On February 24, 2021 a
Motion-Secondary
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 04/15/2022 10:03 AM INDEX NO. 504481/2021
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/15/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
____________________________________________________________________Ç
LALITA CREWS,
AFFIRMATION IN
Plaintiff, OPPOSITION
- against -
Index No. 504481/2021
JAM SERVICES AND REPAIRS LLC, JOSE M. Mot. Seq. #002
NINA BONILLA, QSR EAST LLC, 1040 KFC LLC
and KFC CORPORATION,
Defendants.
__________________---------------------------------------------_______________Ç
RONALD W. RAMIREZ, an attorney duly admitted to practice law before the courts of the
State of New York, respectfully states under the penalties of perjury the following:
1. I am a member of the LAW OFFICE OF RONALD W. RAMIREZ, the attorneys
of record for Plaintiff herein and, as such, am fully familiar with the facts and circumstances of this
action.
2. The sources of your affirmant's information and the grounds for his belief are the
pleadings and proceedings in the above-entitled action.
3. I submit this affirmation in opposition to Defendant 1040 KFC LLC's motion to
dismiss Plaintiff's complaint or preclude Plaintiff.
4. Annexed hereto as Exhibit 1 is a copy of Plaintiff's Verified Bill of Particulars dated
4/5/22, e-filed on 4/6/22, responding to Defendant 1040 KFC LLC's demand for a billof particulars
dated 4/28/21,
5. Annexed hereto as Exhibit 2 are copies of Plaintiff's discovery responses dated
4/5/22, e-filed on 4/6/22, responding to Defendant 1040 KFC LLC's discovery demands dated
4/28/21.
1 of 3
FILED: KINGS COUNTY CLERK 04/15/2022 10:03 AM INDEX NO. 504481/2021
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/15/2022
6. Plaintiff has substantially complied with Defendant 1040 KFC LLC's demand
for a billof particulars and demands for discovery (notwithstanding those items objected to) and
Defendant's motion to dismiss/preclude should be denied in its entirety.
WHEREFORE, itis respectfully requested that Defendant 1040 KFC LLC's motion be
denied in its entirety, and for such other and further relief as to this Court may be just and proper.
Affirmed: Forest Hills, New York
April 15, 2022
RON D W. RAMI Z
2 of 3
FILED: KINGS COUNTY CLERK 04/15/2022 10:03 AM INDEX NO. 504481/2021
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/15/2022
Index No. 504481/21 (J. Montelione)
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
LALITA CREWS,
Plaintiff,
- against -
JAM SERVICES AND REPAIRS LLC, JOSE M. NINA BONILLA, QSR EAST LLC,
1940 KFC LLC and KFC CORPORATION,
Defendants.
AFFIRMATION IN OPPOSITION
LAW OFFICE OF RONALD W. RAMIREZ
Attorneys for Plaintiff
107-19 71st Avenue
Forest Hills, New York 11375
Tel. No.: (718) 261-6161
Fax No.: (718) 268-3045
RR @ RWRAMIREZ.COM
CERTIFICATION:
To the best ofthe undersigned's knowledge, information and belief,formed after an inquiry
reasonable under the circumstances, the within document(s) and contentions contained
therein are not frivolous as defined in 22 NYCRR §130-1.1-a.
Dated: Forest Hills, New York
April 15, 2022
RO ALD W. RA IRE
3 of 3
Document Filed Date
April 15, 2022
Case Filing Date
February 24, 2021
Category
Torts - Other Negligence (injury on deft premises)
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FILED: KINGS COUNTY CLERK 04/15/2022 10:03 AM INDEX NO. 504481/2021 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/15/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ____________________________________________________________________Ç LALITA CREWS, AFFIRMATION IN Plaintiff, OPPOSITION - against - Index No. 504481/2021 JAM SERVICES AND REPAIRS LLC, JOSE M. Mot. Seq. #002 NINA BONILLA, QSR EAST LLC, 1040 KFC LLC and KFC CORPORATION, Defendants. __________________---------------------------------------------_______________Ç RONALD W. RAMIREZ, an attorney duly admitted to practice law before the courts of the State of New York, respectfully states under the penalties of perjury the following: 1. I am a member of the LAW OFFICE OF RONALD W. RAMIREZ, the attorneys of record for Plaintiff herein and, as such, am fully familiar with the facts and circumstances of this action. 2. The sources of your affirmant's information and the grounds for his belief are the pleadings and proceedings in the above-entitled action. 3. I submit this affirmation in opposition to Defendant 1040 KFC LLC's motion to dismiss Plaintiff's complaint or preclude Plaintiff. 4. Annexed hereto as Exhibit 1 is a copy of Plaintiff's Verified Bill of Particulars dated 4/5/22, e-filed on 4/6/22, responding to Defendant 1040 KFC LLC's demand for a billof particulars dated 4/28/21, 5. Annexed hereto as Exhibit 2 are copies of Plaintiff's discovery responses dated 4/5/22, e-filed on 4/6/22, responding to Defendant 1040 KFC LLC's discovery demands dated 4/28/21. 1 of 3 FILED: KINGS COUNTY CLERK 04/15/2022 10:03 AM INDEX NO. 504481/2021 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/15/2022 6. Plaintiff has substantially complied with Defendant 1040 KFC LLC's demand for a billof particulars and demands for discovery (notwithstanding those items objected to) and Defendant's motion to dismiss/preclude should be denied in its entirety. WHEREFORE, itis respectfully requested that Defendant 1040 KFC LLC's motion be denied in its entirety, and for such other and further relief as to this Court may be just and proper. Affirmed: Forest Hills, New York April 15, 2022 RON D W. RAMI Z 2 of 3 FILED: KINGS COUNTY CLERK 04/15/2022 10:03 AM INDEX NO. 504481/2021 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/15/2022 Index No. 504481/21 (J. Montelione) SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS LALITA CREWS, Plaintiff, - against - JAM SERVICES AND REPAIRS LLC, JOSE M. NINA BONILLA, QSR EAST LLC, 1940 KFC LLC and KFC CORPORATION, Defendants. AFFIRMATION IN OPPOSITION LAW OFFICE OF RONALD W. RAMIREZ Attorneys for Plaintiff 107-19 71st Avenue Forest Hills, New York 11375 Tel. No.: (718) 261-6161 Fax No.: (718) 268-3045 RR @ RWRAMIREZ.COM CERTIFICATION: To the best ofthe undersigned's knowledge, information and belief,formed after an inquiry reasonable under the circumstances, the within document(s) and contentions contained therein are not frivolous as defined in 22 NYCRR §130-1.1-a. Dated: Forest Hills, New York April 15, 2022 RO ALD W. RA IRE 3 of 3