Motion for Summary Judgment in Wade S. Williams, Chrystal Peart v. John Doe, Said Name Is Being Fictitious And Unknown, Ean Holdings Llc| Trellis.Law

On April 12, 2021 a Exhibit,Appendix was filed involving a dispute between Chrystal Peart, Wade S. Williams, and Ean Holdings Llc, John Doe, Said Name Is Being Fictitious And Unknown, for Torts - Motor Vehicle in the District Court of Kings County.

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FILED: KINGS COUNTY CLERK 10/11/2022 03:40 PM INDEX NO. 508561/2021
NYSCEF DOC. NO. 108 RECEIVED NYSCEF: 10/11/2022

EXHIBIT D
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

WADE S. WILLIAMS and CHRYSTAL PEART, Index No. 508561/2021

Plaintiff
NOTICE OF MOTION
-against-

JOHN DOE, said name is being fictitious and unknown,
and EAN HOLDINGS, LLC,
Defendants.

MOTION MADE BY: DAVIDOFF & ASSOCIATES, P.C.

Attorney(s) for Plaintiff
108-18 Queens Blvd, Suite 404

Forest Hills, NY 11375
Tel: (718) 268-8800

RETURN DATE AND September 9, 2021 at 9:30 a.m. or as soon
TIME: thereafter as counsel can be heard.

IAS Motion Support, Supreme Court of the State
PLACE·
of New York, Kings County, 360 Adams Street,

Brooklyn, New York 11201.

SUPPORTING PAPERS: Affirmation in support submitted by
PRYANKA ARORA, ESQ., dated August ,

2021, together with all exhibits and all prior

proceedings heretofore had herein.

RELIEF REQUESTED: a) An Order granting the plaintiff partial

Summary Judgment, pursuant to CPLR section

§3212, on the issue of liability;

b) For such other and further relief as to this

Court may seem just and proper.

ANSWERING PAPERS:
All answering papers, if any, are to be served

within seven (7) days of the return date or

adjourn date of this motion pursuant to

CPLR §2214.

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Dated: Forrest Hills, New York
August 021

Yours, etc.,

PRYAN , ESQ.
DAVIDOFF & ASSOCIATES, P.C.

Attorney(s) for the Plaintiff
108-18 Queens Boulevard, Suite 404
Forest Hills, NY 11375

(718) 268-8800

TO:
RANKIN SAVIDGE, PLLC
Attorneys for Defendant(s)
EAN HOLDINGS, LLC
1527 Franklin Avenue, Suite 100

Mineola, New York 11501

(516) 208-1640
esavidge@rankinsavidgelaw.com

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NYSCEF DOC. NO. 108 RECEIVED NYSCEF: 10/11/2022
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

.---..-...--....-...---.......-..-.-..-......-..------...x
WADE S. WILLIAMS and CHRYSTAL PEART,

Plaintiff Index No.: 508561/2021

-against- AFFIRMATION IN

SUPPORT
JOHN DOE, said name is being fictitious and unknown,
and EAN HOLDINGS, LLC,
Defendants.

PRYANKA ARORA, ESQ., an attorney duly admitted to practice law before the courts

of the State of New York, hereby affirms and says the following under penalties of perjury:

1. I am the associate attorney of THE LAW OFFICE OF DAVIDOFF & ASSOCIATES

P.C., attorney for the plaintiff in this action, and as such I am fully familiar with the facts and

circumstances herein upon a review of this matter's file and discussions with plaintiff.

2. This affirmation is submitted in support of the plaintiff's motion for partial

summary judgment on the issue of liability against the defendants, pursuant to CPLR Section

§3212, as there is no defense to the causes of action set forth in the complaint as to liability, and

no question of fact that need be decided by a jury

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BACKGROUND AND PLEADINGS

3. This is an action upon serious injuries sustained by the plaintiff operator WADE S.

WILLIAMS and plaintiff passenger CHRYSTAL PEART as a result of a motor vehicle accident

that occurred on September 17, 2019, at approximately 8:45 PM, on North Conduit Avenue, at or

near the intersecting street of 84th Street, in the County of Queens, City and State of New York.

