Party Statement: Justin Deprospo an infant by his Mother and Natural Guardian EILEEN SANTIAGO and EILEEN SANTIAGO, Individually, Jennifer Santiago Administratrix of the Estate of Richard Santiago, Eileen Santiago Haddock Individually and as Parent and Natural Guardian for Minor Children, JEREMIAH RICHARD SANTIAGO and MATTHEW RICHARD SANTIAGO v. Michelle Nixon-Cochran, General Baito Automotive Warehouse, Inc., Baito General Auto Equipment, Inc., Hector Nunez, D/B/A General Baitoa Auto Parts, Edward Turner, 450 Concord Avenue Corp., D/B/A General Baito, Concord Avenue Llc

On February 08, 2022 a Party Statement was filed involving a dispute between Eileen Santiago Haddock Individually And As Parent And Natural Guardian For Minor Children, Jeremiah Richard Santiago And Matthew Richard Santiago, Jennifer Santiago Administratrix Of The Estate Of Richard Santiago, Justin Deprospo An Infant By His Mother And Natural Guardian Eileen Santiago And Eileen Santiago, Individually, and 450 Concord Avenue Corp., D B A General Baito, Baito General Auto Equipment, Inc., Concord Avenue Llc, Edward Turner, General Baito Automotive Warehouse, Inc., Hector Nunez, D B A General Baitoa Auto Parts, Michelle Nixon-Cochran, for Torts - Motor Vehicle in the District Court of Bronx County.

Preview
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NYSCEF DOC. NO. 95 RECEIVED NYSCEF: 08/24/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
-----------------------------------------------------------X
JUSTIN DePROSPO, an infant by his mother and guardian
EILEEN SANTIAGO and EILEEN SANTIAGO, Index #: 350720/2009

individually, (Action # 1)

Plaintiffs,
AFFIRMATION IN
-against- OPPOSITION

MICHELLE NIXON-COCHRAN, GENERAL BAITOA
AUTOMOTIVE WAREHOUSE, INC., BAITOA GENERAL
AUTO EQUIPMENT INC., HECTOR NUNEZ, d/b/a
GENERAL BAITOA AUTO PARTS, EDWARD TURNER,
450 CONCORD AVENUE CORP., d/b/a GENERAL
BAITOA, and CONCORD AVENUE, LLC,

Defendants.
-------------------------------------------------------------X
JENNIFER SANTIAGO, as the Administratrix of the Index No. 301290/2010
Estate of RICHARD SANTIAGO, and EILEEN (Action # 2)
SANTIAGO HADDOCK, Individually and as Parent and
Natural Guardian for Minor Children, JEREMIAH RICHARD
SANTIAGO and MATTHEW RICHARD SANTIAGO,

Plaintiffs,

-against-

MICHELLE NIXON-COCHRAN, GENERAL BAITOA
AUTOMOTIVE WAREHOUSE, INC., BAITOA GENERAL
AUTO EQUIPMENT INC., HECTOR NUNEZ, d/b/a
GENERAL BAITOA AUTO EQUIPMENT CO., HECTOR
NUNEZ D/B/A GENERAL BAITOA AUTO PARTS,

Defendants.
----------------------------------------------X

TOBI R. SALOTTOLO, an attorney duly licensed to practice law in the State of New

York, subscribing and affirming as true, under penalties of perjury, states as follows:

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1. I am associated with the law firm of Proner & Proner, the attorney for the

plaintiffs, JUSTIN DePROSPO and EILEEN SANTIAGO, and as such am fully familiar with all

of the pleadings and proceedings heretofore had in these actions.

