On October 25, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Brayan Terrazas,
and
Arlene Hershberg,
The City Of New York,
for Torts - Other Negligence (205-e)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 09/06/2022 01:50 PM INDEX NO. 520642/2017
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 09/06/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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BRAYAN TERRAZAS,
GOOD FAITH AFFIRMATION
Plainitff,
Index No.: 520642/17
-against-
THE CITY OF NEW YORK and
ARLENE HERSHBERG,
Defendants.
-------------------------------------------------------------------X
ALEXA RISSOFF, an attorney duly admitted to practice law in the Courts of the State of
New York and affirm the following under the penalty of perjury:
I am an associate with the LAW OFFICES OF TERRENCE F. KUHN, attorneys for the
defendant ARLENE HERSHBERG and as such, I am fully familiar with the fact and
circumstances of the above-captioned action,
This office has unsuccessfully attempted, in good faith to resolve by agreement the issues
raised by the attached motion. The nature of our efforts to resolve this motion were defendants’
Demands dated May 19, 2020 and Good Faith Letter served on September 21, 2020 and e-filed on
October 7, 2020, and Post EBT Demand. To date, plaintiff has not provided a complete response
to our demands or good faith letter, and as such necessitating the need for this motion.
WHEREFORE, it is respectfully requested that the relief requested herein be granted in
its entirety, along with such other relief as this court may deem just and proper.
Dated: September 6, 2022
New York, New York
Alexa Rissoff, Esq.
1 of 1
Document Filed Date
September 06, 2022
Case Filing Date
October 25, 2017
Category
Torts - Other Negligence (205-e)
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FILED: KINGS COUNTY CLERK 09/06/2022 01:50 PM INDEX NO. 520642/2017 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 09/06/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------X BRAYAN TERRAZAS, GOOD FAITH AFFIRMATION Plainitff, Index No.: 520642/17 -against- THE CITY OF NEW YORK and ARLENE HERSHBERG, Defendants. -------------------------------------------------------------------X ALEXA RISSOFF, an attorney duly admitted to practice law in the Courts of the State of New York and affirm the following under the penalty of perjury: I am an associate with the LAW OFFICES OF TERRENCE F. KUHN, attorneys for the defendant ARLENE HERSHBERG and as such, I am fully familiar with the fact and circumstances of the above-captioned action, This office has unsuccessfully attempted, in good faith to resolve by agreement the issues raised by the attached motion. The nature of our efforts to resolve this motion were defendants’ Demands dated May 19, 2020 and Good Faith Letter served on September 21, 2020 and e-filed on October 7, 2020, and Post EBT Demand. To date, plaintiff has not provided a complete response to our demands or good faith letter, and as such necessitating the need for this motion. WHEREFORE, it is respectfully requested that the relief requested herein be granted in its entirety, along with such other relief as this court may deem just and proper. Dated: September 6, 2022 New York, New York Alexa Rissoff, Esq. 1 of 1