On February 14, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
New York Marine And General Insurance Company And Certain Underwriters At Lloyd'S A S O 2133 3Rd Avenue Corp.,
and
Global Luxury Services Inc.,
Ny Fire Service & Installation Inc,
Ny Firetech Inc,
for Torts - Other (Subro - property damage)
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 06/24/2020 11:46 AM INDEX NO. 151657/2020
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 06/24/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------------X
NEW YORK MARINE AND GENERAL INSURANCE Index No.: 151657/2020 ECF
COMPANY AND CERTAIN UNDERWRITERS AT
LLOYD’S A/S/O 2133 3RD AVENUE CORP.,
AFFIRMATION OF
Plaintiff(s), GOOD FAITH
-against-
NY FIRETECH INC, NY FIRE SERVICE &
INSTALLATION INC and GLOBAL LUXURY
SERVICES INC.,
Defendant(s).
-------------------------------------------------------------------------X
CESAR O. BILBAO, an attorney duly admitted to practice law before the Courts of the
State of New York, hereby affirms the following to be true, upon information and belief, and
with knowledge of the penalty for perjury:
1. I am associated with the LAW OFFICE OF JAMES J. TOOMEY, attorneys for
Defendant GLOBAL LUXURY SERVICES INC. in the above-captioned matter and submit this
Affirmation of Good Faith in connection with the annexed notice of motion and in compliance
with 22 N.Y.C.R.R. §202.12.
2. This law office has attempted to resolve this matter in good faith before
requesting the intervention of this Court. However, to date, Plaintiff NEW YORK MARINE
AND GENERAL INSURANCE COMPANY AND CERTAIN UNDERWITERS AT LLOYD’S
A/S/O 2133 3RD AVENUE CORP. has not complied with Defendant GLOBAL LUXURY
SERVICES INC.’s discovery demands.
WHEREFORE, it is respectfully requested that the within motion be granted in all
respects.
1 of 2
FILED: NEW YORK COUNTY CLERK 06/24/2020 11:46 AM INDEX NO. 151657/2020
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 06/24/2020
Dated: New York, New York
June 24, 2020
CESAR O. BILBAO
2 of 2
Document Filed Date
June 24, 2020
Case Filing Date
February 14, 2020
Category
Torts - Other (Subro - property damage)
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FILED: NEW YORK COUNTY CLERK 06/24/2020 11:46 AM INDEX NO. 151657/2020 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 06/24/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------------------------------------------------------------------X NEW YORK MARINE AND GENERAL INSURANCE Index No.: 151657/2020 ECF COMPANY AND CERTAIN UNDERWRITERS AT LLOYD’S A/S/O 2133 3RD AVENUE CORP., AFFIRMATION OF Plaintiff(s), GOOD FAITH -against- NY FIRETECH INC, NY FIRE SERVICE & INSTALLATION INC and GLOBAL LUXURY SERVICES INC., Defendant(s). -------------------------------------------------------------------------X CESAR O. BILBAO, an attorney duly admitted to practice law before the Courts of the State of New York, hereby affirms the following to be true, upon information and belief, and with knowledge of the penalty for perjury: 1. I am associated with the LAW OFFICE OF JAMES J. TOOMEY, attorneys for Defendant GLOBAL LUXURY SERVICES INC. in the above-captioned matter and submit this Affirmation of Good Faith in connection with the annexed notice of motion and in compliance with 22 N.Y.C.R.R. §202.12. 2. This law office has attempted to resolve this matter in good faith before requesting the intervention of this Court. However, to date, Plaintiff NEW YORK MARINE AND GENERAL INSURANCE COMPANY AND CERTAIN UNDERWITERS AT LLOYD’S A/S/O 2133 3RD AVENUE CORP. has not complied with Defendant GLOBAL LUXURY SERVICES INC.’s discovery demands. WHEREFORE, it is respectfully requested that the within motion be granted in all respects. 1 of 2 FILED: NEW YORK COUNTY CLERK 06/24/2020 11:46 AM INDEX NO. 151657/2020 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 06/24/2020 Dated: New York, New York June 24, 2020 CESAR O. BILBAO 2 of 2