2. This affirmation is being submitted in opposition to the motion by the defendants

GENERAL BAITOA AUTOMOTIVE WAREHOUSE, INC., BAITOA GENERAL AUTO

EQUIPMENT, INC., and 450 CONCORD AVENUE CORP. d/b/a GENERAL BAITOA

(hereinafter referred to collectively as "BAITOA") for an order granting said defendants leave to

reargue their motion for summary judgment under CPLR §2221(d) and, upon granting BAITOA

leave to reargue, granting said defendants motion for summary judgement under CPLR §3212

plaintiffs'
dismissing complaint and all cross-complaints on the ground that the defendant

MICHELLE NIXON-COCHRAN (hereinafter referred to as "NIXON-COCHRAN") was acting

as an independent contractor and not as an agent, servant and/or employee of BAITOA when the

incident out of which this cause of action arose took place.

3. All the exhibits which have been submitted by the defendants BAITOA in support

of their motion are incorporated herein by reference, including the transcripts of the deposition

testimony of NIXON-COCHRAN and BAITOA's president, Kenneth Maurer, and the statement

that NIXON-COCHRAN gave to the police at the accident scene, copies of which are also

"B" "C"
annexed hereto and marked Exhibits "A", and respectively.

4. This case was restored to the Trial Calendar on October 8, 2021, by way of the

filing of a Note of Issue. Pursuant to the Rules of this Part, the deadline to file a motion for

summary judgment is 60 days after the filing of the Note of Issue.

5. Itmust be noted that the defendant, NIXON-COCHRAN, whose cross-motion for

summary judgment was also denied by Order of this Honorable Court dated July 5, 2022 and

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whose original cross-motion was in fact untimely as the same was not filed until January 18,

2022 and on entirely different grounds than BAITOA, has neither filed a motion for leave to

reargue or a notice of appeal from said Order at thistime.

6. The defendant BAITOA's original motion which sought summary judgment on

the ground that NIXON-COCHRAN was an independent contractor was served on December 7,

2021, and, even though plaintiffs initially conceded that itwas timely filed, itappears that the

motion could be considered untimely on the ground that, as admitted by BAITOA's counsel in

their motion for leave to reargue, BAITOA's initial notice of motion was filed without a return

date and an amended notice of motion had to be filed but was not done until December 21, 2021

which is beyond the 60 day period allowed for filing dispositive motions. The plaintiffs leave it

up to the Court to decide whether or not BAITOA's motion was timely.

7. Should the Court find BAITOA's motion timely and grant leave to reargue their

plaintiffs'
motion for summary judgment, the argument in opposition to BAITOA's summary

judgment motion is set forth below:

ARGUMENT IN OPPOSITION TO BAITOA'S MOTION FOR
SUMMARY JUDGMENT

PRELIMINARY STATEMENT

8. The plaintiffs commenced this action to recover for serious personal injuries

which were sustained by the plaintiff, JUSTIN DePROSPO, when the motorcycle on which he

was a passenger collided with the rear of NIXON-COCHRAN's double parked vehicle as

NIXON-COCHRAN was making a delivery for BAITOA. As will be set forth herein, the

evidence in the record raises genuine factual issues as to whether BAITOA has sufficient input

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into the method and manner in which NIXON-COCHRAN performed her job to render her an

employee, as opposed to an independent contractor, at the time of the accident.

9. The Courts of this State have repeatedly held that the issue of "whether an

operator of a delivery vehicle is an agent, potentially rendering the principal liable under the

fact."
doctrine of respondeat superior, or an independent contractor, is a question for the trier of

Carrion v. Orbit Messenger, 82 N.Y.2d. 742, 744 (1983); Rivera v. Fenix Car Servi. Corp., 81

(2nd (2nd
A.D.3d 622, 623 Dep't. 2011); Sigh v. Sukhu, 180 A.D.3d 834 Dep't. 2020).

10. Although one would never know it from reading BAITOA's moving papers, it is

well settled that the existence of an agreement labelling a delivery driver as an "independent

contractor"
is not dispositive on the issue of whether a party is an independent contractor or

employee, but rather merely a factor to be weighed with other factors which indicate control such

as whether the worker (1) worked at [her or]his own convenience, (2) was free to engage in other

employment, (3) received fringe benefits, (4) was on the employer's payroll, and (5) was on a fixed

schedule."
Bynog v Cipriani Group, 1 NY3d 193, 198, (2003); D.S v. Positive Behavior Support

(2nd
Consulting & Psychological Res., P.C., 197 A.D.3d 518, 520 Dep't 2021); _ Nachman v

(2nd
Koureichi, 165 AD3d 818, 820 Dep't. 2018).

