On October 25, 2018 a
No Value
was filed
involving a dispute between
Pietro Scicchitano,
and
Monirul Islam,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 10/06/2022 03:50 PM INDEX NO. 521543/2018
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/06/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
PIETRO SCICCHITANO, Index No.: 521543/2018
Plaintiff,
against- GOOD FAITH
AFFIRMATION
MONIRUL ISLAM,
Defendants.
Stephen F. Doddato, an attorney admitted to practice in the State of New York, affirms
the following under the penalties of perjury:
1. That I am of the law firm of Mirotznik & Associates, LLC, the attorneys of record for
the plaintiff, and as such am thoroughly conversant with the facts and circumstances herein
based upon the contents of the filemaintained by this office.
2. In an attempt to resolve the within discovery issue without the need to resort to
judicial intervention, Plaintiff has contacted defendant's counsel via letter, as well as during
court conferences, and via email, on numerous occasions. Plaintiff has sent a good faith letter
to defendant regarding outstanding deposition. However, the defendant has consistently failed
to comply with not only our demands, but this Court's orders as well.
3. Plaintiff made a good faith effort in his June 23, 2022 letters to defendant to seek the
deposition demanded and to avoid judicial intervention in this discovery matter. Defendant
failed to remedy the discovery issues completely, as they failed to appear for deposition. The
defendants failed to respond to the letter and failed to appear for depositions, thus making the
within motion necessary.
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1 of 2
FILED: KINGS COUNTY CLERK 10/06/2022 03:50 PM INDEX NO. 521543/2018
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/06/2022
WHEREFORE, itis respectfully requested that this motion be granted in its entirety, and
that such other and further relief be granted as to this Court seems just and proper, including the
costs of this motion.
Dated: East Meadow, New York
October 6, 2022
tephen . dato
11
2 of 2
Document Filed Date
October 06, 2022
Case Filing Date
October 25, 2018
Category
Torts - Motor Vehicle
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FILED: KINGS COUNTY CLERK 10/06/2022 03:50 PM INDEX NO. 521543/2018 NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/06/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS PIETRO SCICCHITANO, Index No.: 521543/2018 Plaintiff, against- GOOD FAITH AFFIRMATION MONIRUL ISLAM, Defendants. Stephen F. Doddato, an attorney admitted to practice in the State of New York, affirms the following under the penalties of perjury: 1. That I am of the law firm of Mirotznik & Associates, LLC, the attorneys of record for the plaintiff, and as such am thoroughly conversant with the facts and circumstances herein based upon the contents of the filemaintained by this office. 2. In an attempt to resolve the within discovery issue without the need to resort to judicial intervention, Plaintiff has contacted defendant's counsel via letter, as well as during court conferences, and via email, on numerous occasions. Plaintiff has sent a good faith letter to defendant regarding outstanding deposition. However, the defendant has consistently failed to comply with not only our demands, but this Court's orders as well. 3. Plaintiff made a good faith effort in his June 23, 2022 letters to defendant to seek the deposition demanded and to avoid judicial intervention in this discovery matter. Defendant failed to remedy the discovery issues completely, as they failed to appear for deposition. The defendants failed to respond to the letter and failed to appear for depositions, thus making the within motion necessary. 10 1 of 2 FILED: KINGS COUNTY CLERK 10/06/2022 03:50 PM INDEX NO. 521543/2018 NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 10/06/2022 WHEREFORE, itis respectfully requested that this motion be granted in its entirety, and that such other and further relief be granted as to this Court seems just and proper, including the costs of this motion. Dated: East Meadow, New York October 6, 2022 tephen . dato 11 2 of 2