Motion,Ex Parte: Julie Ayala v. 94th Avenue Jamaica, Llc, Artimus Construction Inc., Hp Jamaica 94th Avenue Housing Development Fund Company Inc, 94th Avenue Jamaica Li Llc
On October 30, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Julie Ayala,
and
94Th Avenue Jamaica Li Llc,
94Th Avenue Jamaica, Llc,
Artimus Construction Inc.,
Hp Jamaica 94Th Avenue Housing Development Fund Company Inc,
for Torts - Other Negligence (Premises - Labor Law)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 08/23/2022 06:16 PM INDEX NO. 521818/2018
NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 08/23/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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JULIE AYALA, Index No.: 521818/2018
Plaintiff, AFFIRMATION OF
GOOD FAITH
- against -
94TH AVENUE JAMAICA, LLC, ARTIMUS
CONSTRUCTION INC., HP JAMAICA 94TH AVENUE
HOUSING DEVELOPMENT FUND COMPANY, INC.
AND 94TH AVENUE JAMAICA LI LLC,
Defendants.
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94TH AVENUE JAMAICA, LLC, ARTIMUS
CONSTRUCTION INC., HP JAMAICA 94TH AVENUE
HOUSING DEVELOPMENT FUND COMPANY, INC.
AND 94TH AVENUE JAMAICA LI LLC,
Third-Party Plaintiffs,
- against -
A& M PROFESSIONAL SECURITY CONSULTING CORP.,
Third-Party Defendant.
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ANCILLA H. DIAS-PINTO, an attorney duly licensed to practice law before the Courts
of the State of New York, hereby affirms the following under the penalties of perjury:
1. I am associated with the law firm Gallo Vitucci Klar LLP, attorneys for Defendants/
Third-Party Plaintiffs 94TH AVENUE JAMAICA, LLC, ARTIMUS CONSTRUCTION
INC., HP JAMAICA 94TH AVENUE HOUSING DEVELOPMENT FUND COMPANY,
INC. AND 94TH AVENUE JAMAICA LI LLC (hereinafter referred to as “Defendants”). I am
fully familiar with the facts and circumstances surrounding this matter.
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FILED: KINGS COUNTY CLERK 08/23/2022 06:16 PM INDEX NO. 521818/2018
NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 08/23/2022
2. As detailed in Defendants Affirmation in Support, there remains outstanding
discovery including the deposition of third-party defendant.
3. Prior to making the instant motion, this office has made several good faith efforts
to resolve the outstanding discovery issues raised in this motion. However, failure to resolve the
issues has necessitated the making of this motion.
Dated: New York, New York
August 23, 2022
_________________________________
ANCILLA H. DIAS-PINTO
2 of 3
FILED: KINGS COUNTY CLERK 08/23/2022 06:16 PM INDEX NO. 521818/2018
NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 08/23/2022
3 of 3
Preview
FILED: KINGS COUNTY CLERK 08/23/2022 06:16 PM INDEX NO. 521818/2018 NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 08/23/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------x JULIE AYALA, Index No.: 521818/2018 Plaintiff, AFFIRMATION OF GOOD FAITH - against - 94TH AVENUE JAMAICA, LLC, ARTIMUS CONSTRUCTION INC., HP JAMAICA 94TH AVENUE HOUSING DEVELOPMENT FUND COMPANY, INC. AND 94TH AVENUE JAMAICA LI LLC, Defendants. --------------------------------------------------------------------x 94TH AVENUE JAMAICA, LLC, ARTIMUS CONSTRUCTION INC., HP JAMAICA 94TH AVENUE HOUSING DEVELOPMENT FUND COMPANY, INC. AND 94TH AVENUE JAMAICA LI LLC, Third-Party Plaintiffs, - against - A& M PROFESSIONAL SECURITY CONSULTING CORP., Third-Party Defendant. --------------------------------------------------------------------x ANCILLA H. DIAS-PINTO, an attorney duly licensed to practice law before the Courts of the State of New York, hereby affirms the following under the penalties of perjury: 1. I am associated with the law firm Gallo Vitucci Klar LLP, attorneys for Defendants/ Third-Party Plaintiffs 94TH AVENUE JAMAICA, LLC, ARTIMUS CONSTRUCTION INC., HP JAMAICA 94TH AVENUE HOUSING DEVELOPMENT FUND COMPANY, INC. AND 94TH AVENUE JAMAICA LI LLC (hereinafter referred to as “Defendants”). I am fully familiar with the facts and circumstances surrounding this matter. 1 of 3 FILED: KINGS COUNTY CLERK 08/23/2022 06:16 PM INDEX NO. 521818/2018 NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 08/23/2022 2. As detailed in Defendants Affirmation in Support, there remains outstanding discovery including the deposition of third-party defendant. 3. Prior to making the instant motion, this office has made several good faith efforts to resolve the outstanding discovery issues raised in this motion. However, failure to resolve the issues has necessitated the making of this motion. Dated: New York, New York August 23, 2022 _________________________________ ANCILLA H. DIAS-PINTO 2 of 3 FILED: KINGS COUNTY CLERK 08/23/2022 06:16 PM INDEX NO. 521818/2018 NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 08/23/2022 3 of 3