11. In its moving papers, the defendant BAITOA does not even attempt to deny that

NIXON-COCHRAN was negligent in double parking her vehicle or that the double-parked vehicle

was a substantial contributing factor in causing the accident. Instead, it claims it is entitled to

summary judgment solely on the ground that NIXON-COCHRAN was acting as an independent

contractor, rather than an employee, when she was making the delivery. In advancing that

argument, BAITOA has neglected to advise the Court that NIXON- COCHRAN testified that she

worked on a fixed schedule, received specific instructions from BAITOA as to how to make the

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workers'
delivery at issue, and received compensation benefits in connection with the injuries she

sustained while making the delivery.

12. Although BAITOA tried to prevent plaintiff from ascercaining whether or not it

workers'
afforded compensation benefits to NIXON-COCHRAN, itwas eventually compelled

by way of a court order to furnish an affidavit from itsinsurance carrier, a copy of which is

annexed hereto and marked Exhibit "D", attesting to the fact that it did in fact pay both medical

workers'
and indemnity compensation benefits to NIXON-COCHRAN in connection with the

injuries she sustained in the incident out of which this cause of action arose. BAITOA's

reluctance to furnish this information voluntarily was undoubtedly because only employees, and

workers'
not independent contractors, are entitled to receive compensation benefits. In re

Renouf 254 N.Y. 349 (1930).

13. When she was deposed, NIXON-COCHRAN made itclear that in addition to

workers'
paying her compensation benefits in connection with the accident, BAITOA fixed her

schedule, which required her to work six days a week and request time off two days in advance.

"A"
(Ex. 12:5-12; 18:17-25; 133:6-21). She also testified that she had already finished her

"boss"
assigned deliveries for the day, when she was instructed by her at BAITOA to make a

delivery for him on her way home and told that the recipient would be standing outside waiting

"A"
for her. (Ex. 22:20-23:17). The law is clear that under circumstances such as these, the issue

of whether NIXON-COCHRAN was acting as an agent of BAITOA or an independent

contractor at the time of the accident is a factual one that must be left to the jury to decide.

COUNTER STATEMENT OF RELEVANT FACTS

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14. NIXON-COCHRAN began working for BAITOA about four or five months

before the accident as a driver making deliveries of parts to various auto mechanic shops and

"A" NIXON-
dealers. (Ex. 11:18-21, 12:20-25). While itis certainly true that BAITOA required

contractor"
COCHRAN to sign an operator's agreement that stated she was an "independent in

order to obtain employment, itsclaim that she set her own schedule, and just appeared at

BAITOA's office whenever she chose to, is a complete fabrication.

15. Notwithstanding the allegations set forth in BAITOA's moving papers to the

contrary, NIXON-COCHRAN's work schedule and the schedules of the other drivers was set by

"A"
BAITOA. (Ex, 12:9-12). Drivers were told they must report to work at 8:30 A.M. and the

workday ended after they had made their lastdelivery for the day which would usually be

"A"
between 4:30 and 5:00 P.M. (Ex. 12:5-12). NIXON-COCHRAN and about fifteen other

employees would report to work every day between 8:15 A.M. and 8:20 A.M and sit in a room

waiting to get their delivery assignments. (Ex. "A", pgs. 18: 17-25). They worked six days per

days'
week, Monday through Saturday, and had to give at leasttwo notice if they wanted to take

"A"
a day off. (Ex. 133:6-21). In addition, as has already been set forth herein, itis undisputed

that NIXON-COCHRAN received worker's compensation benefits in connection with the

injuries she sustained in the accident out of which this cause of action arose. (Ex. "D").