4. At the time of the occurrence, Plaintiff WADE S. WILLIAMS was the operator,

and Plaintiff CHRYSTAL PEART was a passenger, of a 2010 Nissan bearing New York license

plate HUG3076.

5. At the time of the occurrence, Plaintiffs were traveling westbound on North Conduit

Avenue in their lane of travel when were and without side-
entirely they abruptly any warning

swiped with substantial impact on the rear passenger side by a 2019 Nissan bearing Connecticut

license plate AV05643 operated by Defendant JOHN DOE, and owned by Defendant EAN

HOLDINGS LLC as it was attempting to change lanes, causing Plaintiffs to sustain serious and

severe personal injuries. Defendant operator JOHN DOE left the scene before the police arrived.

6. This action was commenced by the filing of a summons and verified complaint in

the Supreme Court, Queens County, on April 12, 2021, Index Number 508561/2021. A copy of

the summons and verified complaint is annexed hereto as EXHIBIT "A".

7. Issue was joined when the Defendants, by counsel, served a verified answer on or

about May 27, 2021, a copy of the verified answer is annexed hereto as EXHIBIT "B". A copy of

the Verified Bill of Particulars is annexed hereto as EXHIBIT "C".

8. Plaintiff is entitled to summary judgment on the issue of liability as there are no

defendants'
disputable material issues of fact, the negligence being the sole proximate cause of the

accident, and the plaintiff bearing no comparative negligence. As such, plaintiff moves for an

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Order granting partial summary judgment on the issue of liability.

FACTS OF THE ACCIDENT

9. The subject collision occurred on September 17, 2019, at approximately 8:45 PM,

on North Conduit Avenue, at or near the intersecting street of 84th Street, in the County of Queens,

City and State of New York.

10. At the time of the occurrence, Plaintiff WADE S. WILLIAMS was the operator,

and Plaintiff CHRYSTAL PEART was a passenger, of a 2010 Nissan bearing New York license

plate HUG3076.

11. At the time of the occurrence, Plaintiffs were traveling westbound on North Conduit

Avenue in their lane of travel when were and without side-
entirely they abruptly any warning

swiped with substantial impact on the rear passenger side by a 2019 Nissan bearing Connecticut

license plate AV05643 operated by Defendant JOHN DOE, and owned by Defendant EAN

HOLDINGS LLC as it was attempting to change lanes, causing Plaintiffs to sustain serious and

severe personal injuries. Defendant operator JOHN DOE left the scene before the police arrived.

Defendants' Plaintiffs'
12. As a direct result of the vehicle striking the vehicle, the

Plaintiffs were caused to sustain serious and severe personal injuries.

plaintiffs'
13. Police officers responded to the scene of the accident, obtained the

information and prepared a motor vehicle accident report. A copy of the Police Accident Report is

annexed hereto as EXHIBIT "D". Please note that our office attempted to locate a certified copy

of the Police Accident Report but was unable to locate it.A copy of the search results are annexed

to EXHIBIT "D".

14. The police accident report documents the time, date and location of occurrence,

the names and addresses of the parties involved, in addition to the license plate numbers of

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Defendants'
the vehicles involved. Said report identifies the vehicle as vehicle #1 and the

Plaintiffs'
vehicle as vehicle #2 in the body of the report.

"E"
15. Annexed hereto as EXHIBIT is an affidavit by Plaintiff WADE S.

WILLIAMS, which states:

"I am the Plaintiff in the above-captioned matter. I was the

driver of a 2010 Nissan bearing New York license plate HUG3076

on the 17th day of September 2019. At the time of the

occurrence, I was traveling westbound on North Conduit Avenue

entirely in my lane of travel when my vehicle was abruptly and

without any waming side-swiped with substantial impact on the

rear passenger side by a 2019 Nissan bearing Connecticut license

plate AV05643 operated by Defendant JOHN DOE, and owned by

Defendant EAN HOLDINGS LLC as itwas attempting to change

lanes, causing me to sustain serious and severe personal injuries.

Defendant operator JOHN DOE len the scene before the police

arrived."

16. Those facts unambiguously establish that the sole and proximate cause of this

defendants' plaintiffs'
collision is the fact that the vehicle struck the passenger side of vehicle.

