On February 24, 2021 a
Motion,Ex Parte
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 03/17/2022 03:13 PM INDEX NO. 504481/2021
NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 03/17/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------------------
X
LALITA CREWS, :
: Index No. 504481/2021
Plaintiff, :
: AFFIRMATION
-against- : OF GOOD FAITH
:
JAM SERVICES AND REPAIRS LLC, JOSE M. :
NINA BONILLA, QSR EAST LLC, 1040 KFC LLC :
and KFC CORPORATION, :
Defendants.
----------------------------------------------------------------------X
RHONDA D. THOMPSON, an attorney duly admitted to practice law in the courts of the
State of New York, affirms the truth of the following, under the penalty of perjury:
1. I am associated with the LAW OFFICE OF KEVIN J. PHILBIN, attorneys for
defendant, 1040 KFC LLC, in the above-entitled action, and submit this Affirmation of Good Faith
in connection with the annexed notice of motion and in compliance with 22 NYCRR §202.12.
2. We have attempted to resolve this matter in good faith before requesting the
intervention of this Court. On June 8, 2021, September 13, 2021, September 27, 2021, October 27,
2021, November 18, 2021, and January 28, 2022 good faith emails were forwarded and on
September 13, 2021 a Case Scheduling Order was issued directing the exchange of discovery. I
also reached out to Plaintiff’s counsel, Mr. Ramirez by phone and left a voicemail regarding the
outstanding bill of particulars and discovery responses. (date not recorded) but received no
response. True and accurate copies of the aforesaid emails and Order are annexed to the within
motion, as Exhibit “B”.
WHERFORE, it is respectfully requested that the within motion be granted.
1 of 2
FILED: KINGS COUNTY CLERK 03/17/2022 03:13 PM INDEX NO. 504481/2021
NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 03/17/2022
Dated: New York, New York
March 17, 2022
____________________
RHONDA D. THOMPSON
2 of 2
Document Filed Date
March 17, 2022
Case Filing Date
February 24, 2021
Category
Torts - Other Negligence (injury on deft premises)
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FILED: KINGS COUNTY CLERK 03/17/2022 03:13 PM INDEX NO. 504481/2021 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 03/17/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------------------------------------------ X LALITA CREWS, : : Index No. 504481/2021 Plaintiff, : : AFFIRMATION -against- : OF GOOD FAITH : JAM SERVICES AND REPAIRS LLC, JOSE M. : NINA BONILLA, QSR EAST LLC, 1040 KFC LLC : and KFC CORPORATION, : Defendants. ----------------------------------------------------------------------X RHONDA D. THOMPSON, an attorney duly admitted to practice law in the courts of the State of New York, affirms the truth of the following, under the penalty of perjury: 1. I am associated with the LAW OFFICE OF KEVIN J. PHILBIN, attorneys for defendant, 1040 KFC LLC, in the above-entitled action, and submit this Affirmation of Good Faith in connection with the annexed notice of motion and in compliance with 22 NYCRR §202.12. 2. We have attempted to resolve this matter in good faith before requesting the intervention of this Court. On June 8, 2021, September 13, 2021, September 27, 2021, October 27, 2021, November 18, 2021, and January 28, 2022 good faith emails were forwarded and on September 13, 2021 a Case Scheduling Order was issued directing the exchange of discovery. I also reached out to Plaintiff’s counsel, Mr. Ramirez by phone and left a voicemail regarding the outstanding bill of particulars and discovery responses. (date not recorded) but received no response. True and accurate copies of the aforesaid emails and Order are annexed to the within motion, as Exhibit “B”. WHERFORE, it is respectfully requested that the within motion be granted. 1 of 2 FILED: KINGS COUNTY CLERK 03/17/2022 03:13 PM INDEX NO. 504481/2021 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 03/17/2022 Dated: New York, New York March 17, 2022 ____________________ RHONDA D. THOMPSON 2 of 2