16. BAITOA's delivery drivers were given a route with an address and invoice, and

they would then have to check the parts with the invoice. (Ex. "A", p. 13, lines 10-14). At the

end of the workday, drivers were required to provide BAITOA with a copy of the invoice for

every delivery that they had made so BAITOA could match itagainst their records as to what

"B" NIXON-
had been dispatched out. (Ex. 26:3-8). All the BAITOA employees, including

COCHRAN, used their own vehicles to make the deliveries. (Ex. "A", p. 14, lines 5-8).

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NIXON-COCHRAN was paid on a weekly basis either in cash or by a check bearing the

company's name and did not receive a W-2. (Ex. "A", p. 16, lines 7-11; p. 84, lines 6-22).

17. NIXON-COCHRAN testified that the accident took place at the end of the

"A"
workday after "everyone was off the clock". (Ex. 22:20-21, 74:20-24). She was leaving to

go home and take her kids shopping when her boss called her back in and asked her to make a

"A"
delivery for him on her way home. (Ex. 22:20-21; 74:20-24). The pertinent portion of her

testimony reads as follows:

A. I remember leaving the job. It was the last.....everybody else had left,and itwas like

three gentlemen left with my boss. I was on my way home. He had one call. He
Michele?"
called me back in.He said, "Could you do this on your way home for me,
I said "Sure", took it.
He said, "The owner is going to be standing out in the front when you get there,
leave."
because it's late and he's ready to
"Fine."
And I said I took itright over there.
I seen-I can't think of the guy's name. He was standing in the front. He waved

me down when he saw me coming down the block, so I pulled right up to him. I
rolled my window down, I hand him his box, his invoice, he signed it,he ripped it,
gave itback, and said, "Have a good weekend, Michele".
you."
I said, "Same to
"A"
And all of a sudden, I feltboom, and that is it.(Ex. 22:20-23:17).

18. When she was deposed, NIXON-COCHRAN initially denied that she was double

parked at the time of the accident, but upon further questioning readily admitted that she wasn't

"A"
sure if her vehicle was stopped more than 15 feet away from the curb or not. (Ex. 28:18-20,

away"
37:7-38:5). She also asked if she could say that she was "one car from the curb, because

there" "A" 39:10-
there "was a car right when she "pulled up to where the gentleman was". (Ex.

40:4). When shown the statement which she had given to the police at the time of the accident

(Ex. "C"), NIXON-COCHRAN admitted that she told the police at the accident scene that she

"A"
was "double parked making a delivery for GENERAL BAITOA". (Ex. 56:24-58:11). Then

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when asked again ifshe was double parked at the time of the accident, NIXON-COCHRAN

parked"
changed her prior testimony and responded, "I believe I was double and then went on to

"A"
testify she was stopped to the left of a parked red/burgundy car. (Ex. 58:15-19, 80:5-21).

She also readily admitted that there was a driveway she could have gone into but instead she

"A"
pulled up to the man her boss had told her would be waiting for her. (Ex. 49:20-23). The

police report, a copy of which is annexed hereto and marked Exhibit "E", indicates that the

reporting officer concluded that improper lane usage by NIXON-COCHRAN was a contributing

accidentl
factor to the and cited her for a violation of NYCRR 4-07-B1 which reads as follows:

(b) Obstruction of traffic.

(1) Traffic lane. No person shall operate a vehicle in a manner which obstructs trafficin
lanes specifically designated for the movement of traffic.
Such lanes include, but are not limited
to, no standing zones and no stopping zones.

19. When he was deposed, the president of GENERAL BAITOA, Kenneth Maurer,

workers'
readily admitted that NIXON-COCHRAN had filed a compensation claim in

workers'
connection with the accident and that he learned of the accident from the compensation

"B" workers'
carrier. (Ex. 20:3-8; 13:17-22). However, when questioned as to how the

workers'
compensation claim was resolved and as to who the compensation carrier was, Mr.

