On April 24, 2021 a
No Value
was filed
involving a dispute between
Steven Jimenez,
and
315 Seventh Residential L.L.C.,
Maxwell Kates, Inc.,
The 315 Seventh Avenue Condominium,
T-Mobile Usa, Inc.,
for Torts - Other Negligence (Negligence)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 01/12/2022 04:36 PM INDEX NO. 153982/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 01/12/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
---------------------------------------------------------------x
STEVEN JIMENEZ,
Index No.: 153982/2021
Plaintiff,
GOOD FAITH AFFIRMATION
- against -
MAXWELL KATES, INC., 315 SEVENTH AVENUE
RESIDENTIAL, L.L.C., THE 315 SEVENTH
AVENUE CONDOMINIUM and T-MOBILE USA,
INC.,
Defendants.
---------------------------------------------------------------x
William C. Neves, an attorney duly admitted to practice law in the Courts of the
State of New York, hereby affirms the following under penalties of perjury and pursuant to the
CPLR:
1. I am member of the law firm Sjoquist & Baer, attorneys for Defendants
Maxwell-Kates, Inc. s/h/a Maxwell Kates, Inc. and The 315 Seventh Avenue Condominium
(“Defendants”) in this action.
2. I have knowledge of the facts set forth below through my representation of
Defendants in this matter and my review of my firm’s file and the electronically filed documents
in this matter.
3. I have attempted to resolve the issues raised in this motion via phone and
correspondence to Plaintiff’s counsel, Mr. Joseph Guardino.
4. On January 7, 2022 the undersigned spoke to Jalissa of Liakas Law, P.C.
about the outstanding discovery. I left a verbal message for Plaintiff counsel with Jalissa and was
1 of 2
FILED: NEW YORK COUNTY CLERK 01/12/2022 04:36 PM INDEX NO. 153982/2021
NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 01/12/2022
advised Plaintiff’s counsel would return the call promptly. The undersigned then left a voice mail
message for Plaintiff’s counsel that same day.
5. Defendants electronically filed their good faith correspondence seeking a
Section 202.20-f telephone conference with Plaintiff counsel on January 7, 2022. (Exhibit G to
Neves Mov. Aff.).
6. My phone call to Plaintiff’s counsel has not been returned nor have
Defendant’s demands and good faith correspondences been responded to.
7. As a result, we have been unable to resolve the issues raised in the instant
motion. This Court’s intervention is therefore necessary.
Dated: New York, New York
January 12, 2022
SJOQUIST & BAER
____________________________
By: William C. Neves
2 of 2
Document Filed Date
January 12, 2022
Case Filing Date
April 24, 2021
Category
Torts - Other Negligence (Negligence)
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Preview
FILED: NEW YORK COUNTY CLERK 01/12/2022 04:36 PM INDEX NO. 153982/2021 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 01/12/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------------------------------x STEVEN JIMENEZ, Index No.: 153982/2021 Plaintiff, GOOD FAITH AFFIRMATION - against - MAXWELL KATES, INC., 315 SEVENTH AVENUE RESIDENTIAL, L.L.C., THE 315 SEVENTH AVENUE CONDOMINIUM and T-MOBILE USA, INC., Defendants. ---------------------------------------------------------------x William C. Neves, an attorney duly admitted to practice law in the Courts of the State of New York, hereby affirms the following under penalties of perjury and pursuant to the CPLR: 1. I am member of the law firm Sjoquist & Baer, attorneys for Defendants Maxwell-Kates, Inc. s/h/a Maxwell Kates, Inc. and The 315 Seventh Avenue Condominium (“Defendants”) in this action. 2. I have knowledge of the facts set forth below through my representation of Defendants in this matter and my review of my firm’s file and the electronically filed documents in this matter. 3. I have attempted to resolve the issues raised in this motion via phone and correspondence to Plaintiff’s counsel, Mr. Joseph Guardino. 4. On January 7, 2022 the undersigned spoke to Jalissa of Liakas Law, P.C. about the outstanding discovery. I left a verbal message for Plaintiff counsel with Jalissa and was 1 of 2 FILED: NEW YORK COUNTY CLERK 01/12/2022 04:36 PM INDEX NO. 153982/2021 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 01/12/2022 advised Plaintiff’s counsel would return the call promptly. The undersigned then left a voice mail message for Plaintiff’s counsel that same day. 5. Defendants electronically filed their good faith correspondence seeking a Section 202.20-f telephone conference with Plaintiff counsel on January 7, 2022. (Exhibit G to Neves Mov. Aff.). 6. My phone call to Plaintiff’s counsel has not been returned nor have Defendant’s demands and good faith correspondences been responded to. 7. As a result, we have been unable to resolve the issues raised in the instant motion. This Court’s intervention is therefore necessary. Dated: New York, New York January 12, 2022 SJOQUIST & BAER ____________________________ By: William C. Neves 2 of 2