mentioned herein, and on May 25, 2020, Defcñ±ñt CHRISTINA FALGIANO was and isa resident of Richmond county, city and stateof New York. 9. That at all times mantioned herein, and on 2020, D#=±=± CHRISTINA May 25, FALGIANO, owned the land, sidewalks, walkways paths and structures/premises thereon, commerdy known as 21 Garth Court, Staten Island, New York. 10. That at all times menticñed herein, the Defendant HOLIDAY leased the land, sidewãlis. wãlkways and paths and stmctures/premises nercm commonly known as 21 Garth Court, Staten Island, New York. 11. That at all times mentioned herein, the Defendant CHRISTINA FALGIANO leased the land, sidewalks, walkways and paths and structures/premises thereon, commonly known as 21 Garth Court, Staten Island, New York. 12. That at all times =_wndend herein, the Dcfcñdant, HOLIDAY, operated the land, sideweis, walkways, paths and pa-d=cwpremises commerly known as 21 Garth Court, Staten Island, New York. 13. That at alltimes mentioned the DAdan+ CHRISTINA FALGIANO operated the herein, land, sidcwalks, walkwaya, paths and structures/prcmiscs located at 21 Garth Court, Staten 1sland, New York. 4 of 9 FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF FILED DOC. : NO. 74 RICIW1OND COUNTY CLERK 11/ 05/2020 12:59 PMI RECEIVED INDEX NYSCEF: NO. 09/23/2021 152018/2020 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/05/2020 14. That at all times mentioned herein, the Defendânt HOLIDAY mãnay,cd the land, sidew c, walkways, paths and premises/structures -^-'y known as 21 Garth Court, Staten Island, New York. 15. That at all times mentioned herein, the Defced ñ± CHRISTINA FALGIANO mâñagcd the land, aldowmlin, walkways, paths and premises/structures commonly known as 21 Garth Court, Staten Island, New York. 16. That at all times amuGened herein, the Deféñd=t, HOLIDAY, controlled the land, sidewalks, wallcways, paths, and premises/structures co1rúñcñIy known as 21 Garth Court, Staten Island, 2New York. 17. That at alltimes mentioned herein, the Defendant, CHRISTINA FALGIANO, controlled the land, sidewalka, walkways, paths, and premises/structures commonly known as 21 Garth Court, Staten Island, New York. 18. That at all times mentioned herein, the Defendant, HOLIDAY, m +=had the land, sidewalks, wallcways, paths, premises/structures cc==sly known as 21 Garth Court, Staten Island, New York. 19. That at alltimes mentieñed herein, the Defendant, CHRISTINA ñ÷+=ª=2 FALGIANO, the land, sidewâlis, walkways, paths and premises/stractüros c===ily known as 21 Garth Court, Staten Island, New York. 20. That at alltimes mentioned herein, the Defendant HOLIDAY, possessed and/or occupied the land, sidewalks, walkways, paths and premises/structures cerce-nôñ1y known as 21 Garth Court, Staten Island, New York, 5 of 9 FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF |FILED DOC. : NO. RICHMOND 74 COUNTY CLERK 11/05/2020 12: 59 RECEIVED INDEX NYSCEF: NO. 09/23/2021 152018 /2020 PM| NY SCEF DOC. NO. 1 RECEIVED NYSCEF : 11/ 05/2020 21. That at alltitnes mentioned herein, the Dafendent CHRISTINA FALGIANO possessed and/or occupied the land, sida=alks, waliways, paths, premiscs/stisesas cos=ôdy known as 21 Garth Court, Staten Island, New York. 22. That on or about Maý 25, 2020 while lawfully walking on the external walkway/sidewalk/pathway leading to defed=.at's premiscs located at 21 Garth Court, Staten Island, New York, the Plaintiff was caused to slip,trip and fall on a negligcñtly =i-tained and defective property at, on, or near the concrctc/cement sidewalk/walkway/path. 23. That the above occurrence was caused solely by and through the negligence of the defedants, their agents, servants and/or emplayces, herein, without any negligcacc on the partof the Plaintiffcontributing thereto. 24. That the Defendsn+.a, had both actual and constructive notice of the dangcrous and defective condi*ions and practices cerp=1=ed of herein, 25. That the defendants created the defective and dangerous condition. 