On October 31, 2014 a
Motion-Secondary
was filed
involving a dispute between
Trisha Haynes,
and
Burger King Corporation,
for T90 - Torts - All other
in the District Court of New Haven County.
Preview
Law Office
John P. Calabrese
500 Enterprise Drive, 2C
Rocky Hill, CT 06067
Tel. (860) 256-2222
Fax (860) 256-2251
Juris No. 419054
DOCKET NO: NNH CV 14 6050673-S : SUPERIOR COURT
TRISHA HAYNES : J.D. OF NEW HAVEN
VS. : AT NEW HAVEN
BURGER KING CORPORATION
Affidavit of Jose Ponce in Support of Motion For Summary Judgment
1. I, Jose Ponce am over the age of 18 years old and I believe in the obligations of an
oath.
2. Tama manager in the Compensation in People Services Department of Burger King
Corporation.
3. Tam fully familiar with the relationship between Burger King Corporation and it’s
Franchisees.
4. Lam fully familiar with the relationship between Burger King Corporation and
Northeast Foods LLC which was the Franchisee for the Burger King Restaurant
located at 1292, Boston Post Road in Milford, Connecticut on or about January 14,
2013.
5. Northeast Foods LLC, as a franchisee of Burger King Corporation is an independent
contractor and is not an agent, partner, joint venturer, joint employer or employee of
Burger King Corporation.
6. On or about January 14, 2013 Burger King Corporation did not employ anyone who
was working at the Burger King Restaurant located at 1292, Boston Post Road in
Milford, Connecticut. Said personnel working at said restaurant on said date would
have been employees of Northeast Foods LLC.
7. On or about January 14, Burger King Corporation and or it’s employees, agents or
servants did not sell any product to the plaintiff at the Burger King Restaurant located
at 1292, Boston Post Road in Milford, Connecticut.
8. Ifacup of coffee was sold to the plaintiff on or about January 14, 2013 at the Burger
King Restaurant located at 1292, Boston Post Road Milford, Connecticut, it was sold
to the plaintiff by Northeast Foods LLC.Law Office
John P, Calabrese
500 Enterprise Drive, 2C
Rocky Hill, CT 06067
Tel. (860) 256-2222
Fax (860) 256-2251
Juris No. 419054
9. Ifa lid was secured or fastened to the cup of coffee allegedly sold to the plaintiff on or
about January 14, 2013 it was secured or fastened to the cup of coffee by employees of
Northeast Foods LLC. ZA
JOSE PONCE
a
Subscribed and sworn to before me this .2/ ”_ day of _Cray 2015.
State of Florida rab Gadrade
County oF Miami -Dade, Notary Public/
Commissioner of the Superior Court
‘SHARALEA ANDRADE
MY COMMISSION 4 EE 209719
EXPIRES: June 20, 2016.
Bonded Thru Notary Public Uncervniters
Document Filed Date
May 27, 2015
Case Filing Date
October 31, 2014
Category
T90 - Torts - All other
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Law Office John P. Calabrese 500 Enterprise Drive, 2C Rocky Hill, CT 06067 Tel. (860) 256-2222 Fax (860) 256-2251 Juris No. 419054 DOCKET NO: NNH CV 14 6050673-S : SUPERIOR COURT TRISHA HAYNES : J.D. OF NEW HAVEN VS. : AT NEW HAVEN BURGER KING CORPORATION Affidavit of Jose Ponce in Support of Motion For Summary Judgment 1. I, Jose Ponce am over the age of 18 years old and I believe in the obligations of an oath. 2. Tama manager in the Compensation in People Services Department of Burger King Corporation. 3. Tam fully familiar with the relationship between Burger King Corporation and it’s Franchisees. 4. Lam fully familiar with the relationship between Burger King Corporation and Northeast Foods LLC which was the Franchisee for the Burger King Restaurant located at 1292, Boston Post Road in Milford, Connecticut on or about January 14, 2013. 5. Northeast Foods LLC, as a franchisee of Burger King Corporation is an independent contractor and is not an agent, partner, joint venturer, joint employer or employee of Burger King Corporation. 6. On or about January 14, 2013 Burger King Corporation did not employ anyone who was working at the Burger King Restaurant located at 1292, Boston Post Road in Milford, Connecticut. Said personnel working at said restaurant on said date would have been employees of Northeast Foods LLC. 7. On or about January 14, Burger King Corporation and or it’s employees, agents or servants did not sell any product to the plaintiff at the Burger King Restaurant located at 1292, Boston Post Road in Milford, Connecticut. 8. Ifacup of coffee was sold to the plaintiff on or about January 14, 2013 at the Burger King Restaurant located at 1292, Boston Post Road Milford, Connecticut, it was sold to the plaintiff by Northeast Foods LLC.Law Office John P, Calabrese 500 Enterprise Drive, 2C Rocky Hill, CT 06067 Tel. (860) 256-2222 Fax (860) 256-2251 Juris No. 419054 9. Ifa lid was secured or fastened to the cup of coffee allegedly sold to the plaintiff on or about January 14, 2013 it was secured or fastened to the cup of coffee by employees of Northeast Foods LLC. ZA JOSE PONCE a Subscribed and sworn to before me this .2/ ”_ day of _Cray 2015. State of Florida rab Gadrade County oF Miami -Dade, Notary Public/ Commissioner of the Superior Court ‘SHARALEA ANDRADE MY COMMISSION 4 EE 209719 EXPIRES: June 20, 2016. Bonded Thru Notary Public Uncervniters