Preview
FILED: NASSAU COUNTY CLERK 08/17/2021 03:50 PM INDEX NO. 617082/2019
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/17/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
x
KALSOOM ARA and AMJAD HUSSAIN,
Plaintiff, Index No. 617082/19
-against- REPLY AFFIRMATION
JENNA M. CICCARELLI and KIM CICCARELLI,
Defendants.
-- x
MARSHALL S. BLUTH, an atemey duly licensed to practice law in the courts
of the State of New York, hereby affirms the truth of the following under penalty of
per.jmy:
1. I am the attomey for plaintiffs,Kalsoom Ara and Amjad Hussain, husband and
wife, and as such am fully familiar with allthe proceedings heretofore had herein.
2. I submit this Reply Affirmation in support of the motion for summary judgment
on the issue of liability.
3. In opposition to the motion, counsel for defendants concedes the defendant was
the cause of the accident when she backed her vehicle into the p!einMs. The n:2:2
should be granted. What is more, there has been no offer of proof otherwise by someone
with personal knowledge of facts that would dispute the matter.
4. Defendants merely ask that the Court permit them to conduct discovery with
respect to the damages claim. Plaintiffs do not object.
5. Based
r±- "±d
on the foregoing, itis respectfully there are no issues of fact
presented with respect to liability,and itis therefore requested that summary judgment be
granted in favor of plaintiffs and against defendents. This matter, of course, can then
proceed on the issue of damages.
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FILED: NASSAU COUNTY CLERK 08/17/2021 03:50 PM INDEX NO. 617082/2019
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/17/2021
WHEREFORE, itis respectfelly requested that this Court enter an Order granting
summary judgment forthe plaintiff on the issue of liability, together with such other and
further relief as to this Court may see just and proper.
Dated: New York, NY
August 16, 2021
MAR . BL
2
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FILED: NASSAU COUNTY CLERK 08/17/2021 03:50 PM INDEX NO. 617082/2019
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/17/2021
SPECIFICATIONS STATEMENT
PURSUANT TO Rule 202.8-b
The foregoing Affirmation was prepared on a computer. A proportionally
spaced typeface was used, as follows:
Name of typeface: Times New Roman
Point size: 12
Line spacing: At least 24
The total number of words in the Affirmation, inclusive of point
Reply
headings and footnotes and exclusive of pages containing the table of
contents, table of citations, proof of service, printing specifications statement,
case caption, or any authorized addendum containing statutes, rules,
regulations, etc., is 285.
CERTIFICATION
Marshall S. Bluth, Esq., an attorney duly licensed to practice before the
Courts of the State of New York, hereby affirms the truth of the following
under penalties of perjury:
Pursuant to Rule 202.8-b(c), your affirmant hereby certifies that, upon
information and belief, the information contained in the above Specifications
Statement is true and accurate, and the document complies with the word
count limit set forth therein.
Dated: New York, NY
August 16, 2021
MAD S. B H
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FILED: NASSAU COUNTY CLERK 08/17/2021 03:50 PM INDEX NO. 617082/2019
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/17/2021
SUPREMECOURTOFTHESTATEOFNEWYORK
COUNTYOFNASSAU
X
KALSOOMARAandAMJADHUSSAIN,
Plaintiff, IndexNo.617082/19
-against- REPLYAFFIRMATION
JENNA M. CICCARELLIand KlM CICCARELLI,
Defendants.
MARSHALL S. BLUTH, ESQ.
Attorneys for Plaintiff(s)
589 Eighth 21st Floor
Avenue,
New York, NY 10018
(212) 448-1130
Pursuant to 22 NYCRR 130-1.1, the undersigned, a attorney duly admitted to
practice law in the State of New York, cert le hat, upon information and
belief based upon reasonable inquiry, the o t n ions contained in the
annexed document are not frivolous.
NAR HAL S. LUT ESQ.
PLEASE TAKE NOTI
NOTICE OF
ENTRY that the within is a rurrMxxxxxx true copy of a
entered in the office of the Clerk of the within named
Court on 20 .
NOTICE that an order of which the within is a true copy will be
OF presented to the lion. , one of the
SETTLEMENT judges of the within named Court, at ,
on
20 at M.
Dated:
MARSHALL S. BLUTH, ESQ.