LEGAL ANALYSIS: PARTIAL SUMMARY JUDGMENT AS TO LIABILITY

17. It iswell established that the proponent of a motion for summary judgment must

make a prima facie showing of entitlement ofjudgment as a matter of law, tendering sufficient

evidence to demonstrate the absence of any material issues of fact. See Alvarez Prospect

Hosp., 68 N.Y.2d 320 [1987]. Once the movant has made such a showing, the burden shifts

to the party opposing the motion to produce evidence in admissible form sufficient to establish

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the existence of material issues of fact requiring a trial. See Zuckerman v. City of New York,

49 N.Y.2d 557 [1980].

18. Unless the Defendants present an adequate non-negligent explanation for the

accident, the mere fact that such a collision has occurred creates a presumption and inference

of negligence which un-rebutted requires that Plaintiff be awarded summary judgment as to

liability.

19. Here, the undisputed facts from the Police Accident Report, coupled with the

Plaintiffs'
Affidavit of the Plaintiff WADE S. WILLIAMS, clearly establish the prima facie case

entitling them to summary judgment on the issue of liability. Through his/her actions the

Defendant driver breached his/her common law duties to cautiously and carefully operate his/her

motor vehicle with a reasonable degree of prudence, in addition to violating relevant vehicle and

traffic statutory rules

20. Here, in addition to the foregoing case law, the Defendant driver violated Vehicle

traffic'
and Traffic Law §1128(a) 'Driving on roadways laned for which states: "Whenever any

roadway has been divided into two or more clearly marked lanes for traffic the following rules in

addition to all others consistent herewith shall apply: (a) A vehicle shall be driven as nearly as

practicable entirely within a single lane and shall not be moved from such lane until the driver has

safety."
firstascertained that such movement can be made with

21. Accordingly, Vehicle and Traffic Law §1128(a) is applicable. The evidence

clearly shows that at the time of the occurrence, the Plaintiffs were Plaintiffs were traveling

westbound on North Conduit Avenue entirely in their lane of travel when they were abruptly and

without any warning side-swiped with substantial impact on the rear passenger side by a 2019

Nissan bearing Connecticut license plate AV05643 operated by Defendant JOHN DOE, and

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owned by Defendant EAN HOLDINGS LLC as itwas attempting to change lanes. Therefore, the

Defendant operator was negligent for failing to move from his/her lane safely, as required by

VTL §1128(a). Notwithstanding the violation, the Defendant driver is negligent as a matter

of law.

22. Accordingly, the Plaintiffs have met their initial prima facie burden on summary

judgment as there is no issue of triable fact as to liability. The Defendants were completely at fault

for the subject accident with no fault being attributable to the Plaintiffs.

THIS SUMMARY JUDGMENT IS NOT PREMATURE

23. CPLR Section 3212(a) allows for a party to move for summary judgment as soon

as joinder has occurred. Summary judgment is designed to allow the Court to determine whether

factual issues exist. If there is no factual issue by the opposing party, by proof in admissible form,

then the issue must be resolved in favor of the moving party. In light of the foregoing, it is

respectfully submitted that the plaintiff's motion for summary judgment on the issue of liability

should be granted against the defendants herein.

24. It is well-settled law that a party opposing summary judgment must present

evidence in admissible form sufficient to raise a triable issue of fact. Doherty v. City of New York,

(15t (1st
et al., 16 A.D.3d 124 Dept. 2005); Ward v. N Y C. Housing Authority 18 A.D.3d 391 Dept.

2005); Zabusky v. Cochran. 234 A.D.2d 542. 651 N.Y.S.2d 504 (2nd Dept. 1996): Jacobs v.

