On May 01, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Darryl Nowak,
and
Sea Wolf Marine Transportation, Llc,
Weeks Marine,Inc.,
Wittich Brothers Marine, Inc,
for Torts - Other (Slip and fall)
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 07/12/2020 05:19 PM INDEX NO. 154000/2018
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/12/2020
Betancourt, Van Hemmen, Greco & Kenyon LLC
Attorneys for Defendant
Weeks Marine, Inc.
- 4th
75 South Broadway
White Plains, New York 10601
(914) 997-1100
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
------------------------------------------------------------------------X
DARRYL NOWAK, :
Plaintiff, : Index No. 154000/2018
-v- : AFFIRMATION OF
GOOD FAITH
SEA WOLF MARINE TRANSPORTATION, LLC, :
WITTICH BROTHERS MARINE, INC., and
WEEKS MARINE, INC., :
Defendants.
------------------------------------------------------------------------X
RONALD BETANCOURT, an attorney at law duly licensed to practice in the State of New
York, hereby affirms the following under penalty of perjury pursuant to C.P.L.R. § 2106:
1. I am a member of the firm of Betancourt, Van Hemmen, Greco & Kenyon, attorneys
for defendant Weeks Marine, Inc. ("Weeks") in the above-captioned matter and as such am familiar
with the facts and circumstances surrounding this matter.
2. On March 15, 2020, defendant wrote to plaintiff to obtain the subject discovery. (See
Exhibits A and B hereto.)
3. The affirmant has also spoken to plaintiff's counsel in good faith efforts to obtain
the subject discovery. During the last such conversation on May 7, 2020, I told plaintiff's counsel
that defendant would be filing the instant motion to compel.
1 of 2
FILED: NEW YORK COUNTY CLERK 07/12/2020 05:19 PM INDEX NO. 154000/2018
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/12/2020
4. To date, your Affiant has received no proper responses to his outstanding discovery
demands as fully set forth in the accompanying Affirmation In Support..
Dated: White Plains, New York
July 12, 2020
s/ Ronald Betancourt
RONALD BETANCOURT
To: NAPOLI SHKOLNIK, PLLC
Attorneys for Plaintiff
11th
360 Lexington Ave,
New York, New York 10017
MAHONEY & KEANE, LLP
Attorneys for Defendants
Sea Wolf Marine Transportation, LLC
and Wittich Brothers Marine, Inc.
61 Broadway, Suite 905
New York, New York 10005
-2-
2 of 2
Document Filed Date
July 12, 2020
Case Filing Date
May 01, 2018
Category
Torts - Other (Slip and fall)
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FILED: NEW YORK COUNTY CLERK 07/12/2020 05:19 PM INDEX NO. 154000/2018 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/12/2020 Betancourt, Van Hemmen, Greco & Kenyon LLC Attorneys for Defendant Weeks Marine, Inc. - 4th 75 South Broadway White Plains, New York 10601 (914) 997-1100 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------------X DARRYL NOWAK, : Plaintiff, : Index No. 154000/2018 -v- : AFFIRMATION OF GOOD FAITH SEA WOLF MARINE TRANSPORTATION, LLC, : WITTICH BROTHERS MARINE, INC., and WEEKS MARINE, INC., : Defendants. ------------------------------------------------------------------------X RONALD BETANCOURT, an attorney at law duly licensed to practice in the State of New York, hereby affirms the following under penalty of perjury pursuant to C.P.L.R. § 2106: 1. I am a member of the firm of Betancourt, Van Hemmen, Greco & Kenyon, attorneys for defendant Weeks Marine, Inc. ("Weeks") in the above-captioned matter and as such am familiar with the facts and circumstances surrounding this matter. 2. On March 15, 2020, defendant wrote to plaintiff to obtain the subject discovery. (See Exhibits A and B hereto.) 3. The affirmant has also spoken to plaintiff's counsel in good faith efforts to obtain the subject discovery. During the last such conversation on May 7, 2020, I told plaintiff's counsel that defendant would be filing the instant motion to compel. 1 of 2 FILED: NEW YORK COUNTY CLERK 07/12/2020 05:19 PM INDEX NO. 154000/2018 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/12/2020 4. To date, your Affiant has received no proper responses to his outstanding discovery demands as fully set forth in the accompanying Affirmation In Support.. Dated: White Plains, New York July 12, 2020 s/ Ronald Betancourt RONALD BETANCOURT To: NAPOLI SHKOLNIK, PLLC Attorneys for Plaintiff 11th 360 Lexington Ave, New York, New York 10017 MAHONEY & KEANE, LLP Attorneys for Defendants Sea Wolf Marine Transportation, LLC and Wittich Brothers Marine, Inc. 61 Broadway, Suite 905 New York, New York 10005 -2- 2 of 2