Maurer claimed not to know. (Ex "B", 20: 9 -23; 32: 7 -11). In itsinitial discovery response, a

copy of which is annexed hereto and marked Exhibit "F", BAITOA indicated that itsliability

carrier was Utica National Insurance Group. When asked at his deposition if Utica was also the

workers' "B"
compensation carrier, Mr. Mauer responded that itwas not. (Ex. 41:10-13).

1 Improper"
The reporting officerinserted the # 13 in box #21 indicatingthat "Passing or Lane Usage was an
apparent contributing factor to the accident.

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20. Immediately following Mr. Mauer's deposition, plaintiff served the defendant

BAITOA and the defendant NIXON-COCHRAN with post-deposition discovery demands

workers'
seeking information relevant to NIXON-COCHRAN's compensation claim, copies of

"G" "H"
which are annexed hereto and marked Exhibits and respectively. The demand which

was directed to the defendant NIXON-COCHRAN sought the production of any records in her

workers'
possession relevant to her compensation claim as well as HIPAA authorizations

Workers' workers'
addressed to the Compensation Board and her compensation carrier. On

the defendant NIXON- COCHRAN's counsel responded to the demands for
May 10, 2016,

workers' applicable"
compensation records and authorizations simply by stating "not without

offering any explanation as to why. The discovery demand which was directed to BAITOA

workers'
sought the production of all compensation records, orders and judgments pertaining to

workers'
the compensation claim filed by NIXON-COCHRAN against BAITOA as well as any

workers'
records pertaining to NIXON-COCHRAN's compensation claim. BAITOA never

responded to the demand.

21. On November 28, 2016, plaintiff made a motion for an order directing that the

answers of the defendants NIXON-COCHRAN and BAITOA be stricken unless they responded

to the foregoing discovery demands by either furnishing the documents requested in said

demands or an affidavit stating why said documents could not be furnished. The moving papers

made itclear that confirmation of whether BAITOA's insurance carrier has paid workers

compensation benefits to NIXON-COCHRAN in connection with the accident was relevant

because itwas a factor to be considered when determining whether NIXON-COCHRAN was

acting as an agent, servant and/or employee of BAITOA or an independent contractor since if

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workers'
she was truly an independent contractor, BAITOA would not be obligated to pay her

compensation benefits.

22. On January 20, 2017, the parties resolved the motion by entering into a stipulation

which provided that the defendant NIXON -COCHRAN would provide HIPAA compliant

workers'
authorizations for those portions of her no-fault and compensation files with regard to

allreferences to her employment status within 60 days. Subsequent to the signing of the

stipulation, your affirmant's office was advised by counsel for NIXON-COCHRAN that they

could not forward the authorizations as required by the stipulation because they could not locate

NIXON-COCHRAN. NIXON-COCHRAN's insurance carrier did, however, furnish your

affirmant's office with an ISO claim search, a copy of which is annexed hereto and marked

Exhibit "I", which indicated that despite Mr. Mauer's sworn testimony to the contrary, Utica

workers'
Mutual was in fact BAITOA's compensation carrier, that the adjuster was Carol A.

Hines, and that the claim number was 1033846.

23. Upon receipt of the ISO claim search, yóur affirmant's office served Utica Mutual

with a subpoena duces tecum, a copy of which is annexed hereto and marked Exhibit "J", which

sought "those portions of your filepertaining to the Worker's Compensation Claim which was

filed by Michele Nixon-Cochran in connection with an accident that took place on August 7,

2009 bearing claim number 1033846 that relate to a determination as to whether or not Michele

Nixon-Cochran was an employee of your insured, General Baitoa, at the time of said accident".

Rather than complying with the subpoena, Utica moved to quash it.