(2nd
Schleicher, 124 A.D,2d 785, 508 N.Y.S.2d 504 Dept. 1986). A party claiming ignorance of

facts due to un-conducted discovery must show that he has made reasonable attempts to discover

the facts and that the facts sought would give rise to a triable issue. An opponent of summary

judgment seeking further discovery must set forth a reason to believe additional discovery would

(2nd
reveal a relevant triable issue. Bryan v. City, 614 N.Y.S.2d 554 Dept., 1994); Morales v. P.S.I

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(2nd
Elevator 167 A.D.2d 520 Dept 1990). The mere hope or belief that further discovery might

reveal some bit of helpful information is insufficient grounds to postpone a determination of

(2nd
summary judgment. Morrisaint v. Raemar Corp ...271 A.D.2d 586, 706 N.Y.S.2d 165 Dept

(2nd
2000); Berrios v. Koba. 262 A.D.2d 514, 691 N.Y.S.2d 334 Dept. 1999): Frouws v. Campbell

(2nd
Foundry Company, 275 A.D.2d 761, 714 N.Y.S.2d 227 Dept. 2000) citing Mazzaferro v.

Barlerama Corp., 218 A.D.2d 643, 630 N.Y.S.2d 346.

25. Based on the foregoing, the burden has shifted to the Defendants to produce

Plaintiffs'
evidence in admissible form to rebut established right to summary judgment on the issue

of liability. Without such a showing, there is no question of fact to be resolved by a jury, and the

Plaintiffs'
entitlement to summary judgment on the issue of liability shall remain. Here, there can

Plaintiffs'
be no such showing, and thus the motion for summary judgment should be granted.

26. No prior application for the same or similar relief has been made to this or any other

court.

WHEREFORE, itis respectfully requested that the within motion by plaintiffs for

partial summary judgment on the issue of liability be granted in allrespects and such other and

further relief as this Court deems just and proper.

Dated: Forest Hil s, NewYork
August , 2021

PR NI A ARO , ESQ

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CERTIFICATION

In accordance with Rule 17 of the Rules of the Commercial Division, 22 NYCRR

$202.70, the undersigned certifies that the word count in this memorandum of law (excluding the

caption, table of contents, table of authorities, signature block, and this certification), as

established using the word count on the word-processing system used to prepare it,is 1.808

words.

Dated: Forest Hills, New York
August , 2021

Respectfull submitted,

By: Pry rora, Esq.
DAVIDOFF & ASSOCIATES, P.C.

Attorneys(s) for the Plaint1ff
108-18 Queens Boulevard, Suite 404
Forest Hills, NY 11375

(718) 268-8800

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
X
WADE S. WILLIAMS and CHRYSTAL PEART,

Plaintiff Index No.: 508561/2021

-against-
STATEMENT OF
MATERIAL FACTS
JOHN DOE, said name is being fictitious and unknown,
and EAN HOLDINGS, LLC,
Defendants.

Statement of Material Facts

1. Plaintiffs WADE S. WILLIAMS and CHRYSTAL PEART, and Defendants JOHN

DOE and EAN HOLDINGS, LLC, were involved in a motor vehicle accident that occurred on

September 17, 2019, at approximately 8:45 PM, and occurred on North Conduit Avenue, at or near

the intersecting street of 84th Street, in the County of Queens, City and State of New York. See

"D"
Exhibit for the Police Accident Report.

2. On the date and time and location of the subject accident mentioned in 11 above,

Plaintiff, WADE S. WILLIAMS, was the operator ofhis vehicle, a 2010 Nissan bearing New York

license plate HUG3076. See Exhibit "D".

3. On the date and time and location of the subject accident mentioned in 11 above,

Plaintiff, CHRYSTAL PEART, was the passenger of the vehicle operated by Plaintiff, WADE

WILLIAMS, a 2010 Nissan bearing New York license plate HUG3076. See Exhibit "D".

4. On the date and time and location of the subject accident mentioned, Defendant,

JOHN DOE, said name isbeing fictitious and unknown, was the operator of a 2019 Nissan bearing

Connecticut license plate AV05643. See Exhibit "D".

5. Defendant EAN HOLDINGS LLC was the owner of a 2019 Nissan bearing

Connecticut license plate AV05643. See Exhibit "D".

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6. Following the subject accident, Defendant, JOHN DOE, said name is being

fictitious and unknown, fled the scene of the accident without exchanging insurance information

with the Plaintiffs or waiting for the arrival of police. See Exhibit "D".

Defendants' Plaintiffs'
7. vehicle struck the rear passenger side of vehicle with

substantial impact while Plaintiffs vehicle was traveling westbound on North Conduit Avenue

entirely in his lane of travel. See Exhibit "D".

