On February 24, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Lalita Crews,
and
1040 Kfc Llc,
Jam Services And Repairs Llc,
Jose M. Nina Bonilla,
Kfc Corporation,
Qsr East Llc,
for Torts - Other Negligence (injury on deft premises)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 02/23/2022 01:11 PM INDEX NO. 504481/2021
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/23/2022
Exhibit 2
FILED: KINGS COUNTY CLERK 02/23/2022 01:11 PM INDEX NO. 504481/2021
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/23/2022
Ron Ramirez
From: Dale, Wendy
Sent: Tuesday, January 5, 2021 12:18 PM
To: Ron Ramirez
Subject: Response to Attorney Representation Letter for LalitaCrews
Attachments: ARL Lalita Crews.pdf
KFC Corporation received your Notice of Representation of LalitaCrews for injuriesshe claims to have sustained on or
about March 11, 2020 at a KFC restaurant in Brooklyn, New York.
In thiscase, I must report that the KFC restaurant in question is owned and operated by a franchisee of KFC
Corporation. Franchisees are indepêñdêñt businesspersons and corporations who own and operate KFC restaurants
under a License Agreement with KFC Corporation. KFC Corporation does not own, operate or cõñtict this restaurant and
isnot the insured for this property.
I have looked into this matter for you, and the owner of the KFC Restaurant located at 1040 Bedford Ave., Brooklyn, NY
10205 isQ5R East LLC. The contract information for this franchisee is24 Outwater Lane, Suite 2, Garfield, NJ
07026. Thus, the appropriate course of action willbe for you to address this matter with the owner of this restaurant. I
have also forwarded a copy of your Notice directly to the franchisee as well.
Thank you in advance for your attêñtics.
Wendy C. Dale
Executive Administrator
For the Chief Legal Officer
KFC Corporation
1900 Colonel Sanders Lane
Louisville,KY 40213
(502) 874-7144
Cell: (502) 387-3913
UNRIVALED
CultureCrew
"This communication is ccñfidêñtial and may be legally privilêgêd. Ifyou are not the intended recipient, (i)please do not
read or disclose to others, (ii)please notify the sender by reply mail, and please
(iii) delete this communication from
cooperation."
your system. Failure to follow this process may be unlawful. Thank you for your
1
Document Filed Date
February 23, 2022
Case Filing Date
February 24, 2021
Category
Torts - Other Negligence (injury on deft premises)
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FILED: KINGS COUNTY CLERK 02/23/2022 01:11 PM INDEX NO. 504481/2021 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/23/2022 Exhibit 2 FILED: KINGS COUNTY CLERK 02/23/2022 01:11 PM INDEX NO. 504481/2021 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/23/2022 Ron Ramirez From: Dale, Wendy Sent: Tuesday, January 5, 2021 12:18 PM To: Ron Ramirez Subject: Response to Attorney Representation Letter for LalitaCrews Attachments: ARL Lalita Crews.pdf KFC Corporation received your Notice of Representation of LalitaCrews for injuriesshe claims to have sustained on or about March 11, 2020 at a KFC restaurant in Brooklyn, New York. In thiscase, I must report that the KFC restaurant in question is owned and operated by a franchisee of KFC Corporation. Franchisees are indepêñdêñt businesspersons and corporations who own and operate KFC restaurants under a License Agreement with KFC Corporation. KFC Corporation does not own, operate or cõñtict this restaurant and isnot the insured for this property. I have looked into this matter for you, and the owner of the KFC Restaurant located at 1040 Bedford Ave., Brooklyn, NY 10205 isQ5R East LLC. The contract information for this franchisee is24 Outwater Lane, Suite 2, Garfield, NJ 07026. Thus, the appropriate course of action willbe for you to address this matter with the owner of this restaurant. I have also forwarded a copy of your Notice directly to the franchisee as well. Thank you in advance for your attêñtics. Wendy C. Dale Executive Administrator For the Chief Legal Officer KFC Corporation 1900 Colonel Sanders Lane Louisville,KY 40213 (502) 874-7144 Cell: (502) 387-3913 UNRIVALED CultureCrew "This communication is ccñfidêñtial and may be legally privilêgêd. Ifyou are not the intended recipient, (i)please do not read or disclose to others, (ii)please notify the sender by reply mail, and please (iii) delete this communication from cooperation." your system. Failure to follow this process may be unlawful. Thank you for your 1