On May 24, 2017 a
Motion-Secondary
was filed
involving a dispute between
Dayonna Howell,
and
Dream Land,
G Aranda-Bernardez,
John Doe The Name John Doe Being Fictitious And Intended To Designate The Person Operating The Automobile Of Said Dream Land, At The Time And Place Herein Alleged,
for Torts - Motor Vehicle
in the District Court of New York County.
Preview
os INDEX NO. 154787/2017
2/1 3: 1
NYSCEF DOC. NO. 6 RECEIVED NYSCER: 09/28/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
=== --- -
DAYONNA HOWELL,
Plaintiff, Index No.: 154787/17
-against- Date of Filing: 5/24/17
AFFIDAVIT IN SUPPORT
G ARANDA-BERNANDEZ, OF MOTION FOR DEFAULT
DREAM LAND, JUDGEMENT AND FOR
"JOHN DOE," the name "JOHN DOE" ASSESMENT OF DAMAGES
being fictitious and intended to
designate the person operating the;
me
automobile of said DREAM LAND,
at the time and place herein
alleged,
Defendants.
STATE OF NEW YORK)
) ss
COUNTY OF NASSAU )
DAYONNA HOWELL, being duly sworn, hereby deposes and
says:
1 Iam the plaintiff herein and reside at 12 W. 109th
Street Apt. 1D, New York, NY 10025.
2 I submit this affidavit of merit in support of my
attorney’s motion for a default judgment against defendants -c.
ARANDA-BERNENDEZ, DREAM LAND and "JOHN DOE",
3. On the 19th day of July, 2015 I was seriously injured, due
to defendants’ negligence, in an automobile accident which took
place on Major Deegan Expressway, in the County of Bronx, State of
New York. At the aforesaid time and place, the vehicle owned by
DREAM LAND, occupied by plaintiff DAYONNA HOWELL and operated by
defendant "JOHN DOE" negligently struck the vehicle owned and
operated by defendant G. ARANDA-BERNANDEZ; said accident being due
1 of 2
= INDEX NO. 154787/2017
tysrho ss, E O2/a2
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: : 09/25/2017
to defendants’ G ARANDA - BERNANDEZ, ‘ DREAM LAND and "JOHN DOE"
negligence in Operating said vehicle at an excessive rate of speed,
above the posted speed limit, and in failing to maintain proper
control of his vehicle.
4 I was caused to suffer pain and suffering, serious injury
and out-of-pocket expenses as a result of this accident. I suffered
multiple injuries dacluding injuries to the, among other injuries
sustained.
— Saesicicass
Since ‘the cause of my injuries -was> the negligéiive of
defendants’ G-—ARANDA-BERNANDEZ, DREAM LAND and "JOHN DOE", I am
asking this court to allow me to enter a default judgment against
said defendants.
WHEREFORE, i respectfully ask that the judgment be directed
against defendants’ S--ARANDA-BERNANBES, DREAM LAND and "JOHN DOE",
together with the costs and disbursements, as demanded in the
complaint.
DAO!
Ly UX
Lf | Uh OWELL
VY)
Fh to before
ay of ae a
me this
ici
TARY PUBL
CHARMAINE RAPHARL
NOTARY PUBLIC 5 OF NEW yr
NO, 0 6217662
“QUALIFIED IN THE GOUNTY OF NEW YORK
COMMISSION EXPIRED FEBRUARY 5 eure
ble 739 39/7
2 of 2
Document Filed Date
September 25, 2017
Case Filing Date
May 24, 2017
Category
Torts - Motor Vehicle
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
os INDEX NO. 154787/2017 2/1 3: 1 NYSCEF DOC. NO. 6 RECEIVED NYSCER: 09/28/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK === --- - DAYONNA HOWELL, Plaintiff, Index No.: 154787/17 -against- Date of Filing: 5/24/17 AFFIDAVIT IN SUPPORT G ARANDA-BERNANDEZ, OF MOTION FOR DEFAULT DREAM LAND, JUDGEMENT AND FOR "JOHN DOE," the name "JOHN DOE" ASSESMENT OF DAMAGES being fictitious and intended to designate the person operating the; me automobile of said DREAM LAND, at the time and place herein alleged, Defendants. STATE OF NEW YORK) ) ss COUNTY OF NASSAU ) DAYONNA HOWELL, being duly sworn, hereby deposes and says: 1 Iam the plaintiff herein and reside at 12 W. 109th Street Apt. 1D, New York, NY 10025. 2 I submit this affidavit of merit in support of my attorney’s motion for a default judgment against defendants -c. ARANDA-BERNENDEZ, DREAM LAND and "JOHN DOE", 3. On the 19th day of July, 2015 I was seriously injured, due to defendants’ negligence, in an automobile accident which took place on Major Deegan Expressway, in the County of Bronx, State of New York. At the aforesaid time and place, the vehicle owned by DREAM LAND, occupied by plaintiff DAYONNA HOWELL and operated by defendant "JOHN DOE" negligently struck the vehicle owned and operated by defendant G. ARANDA-BERNANDEZ; said accident being due 1 of 2 = INDEX NO. 154787/2017 tysrho ss, E O2/a2 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: : 09/25/2017 to defendants’ G ARANDA - BERNANDEZ, ‘ DREAM LAND and "JOHN DOE" negligence in Operating said vehicle at an excessive rate of speed, above the posted speed limit, and in failing to maintain proper control of his vehicle. 4 I was caused to suffer pain and suffering, serious injury and out-of-pocket expenses as a result of this accident. I suffered multiple injuries dacluding injuries to the, among other injuries sustained. — Saesicicass Since ‘the cause of my injuries -was> the negligéiive of defendants’ G-—ARANDA-BERNANDEZ, DREAM LAND and "JOHN DOE", I am asking this court to allow me to enter a default judgment against said defendants. WHEREFORE, i respectfully ask that the judgment be directed against defendants’ S--ARANDA-BERNANBES, DREAM LAND and "JOHN DOE", together with the costs and disbursements, as demanded in the complaint. DAO! Ly UX Lf | Uh OWELL VY) Fh to before ay of ae a me this ici TARY PUBL CHARMAINE RAPHARL NOTARY PUBLIC 5 OF NEW yr NO, 0 6217662 “QUALIFIED IN THE GOUNTY OF NEW YORK COMMISSION EXPIRED FEBRUARY 5 eure ble 739 39/7 2 of 2