On March 29, 2021 a
Party Statement
was filed
involving a dispute between
Efrin Cishooga,
Janna Sichuga,
and
Archdiocese Of New York,
City Of New York,
New York City Department Of Parks And Recreation,
New York City Department Of Transportation,
The Franciscan Handmaids Of The Most Pure Heart Of Mary, Inc.,
for Torts - Other Negligence (injury on the premises)
in the District Court of Richmond County.
Preview
FILED: RICHMOND COUNTY CLERK 06/22/2022 04:45 PM INDEX NO. 150671/2021
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/22/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
-----x
JANNA SICHUGA ANd EFRIN CISHOOGA, RULE 202.8.G
Plaintiffs STATEMENT OF
MATERIAL FACTS
- against -
Index No. 15067112021
THE CITY OF NEW YORK, NEW YORK CITY City File No.: 2021-007631
DEPARTMENT OF TRANSPORTATION, NEW YORK Assigned to: Judge Thomas Aliotta
CITY DEPARTMENT OF PARKS AND RECREATION,
THE FRANCISCAN HANDMAIDS OF THE MOST
PURE HEART OF MARY, INC., AND ARCHDIOCES
OF NEW YORK,
Defendants.
---------x
Defendant the City of New York, the City of New York s/h/a New York City
Department of Transportation and City of New York s/h/a New York City Department of Parks and
Recreation (hereinafter collectively referred to as the "City"), submits, as required by Uniform Civil
Rule 202.8-9, the following statement of material facts in support of its motion for summary judgment
under CPLR3212
1. Plaintiff, JANNA SICHUGA, sued City of New York and other defendants as
the result of an injury she sustained on January L5,2020,when she tripped and fell on the sidewalk
on Woodvale Avenue, specifically on the Woodvale Avenue side of 63 Bayside Lane, Staten Island,
New York.
2. All allegations against the City relate to ownership and operation of the
accident location, specifically the sidewalk at the location.
3. The location of the accident, 63 Bayside Lane, is a non-exempt property under
Administrative Law $7-210 and thus the City is not liable for the Plaintiff's injuries.
1 of 2
FILED: RICHMOND COUNTY CLERK 06/22/2022 04:45 PM INDEX NO. 150671/2021
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/22/2022
4. For the reasons more fully explained in the City's supporting affirmation, the
Court should grant the City's motion in its entirety.
Dated: Staten Island, New York
Jvne22,2022
. SYLVIA O. HINDS-RADX
Corporation Counsel of the City of New York
Attorney for Defendant THE CITY OF NEW YORK
60 Bay Street
Staten Island, New York 10301
By: GIANNA M FAMULARI, Esq.
-2-
2 of 2
Document Filed Date
June 22, 2022
Case Filing Date
March 29, 2021
Category
Torts - Other Negligence (injury on the premises)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: RICHMOND COUNTY CLERK 06/22/2022 04:45 PM INDEX NO. 150671/2021 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/22/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND -----x JANNA SICHUGA ANd EFRIN CISHOOGA, RULE 202.8.G Plaintiffs STATEMENT OF MATERIAL FACTS - against - Index No. 15067112021 THE CITY OF NEW YORK, NEW YORK CITY City File No.: 2021-007631 DEPARTMENT OF TRANSPORTATION, NEW YORK Assigned to: Judge Thomas Aliotta CITY DEPARTMENT OF PARKS AND RECREATION, THE FRANCISCAN HANDMAIDS OF THE MOST PURE HEART OF MARY, INC., AND ARCHDIOCES OF NEW YORK, Defendants. ---------x Defendant the City of New York, the City of New York s/h/a New York City Department of Transportation and City of New York s/h/a New York City Department of Parks and Recreation (hereinafter collectively referred to as the "City"), submits, as required by Uniform Civil Rule 202.8-9, the following statement of material facts in support of its motion for summary judgment under CPLR3212 1. Plaintiff, JANNA SICHUGA, sued City of New York and other defendants as the result of an injury she sustained on January L5,2020,when she tripped and fell on the sidewalk on Woodvale Avenue, specifically on the Woodvale Avenue side of 63 Bayside Lane, Staten Island, New York. 2. All allegations against the City relate to ownership and operation of the accident location, specifically the sidewalk at the location. 3. The location of the accident, 63 Bayside Lane, is a non-exempt property under Administrative Law $7-210 and thus the City is not liable for the Plaintiff's injuries. 1 of 2 FILED: RICHMOND COUNTY CLERK 06/22/2022 04:45 PM INDEX NO. 150671/2021 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 06/22/2022 4. For the reasons more fully explained in the City's supporting affirmation, the Court should grant the City's motion in its entirety. Dated: Staten Island, New York Jvne22,2022 . SYLVIA O. HINDS-RADX Corporation Counsel of the City of New York Attorney for Defendant THE CITY OF NEW YORK 60 Bay Street Staten Island, New York 10301 By: GIANNA M FAMULARI, Esq. -2- 2 of 2