24. In addition to opposing the motion to quash, the plaintiff made a cross-motion for

an order directing Utica Mutual to furnish the plaintiff with a sworn statement either confirming

workers'
or denying that itpaid compensation benefits to Michelle-Nixon Cochran in connection

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with injuries she sustained in an accident that took place on August 7, 2009 and setting forth the

name of the insured on whose behalf those benefits were either paid or denied. On June 13,

2018, the Hon. Norma Ruiz issued an order, a copy of which is annexed hereto and marked

Exhibit "K", directing Utica Mutual Insurance Company to provide the plaintiff with the sworn

statement. Shortly thereafter, on August 6, 2018, which was more than two years after plaintiffs

workers'
had made their initial request for the compensation information, Utica National

Insurance Company finally furnished an affidavit stating that "Michelle Nixon-Cochran has been

collecting both medical and indemnity worker's compensation benefits....effective April 1, 2009

to April 1, 2010, from General Baitoa Automotive Warehouse, Inc. arising out of an accident

2009."
that is alleged to have occurred on August 7, (Ex. "D").

ARGUMENT

THE EVIDENCE IN THIS CASE IS SUCH THAT A DETERMINATION AS TO
WHETHER NIXON-COCHRAN WAS ACTING AS AN INDEPENDENT
CONTRACTOR OR AN EMPLOYEE OF BAITOA AT THE TIME OF THE
ACCIDENT IS A FACTUAL ONE THAT MUST BE LEFT TO THE JURY TO
DECIDE.

25. Because a motion for summary judgment is the functional equivalent of a trial,it

must not be granted if there is any doubt as to the existence of a triable issue and the Court's

finding," determination"
function is limited to "issue not "issue [Rotuba Extruders v. Ceppos, 46

NY2d 223 (1977); Sillman v. Twentieth Century Fox Film, 3 NY2d 395, 144 N.E.2d 387, 165

N.Y.S.2d 498 (1957). In accordance with that harsh standard, the "movant bears the heavy

burden of establishing "a prima facie showing of entitlement to judgment as a matter of law,

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tendering sufficient evidence to demonstrate the absence of any material issues of fact'". Deleon

v New York City Sanitation Dept., 25 NY3d 1102, 1106, quoting Alvarez v Prospect Hosp., 68

NY2d 320, 324 (1986); see Winegrad v New York Univ. Med. Or., 64 NY2d 851, 853 (1985);

Zuckerman v City of New York, 49 NY2d 557, 562(1980). The evidence which the defendant

BAITOA has submitted in support of itsmotion clearly fails to meet that burden.

26. The Courts of this State, including the Court of Appeals, have repeatedly held that

in most instances the issue of "whether an operator of a delivery vehicle is an agent, potentially

rendering the principal liable under the doctrine of respondeat superior, or an independent

fact."
contractor, is a question for the trier of Carrion v. Orbit Messenger, 82 N.Y.2d. 742, 744

(2nd
(1983); see also Rivera v. Fenix Car Servi. Corp., 81 A.D.3d 622, 623 Dep't. 2011); Sigh v.

(2nd
Sukhu, 180 A.D.3d 834 Dep't. 2020). The Court of Appeals has also made it clear that the

"
fact that there is an agreement labelling a delivery driver as an "independent contractor is not

dispositive on the issue of whether a party is an independent contractor or employee, but rather

merely a factor to be weighed with others. Carlson v. American Int. Group, Inc., 30 N.Y.3d 288,

301 (2017); see also D.S v. Positive Behavior Support Consulting & Psychological Res., P.C., 197

(2nd
A.D.3d 518 Dep't 2021) [The fact that a contract exists designating a person as an independent

contractor is to be considered but is not dispositive]. Araneo v Town Bd. for Town of Clarkstown,

(2nd
55 AD3d 516, 518 Dep't. 2008) ; Shanklin v Wilhelmina Models, Inc., 161 AD3d 610, 611,

(1" (2nd
Dep't. 2018); Hernandez v Chefs Diet Delivery, LLC, 81 AD3d 596, 599 Dep't. 2011).

