On December 15, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Arias Panayoty,
Saba Yehia,
and
Citi Connect Llc,
Ralph G. Bonhomme,
for Torts - Motor Vehicle
in the District Court of Bronx County.
Preview
FILED: BRONX COUNTY CLERK 10/31/2022 08:18 PM INDEX NO. 35300/2020E
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/31/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
----------------------------------------------------------------------X
ARIAS PANAYOTY and SABA YEHIA,
AFFIRMATION OF
Plaintiffs,
GOOD FAITH
-against-
Index No.: 35300/2020E
RALPH G. BONHOMME and CITI CONNECT LLC.,
Defendants.
----------------------------------------------------------------------X
DANIEL BERGER, Esq., an attorney duly admitted to practice before all of the Courts of
the State of New York, hereby affirms the truth of the following under the penalty of perjury:
1. I am an associate with the BELUSHIN LAW FIRM, P.C., the attorneys for the
Plaintiff, herein, and as such, I am fully familiar with the facts and circumstances of this action
based upon a review of the case file and the investigation materials contained therein.
2. I submit this Affirmation pursuant to the applicable Uniform Trial Court Rules with
respect to discovery-related motions.
3. This office has made numerous attempts to secure the deposition of all parties, to
date, Defendant refuse to go forward with deposition and remain in default in violation of
multiple Court Orders.
4. We are seeking your Court’s intervention due to the default we have encountered as
explained in the motion.
5. It is respectfully submitted that we have made a good faith effort to resolve the
discovery issues raised in the Plaintiff’s motion and that judicial intervention is needed at this time.
WHEREFORE, Plaintiff respectfully requests that the within motion be granted.
1 of 2
FILED: BRONX COUNTY CLERK 10/31/2022 08:18 PM INDEX NO. 35300/2020E
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/31/2022
Dated: Brooklyn, New York
October 31, 2022
Yours, etc.,
Daniel Berger, Esq., for
BELUSHIN LAW FIRM P.C.
Attorneys for Plaintiffs
ARIAS PANAYOTY AND
SABA YEHIA
1712 Kings Highway, Ste. 2
Brooklyn, New York 11229
(718) 787-4470
Our File No.: 20-0079VB-0
TO:
Smith Mazure, PC
Attorneys for Defendants
RALPH G. BONHOMME and
CITI CONNECT LLC.,
111 John Street,
New York, New York 10038
(516) 294-7325
NIC-00862
2 of 2
Document Filed Date
October 31, 2022
Case Filing Date
December 15, 2020
Category
Torts - Motor Vehicle
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FILED: BRONX COUNTY CLERK 10/31/2022 08:18 PM INDEX NO. 35300/2020E NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/31/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX ----------------------------------------------------------------------X ARIAS PANAYOTY and SABA YEHIA, AFFIRMATION OF Plaintiffs, GOOD FAITH -against- Index No.: 35300/2020E RALPH G. BONHOMME and CITI CONNECT LLC., Defendants. ----------------------------------------------------------------------X DANIEL BERGER, Esq., an attorney duly admitted to practice before all of the Courts of the State of New York, hereby affirms the truth of the following under the penalty of perjury: 1. I am an associate with the BELUSHIN LAW FIRM, P.C., the attorneys for the Plaintiff, herein, and as such, I am fully familiar with the facts and circumstances of this action based upon a review of the case file and the investigation materials contained therein. 2. I submit this Affirmation pursuant to the applicable Uniform Trial Court Rules with respect to discovery-related motions. 3. This office has made numerous attempts to secure the deposition of all parties, to date, Defendant refuse to go forward with deposition and remain in default in violation of multiple Court Orders. 4. We are seeking your Court’s intervention due to the default we have encountered as explained in the motion. 5. It is respectfully submitted that we have made a good faith effort to resolve the discovery issues raised in the Plaintiff’s motion and that judicial intervention is needed at this time. WHEREFORE, Plaintiff respectfully requests that the within motion be granted. 1 of 2 FILED: BRONX COUNTY CLERK 10/31/2022 08:18 PM INDEX NO. 35300/2020E NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/31/2022 Dated: Brooklyn, New York October 31, 2022 Yours, etc., Daniel Berger, Esq., for BELUSHIN LAW FIRM P.C. Attorneys for Plaintiffs ARIAS PANAYOTY AND SABA YEHIA 1712 Kings Highway, Ste. 2 Brooklyn, New York 11229 (718) 787-4470 Our File No.: 20-0079VB-0 TO: Smith Mazure, PC Attorneys for Defendants RALPH G. BONHOMME and CITI CONNECT LLC., 111 John Street, New York, New York 10038 (516) 294-7325 NIC-00862 2 of 2