Dated: Forest Hills, NewYork
August , 2021
PRYA A , SQ

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CERTIFICATION

In accordance with the Uniform Rules of the Supreme Court Section 202.8-B, the

undersigned certified that the word count in this statement of material facts (excluding this

certification) as established using the word count on the word-processing system used to prepare

it,is,276 words.

Dated: Queens, New York
August , 2021
Yours,

PRYA , ESQ

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SUPREME COURT OF THˆ STATE OF NEW YORK
COUNTY OF KINGS
___________________________________________Ç
WADE S. WILLIAMS and CHRYSTAL PEART, NOTICE OF CROSS-MOTION
FOR SUMMARY JUDGMENT

Plaintiff(s),
-against-

Index No.: 508561/2021

JOHN DOE, said name is being fictitious and unknown,
And EAN HOLDINGS, LLC,

Defendant(s).
_______.._________________________________Ç

COUNSELORS:

PLEASE TAKE NOTICE, that upon the annexed Affirmation of BARRY J. UNG AR,

ESQ., dated November 18, 2021, and upon allthe pleading and proceedings heretofore had herein,

the undersigned will move thisCourt at an IAS part at the Courthouse located at 360 Adams Street,

2nd
Brooklyn, New York 11201, on the day of December, 2021, at 9:30 o'clock in the forenoon of

that day or as soon thereafter as Counsel may be heard for an Order: (1) pursuant to CPLR §§

3211/3212, granting defendant EAN HOLDINGS, LLC's cross-motion to dismiss all claims and

Graves'
cross-claims against it in this action as such claims are barred by the Amendment; (2)

plaintiffs'
denying motion for partial summary judgment on the issue of liability; and (3) for such

other and further relief as this Court deems just and proper.

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. . . . . .

PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR Section 2214, all

answering affirmations must be served seven (7) days prior to the return date of this motion.

Dated: Mineola, New York
November 18, 2021
RANKIN SAVIDGE, PLLC

BARRY J. UNGAR, Esq.
Attorneys for Defendant(s)
EAN HOLDINGS, LLC.
1527 Franklin Avenue, Suite 100

Mineola, New York 11501

(516) 208-1640

To:

DAVIDOFF & ASSOCIATES, P.C.
Attorneys for Plaintiff(s)
WADE S. WILLIAMS and
CHRYSTAL PEART
108-18 Queens Boulevard, Suite 404
Forest Hills, New York 11375

(718) 268-8800

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. . . .

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_________________________________.._____________________..____________Ç
WADE S. WILLIAMS and CHRYSTAL PEART, AFFIRMATION IN SUPPORT
OF DEFENDANT'S CROSS-
MOTION

Plaintiff(s),
-against- Index No.: 508561/2021

JOHN DOE, said name is being fictitious and unknown,
And EAN HOLDINGS,

Case Info

Judge

Karen B Rothenberg Track Judge’s New Case

Case No.

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Document Filed Date

October 11, 2022

Case Filing Date

April 12, 2021

County

Parties

Chrystal Peart Plaintiff
DAVIDOFF, RUBEN Attorney for the Plaintiff
EAN HOLDINGS LLC Defendant
ECONOMOU, PAULINA Attorney for the Defendant
James G. Bilello and Associates Non Party
JOHN DOE, said name is being fictitious and unknown Defendant
SAVIDGE, EDWARD J Attorney for the Defendant
Shanti J Tuthill ESQ Non Party
SIMURO, ARTHUR Attorney for the Plaintiff
TUTHILL, SHANTI JENNIFER Attorneys for Plaintiffs
TUTHILL, SHANTI JENNIFER Attorney for the Plaintiff
Wade S. Williams Plaintiff
BARRY UNGAR Attorneys for Defendants
JENNIFER UNGAR
CHONGJIN KIM Attorneys for Defendants
SUE KIM Attorneys for Plaintiffs
MARK GETZONI Attorney
PRYANKA ARORA Attorney
JOSEPH KIM Attorney
JOSEPH MILITI Attorneys for Plaintiffs

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Exhibit,Appendix: Wade S. Williams, Chrystal Peart v. John Doe, Said Name Is Being Fictitious And Unknown, Ean Holdings Llc

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