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  • Robert Moore v. Starrett City, Inc. Torts - Motor Vehicle document preview
						
                                

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THENOLANLAw FIRM A GENERAL LAW PRACTICE 444 EAST 75TH STREET NEW YORK, NEW YORK 10021 15TH FLOOR WILLIAM PAUL NOLAN, ESQ TELEPHONE E-MAIL (212) 308-3456 WPN@ATTORNEYSNEWYORK.COM TELECOPIER CELL (212) 879-6806 (917) 570-0297 September 10, 2018 Justice Peter P. Sweeney Kings County Supreme Court 360 Adams Street Brooklyn, New York 11201 Re: Moore v. Starrett City, Inc. Supreme Court, Kings County, Index #518485/2017 Justice Sweeney: Plaintiff's Motion to Amend the Complaint was submitted today. After mailing Plaintiff's Reply Affirmation, Plaintiff found Defendant's employee, Margarita Santiago's attached New York Vehicles' Department of Motor Abstract of Driving Record, which states that in addition to Santiago's 2 speeding in zone violations and 1 failure to wear seat belt violation, Santiago had a second seat belt violation. Defendant's Affirmation in Opposition at $7 affirms that Santiago had 1 seat belt violation. Respe t -s,ubmitted/ Wifliam Paul Nolan cc: Eustace, Marquez, Epstein, Perzioso & Yapchanyk Nicoletti Goson Spinner Ryan Gulino Pinter LLP