27. It is well settled that "(w)hether the relationships of the operators-deliverers with

the delivery companies is that of employees or independent contractors involves a question of fact

as to whether there is evidence of either control over the results produced or over the means used

results."
to achieve the Matter of Rivera (State Line Delivery Serv.-Roberts) 69 NY2d 679, 682

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(1986); Carlson, supra at 301. Itis equally well settled that "(f)actors relevant to assessing control

include whether the worker (1) worked at [her or] his own convenience, (2) was free to engage in

other employment, (3) received fringe benefits, (4) was on the employer's payroll, and (5) was on

schedule."
a fixed Bynog v Cipriani Group, 1 NY3d 193, 198, (2003); D.S v. Positive Behavior

(2nd
Support Consulting & Psychological Res., P.C., 197 A.D.3d 518, 520 Dep't 2021); Nachman

(2nd
v Koureichi, 165 AD3d 818, 820 Dep't. 2018).

28. In the case at hand, there is evidence that NIXON-COCHRAN was on a fixed

schedule that required her to report to work six days a week, work an eight-hour day, and request

time off at least two days in advance. In addition, itis undisputed that she was afforded the fringe

workers'
benefit of receiving the compensation medical and indemnity benefits to which only

and not independent are entitled. It is also undisputed that NIXON-
employees, contractors,

COCHRAN was specifically instructed by her boss to deliver the package to a gentleman who

would be waiting outside on the street for it,and that in accordance with those instructions she

double parked and rolled down her window when she saw the gentleman waving at her. The law

is clear, that under circumstances such as these, the issue of whether NIXON-COCHRAN was

acting as an employee of BAITOA or an independent contractor at the time of the accident is a

factual one that must be left to the jury to decide. Carrion, supra; Rivera, supra; Sigh, supra;

Carlson, supra; Bynog, supra; D.S v. Positive Behavior Support Consulting & Psychological Res.,

supra; Hernandez, supra; Matter of Rivera, supra; Nachman, supra.

CONCLUSION

29. The relevant case law makes itclear that the issue of whether NIXON-COCHRAN

was acting as an independent contractor or an employee of the defendant BAITOA when she

double parked her vehicle is a factual one that must be left to a jury to decide.

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Case Info

Case No.

(Subscribe to View)

Document Filed Date

August 24, 2022

Case Filing Date

February 08, 2022

County

Parties

450 CONCORD AVENUE CORP., d/b/a GENERAL BAITO Defendant
BAITO GENERAL AUTO EQUIPMENT, INC. Defendant
BROWN, DAVID ALEXANDER Attorney for the Defendant
BUONO, ANTHONY JAMES Attorney for the Defendant
CAMACHO, ANDREA S Attorney for the Defendant
CHAIFETZ, LAWRENCE B Attorney for the Plaintiff
CONCORD AVENUE LLC Defendant
DOMOTO, JEFFREY A Attorney for the Defendant
Edward Turner Defendant
Eileen Santiago haddock Individually and as Parent and Natural Guardian for Minor Children, JEREMIAH RICHARD SANTIAGO and MATTHEW RICHARD SANTIAGO Plaintiff
GENERAL BAITO AUTOMOTIVE WAREHOUSE, INC. Defendant
HATZIS, CHRISOSTOMOS MINAS Attorney for the Defendant
HECTOR NUNEZ, d/b/a GENERAL BAITOA AUTO PARTS Defendant
Jennifer Santiago Administratrix of the Estate of Richard Santiago Plaintiff
Justin Deprospo an infant by his Mother and Natural Guardian EILEEN SANTIAGO and EILEEN SANTIAGO, Individually Plaintiff
Michelle Nixon-cochran Defendant
SALOTTOLO, TOBI ROCHFORD Attorney for the Plaintiff
SHAFIQ CHOUDHRY
MICHAEL CARTHY Attorneys for Plaintiffs
MITCHELL PRONER Attorneys for Plaintiffs
MATTHEW HAICKEN Attorneys for Plaintiffs
MATTHEW SCOLL Attorneys for Defendants
WENDY JENNINGS Attorneys for Defendants
EDWARD LEMMO Attorneys for Plaintiffs
MICHAEL SKLIAR Attorneys for Defendants
TIMOTHY MCCARTHY Attorney
MELISSA TRINOS Attorneys for Defendants

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