On March 22, 2019 a
AFFIRMATION OF GOOD FAITH (Motion #3) - Good Faith Affirmation in Support of Motion
was filed
involving a dispute between
Delfina Warrick,
and
Osric King,
for Matrimonial - Uncontested
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 10/01/2021 11:34 AM INDEX NO. 514351/2019
NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 10/01/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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ARIADNI CORDERO, Index No.: 514351/19
Plaintiff,
-against- GOOD FAITH
AFFIRMATION
HP MARCUS GARVEY PRESERVATION
HOUSING COMPANY, INC. and C&C APARTMENT
MANAGEMENT, LLC,
Defendants.
--------------------------------------------------------------------X
Theodore W. Ucinski, an attorney duly licensed to practice law before the court’s of the
state of New York, hereby affirms the following to be true under the penalty of perjury:
1. I am a member of the law offices of Goldberg Segalla, LLP, counsel for defendants,
HP Marcus Garvey Preservation Housing Company, Inc. and C & C Apartment Management,
LLC. As such, I am fully familiar with the facts and circumstances of this matter.
2. I make this affirmation in support of the within motion which seeks to dismiss
plaintiff’s complaint.
3. I forwarded plaintiff multiple good faith letters asking for all gynecological treatment
both pre and post-accident and plaintiff failed to respond to same.
4. Based upon the foregoing, it is respectfully requested that the Court issue an Order
dismissing plaintiff’s complaint and for such other, further and different relief as the court deems
just, proper and equitable.
Dated: Garden City, New York
October 1, 2021
______________________________
THEODORE W. UCINSKI
31235319.v1
1 of 2
FILED: KINGS COUNTY CLERK 10/01/2021 11:34 AM INDEX NO. 514351/2019
NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 10/01/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------X
ARIADNI CORDERO, Index No.: 514351/19
Plaintiff, CERTIFICATION OF
WORD COUNT
-against-
HP MARCUS GARVEY PRESERVATION
HOUSING COMPANY, INC. and C&C APARTMENT
MANAGEMENT, LLC,
Defendants.
--------------------------------------------------------------------X
Pursuant to Rule 33.1(h) of the Rules of this Court, I certify that the accompanying Good
Faith Affirmation, which was prepared using Times New Roman 12-point typeface, contains 150
words (excluding the caption and the signature lines). This certificate was prepared in reliance on
the word-count function of the word processing system (Microsoft Word) used to prepare the
document.
I declare under the penalty of perjury that the foregoing is true and correct.
Dated: Garden City, New York
October 1, 2021
__________________________________
Theodore W. Ucinski
31235319.v1
2 of 2
Preview
FILED: KINGS COUNTY CLERK 10/01/2021 11:34 AM INDEX NO. 514351/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 10/01/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------X ARIADNI CORDERO, Index No.: 514351/19 Plaintiff, -against- GOOD FAITH AFFIRMATION HP MARCUS GARVEY PRESERVATION HOUSING COMPANY, INC. and C&C APARTMENT MANAGEMENT, LLC, Defendants. --------------------------------------------------------------------X Theodore W. Ucinski, an attorney duly licensed to practice law before the court’s of the state of New York, hereby affirms the following to be true under the penalty of perjury: 1. I am a member of the law offices of Goldberg Segalla, LLP, counsel for defendants, HP Marcus Garvey Preservation Housing Company, Inc. and C & C Apartment Management, LLC. As such, I am fully familiar with the facts and circumstances of this matter. 2. I make this affirmation in support of the within motion which seeks to dismiss plaintiff’s complaint. 3. I forwarded plaintiff multiple good faith letters asking for all gynecological treatment both pre and post-accident and plaintiff failed to respond to same. 4. Based upon the foregoing, it is respectfully requested that the Court issue an Order dismissing plaintiff’s complaint and for such other, further and different relief as the court deems just, proper and equitable. Dated: Garden City, New York October 1, 2021 ______________________________ THEODORE W. UCINSKI 31235319.v1 1 of 2 FILED: KINGS COUNTY CLERK 10/01/2021 11:34 AM INDEX NO. 514351/2019 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 10/01/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------X ARIADNI CORDERO, Index No.: 514351/19 Plaintiff, CERTIFICATION OF WORD COUNT -against- HP MARCUS GARVEY PRESERVATION HOUSING COMPANY, INC. and C&C APARTMENT MANAGEMENT, LLC, Defendants. --------------------------------------------------------------------X Pursuant to Rule 33.1(h) of the Rules of this Court, I certify that the accompanying Good Faith Affirmation, which was prepared using Times New Roman 12-point typeface, contains 150 words (excluding the caption and the signature lines). This certificate was prepared in reliance on the word-count function of the word processing system (Microsoft Word) used to prepare the document. I declare under the penalty of perjury that the foregoing is true and correct. Dated: Garden City, New York October 1, 2021 __________________________________ Theodore W. Ucinski 31235319.v1 2 of 2