Attorneys for Plaintiff(s)
589 Eighth 21** Floor
Avenue,
New York, NY 10018
TO:
Attorneys for Defendants
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Preview
FILED: NASSAU COUNTY CLERK 08/17/2021 03:50 PM INDEX NO. 617082/2019 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/17/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU x KALSOOM ARA and AMJAD HUSSAIN, Plaintiff, Index No. 617082/19 -against- REPLY AFFIRMATION JENNA M. CICCARELLI and KIM CICCARELLI, Defendants. -- x MARSHALL S. BLUTH, an atemey duly licensed to practice law in the courts of the State of New York, hereby affirms the truth of the following under penalty of per.jmy: 1. I am the attomey for plaintiffs,Kalsoom Ara and Amjad Hussain, husband and wife, and as such am fully familiar with allthe proceedings heretofore had herein. 2. I submit this Reply Affirmation in support of the motion for summary judgment on the issue of liability. 3. In opposition to the motion, counsel for defendants concedes the defendant was the cause of the accident when she backed her vehicle into the p!einMs. The n:2:2 should be granted. What is more, there has been no offer of proof otherwise by someone with personal knowledge of facts that would dispute the matter. 4. Defendants merely ask that the Court permit them to conduct discovery with respect to the damages claim. Plaintiffs do not object. 5. Based r±- "±d on the foregoing, itis respectfully there are no issues of fact presented with respect to liability,and itis therefore requested that summary judgment be granted in favor of plaintiffs and against defendents. This matter, of course, can then proceed on the issue of damages. 1 of 4 FILED: NASSAU COUNTY CLERK 08/17/2021 03:50 PM INDEX NO. 617082/2019 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/17/2021 WHEREFORE, itis respectfelly requested that this Court enter an Order granting summary judgment forthe plaintiff on the issue of liability, together with such other and further relief as to this Court may see just and proper. Dated: New York, NY August 16, 2021 MAR . BL 2 2 of 4 FILED: NASSAU COUNTY CLERK 08/17/2021 03:50 PM INDEX NO. 617082/2019 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/17/2021 SPECIFICATIONS STATEMENT PURSUANT TO Rule 202.8-b The foregoing Affirmation was prepared on a computer. A proportionally spaced typeface was used, as follows: Name of typeface: Times New Roman Point size: 12 Line spacing: At least 24 The total number of words in the Affirmation, inclusive of point Reply headings and footnotes and exclusive of pages containing the table of contents, table of citations, proof of service, printing specifications statement, case caption, or any authorized addendum containing statutes, rules, regulations, etc., is 285. CERTIFICATION Marshall S. Bluth, Esq., an attorney duly licensed to practice before the Courts of the State of New York, hereby affirms the truth of the following under penalties of perjury: Pursuant to Rule 202.8-b(c), your affirmant hereby certifies that, upon information and belief, the information contained in the above Specifications Statement is true and accurate, and the document complies with the word count limit set forth therein. Dated: New York, NY August 16, 2021 MAD S. B H 3 of 4 FILED: NASSAU COUNTY CLERK 08/17/2021 03:50 PM INDEX NO. 617082/2019 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/17/2021 SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFNASSAU X KALSOOMARAandAMJADHUSSAIN, Plaintiff, IndexNo.617082/19 -against- REPLYAFFIRMATION JENNA M. CICCARELLIand KlM CICCARELLI, Defendants. MARSHALL S. BLUTH, ESQ. Attorneys for Plaintiff(s) 589 Eighth 21st Floor Avenue, New York, NY 10018 (212) 448-1130 Pursuant to 22 NYCRR 130-1.1, the undersigned, a attorney duly admitted to practice law in the State of New York, cert le hat, upon information and belief based upon reasonable inquiry, the o t n ions contained in the annexed document are not frivolous. NAR HAL S. LUT ESQ. PLEASE TAKE NOTI NOTICE OF ENTRY that the within is a rurrMxxxxxx true copy of a entered in the office of the Clerk of the within named Court on 20 . NOTICE that an order of which the within is a true copy will be OF presented to the lion. , one of the SETTLEMENT judges of the within named Court, at , on 20 at M. Dated: MARSHALL S. BLUTH, ESQ. Attorneys for Plaintiff(s) 589 Eighth 21** Floor Avenue, New York, NY 10018 TO: Attorneys for Defendants 4 of 4