26. That the defbada-t, and/or their agents, servants, a=sociates and/or employccs were negligent, careless and reckless,in that they/it: a) Negligently, carelessly and recklessly,failed and omitted to properly, shore, equip, guard, arrange, operate and conduct itsactives at the aforemennoned premises; so as to provide reasonable and adequate protection and safety to the panom therein,and more particularly to the Plaintiff herein; b) Failed and omitted to provide the Plaintiffwith a safe place to walk; c) Failed and omitted to insure that the area Plaintiffwas walking on at the aforanentioned location was kept freeof hazardous conditions; d) Failed and emitted to properly train & inspect their/itsemplayces at the aforementioned 6 of 9 FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF DOC. NO. 74 INDEX RECEIVED NO. NYSCEF:152018/2020 09/23/2021 |F ILED : RICHMOND COUNTY CLERK 11/05/2020 12:59 PM| NYSCEF 'DOC. NO. 1 RECEIVED NYSCEF: 11/05/2020 premises; e) Failed and omitted to properly and adeqetely coordinate the activities of their/its cmploycca with the public at large and more particularly the Plaintiff, f) Failed and emined to construct and/or install barricades and/or other warnings so as to apprise the public at large, and more particularly the Plaintiffherein, of the dangerous cc:2T::G existing thereat; g) Failed and omitted to properly secure the public areas so that Plaintiff could walk in safety; h) Failed to properly maintain and repair the aforesaid location; i) Negligcidly and improperly =±th:d the concrete/cement sidewalk/walkway/path and surróüñdir.g dirt/grass adjciiaiñg the sidewalk/walkway/path causing an unlevel and dangerous difference in elevation, which created a dangerõüs and/or trap-like ceñdifies leading to the severe and permanent injuries of the plaintiffherein. 27, That as a result of the negligcñcc of the defend=±, the Plaintiff,VICTOR CALDERON, became, stillis and for a long time to come, will be sick, sore, lame, bruised, injured, disabled and wounded in and about the various parts of his head, limbs, body, blood vessels and surrcsd's tissues, and has suffered severe and extreme mental shock, añgaish and psychic injuries, and that Plaintiff was other wise injured, and upon information and belief,said injuries are perm=nt That by reason of the foregoing, the Plaintiff was obligated to and did acesssãrily employ medical aid, hospital services, reediciñals and medical supplica in an attempt to cure the afarcsaid injuries, and has been prevented from his usual duties and will be so prevented for a long time to come. 28. That by reason of the foregoing, the Plaintiff,VICTOR CALDBRON, has been damaged 7 of 9 FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF DOC. NO. 74 INDEX RECEIVED NO. NYSCEF:152018/2020 09/23/2021 [FILED : RICHMOND COUNTY CLERK 11/ 05 / 2020 12:59 PM| NYSCEF'DOC. NO. 1 RECEIVED NYSCEF: 11/05/2020 : in an amount that exceeds the jurisdictional limits of alllower courts. WHEREFORE, the Plaintiff VICTOR CALDERON, descris judgnicat against theDefenda_nts, HOLIDAY VlLLAS AT OAKWOOD HOMEOWNERS ASSOCIATION, INC. AND CHRISTINA FALGIANO, in an amount that exceeds the jurisdicticñal limits of all lower courts which would otlierwise have jurisdiction, together with costs and disbursements of this action. Dated: Staten Island, NewYork October 15, 2020 f: Jd ph A. I Ago t o q. CHELLI & BUSH Attorneys for Plaintiff 149 New Dorp Lane Staten Island, New York 10306 Tel. (718) 987-8444 8 of 9 FILED: RICHMOND COUNTY CLERK 09/23/2021 11:54 AM INDEX NO. 152018/2020 NYSCEF DOC.RICHMOND NO. 74 INDEX RECEIVED NO. NYSCEF:152018/2020 09/23/2021 FILED: COUNTY CLERK 11/05/2020 12:59 PM| NYSCElf DOC. NO. 1 RECEIVED NYSCEF: 11/05/2020 CLIENT VERIFICATION STATE OF NEW YORK ) } as COUNTY OF RICHMOND ) VICTOR CALDERON, being duty swom, deposes and states the following under the penalties of perjury: 1 am the plaintiffin thewithin action. 1 have read the Verified Billof Part|cü¡sis and know the contents thereof. The same is true to my know!edge.except as to those mattars herein stated to be alleged upon information and belief,and upon those matters, 1 believe same to be true. VICTOR CALDERON Sworn to me this _ day of Octo¼gn 2020 tary Public, State of New Yo MARVINO. UWANGUE Notmy Public, stateof New York Not 02UW6338770 Qualified in Richmond County Commission Expires May16,2024 9 of 9