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  • Lalita Crews v. Jam Services And Repairs Llc, Jose M. Nina Bonilla, Qsr East Llc, 1040 Kfc Llc, Kfc CorporationTorts - Other Negligence (injury on deft premises) document preview
  • Lalita Crews v. Jam Services And Repairs Llc, Jose M. Nina Bonilla, Qsr East Llc, 1040 Kfc Llc, Kfc CorporationTorts - Other Negligence (injury on deft premises) document preview
  • Lalita Crews v. Jam Services And Repairs Llc, Jose M. Nina Bonilla, Qsr East Llc, 1040 Kfc Llc, Kfc CorporationTorts - Other Negligence (injury on deft premises) document preview
  • Lalita Crews v. Jam Services And Repairs Llc, Jose M. Nina Bonilla, Qsr East Llc, 1040 Kfc Llc, Kfc CorporationTorts - Other Negligence (injury on deft premises) document preview
  • Lalita Crews v. Jam Services And Repairs Llc, Jose M. Nina Bonilla, Qsr East Llc, 1040 Kfc Llc, Kfc CorporationTorts - Other Negligence (injury on deft premises) document preview
  • Lalita Crews v. Jam Services And Repairs Llc, Jose M. Nina Bonilla, Qsr East Llc, 1040 Kfc Llc, Kfc CorporationTorts - Other Negligence (injury on deft premises) document preview
  • Lalita Crews v. Jam Services And Repairs Llc, Jose M. Nina Bonilla, Qsr East Llc, 1040 Kfc Llc, Kfc CorporationTorts - Other Negligence (injury on deft premises) document preview
  • Lalita Crews v. Jam Services And Repairs Llc, Jose M. Nina Bonilla, Qsr East Llc, 1040 Kfc Llc, Kfc CorporationTorts - Other Negligence (injury on deft premises) document preview
						
                                

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LAWOFFICE OF RONALDW.RAMIREZ OFFICE MANAGER: LEGAL ASSISTANT ATTORNEY AT LAW sUZANNE SHEAR 7. sÄ WENDY MADDEN 9 7 FOREST HILLS, N.Y. 1 1 375-4762 (7 1 8) 26 1 -6 1 6 1 F AX: (7 1 8) 268-3045 RR @ RWRAMIREZ.COM June 23, 2022 Hon. Richard J.Montelione Part 99 Supreme Court, Kings County 360 Adams Street Brooklyn, NY 11210 Re: Crews v. JAM Services and Repairs LLC et al. Index No.: 504481/21 Your Honor: I represent the plaintiff in this action who was injured in an accident at the KFC Restaurant located at 1040 Bedford Avenue, Brooklyn, New York on 3/11/20. I fileda motion on behalf of plaintiff(Mot. Seq. #1) returnable on 6/1/22 seeking an order permitting the entry of plaintiff's counsel and expert onto the aforesaid premises for the purposes of performing an inspection of, testing of and taking photographs of the pressure fryer that was involved in the subject accident. On 5/13/22 I e-filed a letterto the Court, a copy of which is attached, requesting that plaintiff's 6/1/22 motion be adjourned to 6/29/22 to allow for the inspection to take place. On 5/31/22 I e-filed a letterto the Court, a copy of which is attached, advising that the inspection had taken place on 5/31/22 as scheduled, and requested that the 6/1/22 motion be withdrawn. Inaddition, on 6/1/22 I e-fileda Stipulation of Discontinuance only as against defendant QSR East LLC, a copy of which isattached. According to eCourts, plaintiff's 6/1/22 motion has been adjourned and now appears on your calendar on 7/20/22. At thistime, Iagain respectfully request that plaintiff's motion be withdrawn. Ifthere isanything further I must do to have this motion withdrawn, please contact me and letme know. Res tfully, RWR:wm R NALD W. AMI cc: QSR East LLC via email to: craig@valuefoodservice.com denise.springer@valuefoodservice.com NYSCEF DOC. NO. 55 RECEIVED NYSCEF: 05/13/2022 LAw OFFICE OF RONALD W. RAMIREZ OFFICE MANAGER. LEGAL ASSISTANT: AÀORNEY AT LAW sUZANNE SHEAR 07. w WENDY MADDEN 7 AVENUE FOREST HILLS, N.Y. 1 1 375-4762 (7 1 8) 2 6 1 -6 1 6 1 F AX: (7 1 8) 268-3045 RR @ RWRAMIREZ.COM May (3, 2022 Hon. Richard J. Montelione Part 99 Supreme Court, Kings County 360 Adams Street Brooklyn, NY 1 1210 Re: Crews v. JAM Services and Repairs LLC et al. Index No,: 504481/21 Your Honor: 1 represent the plaintiff in this action who was injured in an accident at the KFC Restaurant located at 1040 Bedford Avenue, Brooklyn, New York on 3/11/20. Subsequent to the accident the premises were transferred to defendant QSR East LLC. Plaintiff's motion returnable on 6/1/22 (Mot. Seq. #1) seeks an order the permitting entry of plaintiff's counsel and expert onto the aforesaid premises for the puÆoses of an performing inspection of, testing of and taking photographs of the pressure fryer that was involved in the subject accident. I have been in contact with defendant QSR East LLC and they have agreed to allow the inspection to be held on 5/31/22, the day before the return date of the motion. It is,therefore, respectfully requested that plaintiff's motion be adjourned to June 29, 2022. After the inspection has taken place, l expect to be able to withdraw the motion and file a Stipulation of Discontinuance dismissing the action as against defendant QSR East LLC. Thank you for your courtesy in this matter. V truly y urs -f RWR:wm ONALD W. cc: QSR East LLC via email to: craig@valuefoodservice.com denise.springer@valuefoodservice.com 1 o f 1 NYSCEF Confirmation Notice Kings County Supreme Court The NYSCEF website has received an electronic filingon 05/13/2022 02:21 PM. Please keep this notice as a confirmation of thisfiling. 504481/2021 Lalita Crews v. JAM Services and Repairs LLC et ai Assigned judge: Richard Montellone Documents Received on 05/13/2022 02:21 PM DoC # Document Type 55 ADjOURNMENT OF MOTION -REQUEST, Motion #1 Filing User Ronald W Ramirez | RR@RWRamirez.com | 718-261-6161 107-19 71st Avenue, Forest Hills, NY 11375 E-mail Notifications An email regarding thisfilinghas been sent to the following on 05/13/2022 02:21 PM: MEGAN F. ORGANEK - organek@hagelinspencer.com RONALD W. RAMIREZ - RR@RWRamirez.com RICHARD A. SALVATO - Richard.A.Salvato@peircesalvato.com SEAN M. SPENCER - spencer@hagellnspencer.com RHONDA D. THOMPSON - thomr5@nationwide.com KELLY M. ZIC - kelly.m.zic@peircesalvato.com MARIA ZOUROS - mzouros@gvlaw.com Hon. T. Sunshine, Kings Clerk and Clerk of the supreme Court - kcco-efile@nycourts.gov Nancy County Phone: Phone: 347-404-9766 or 347-404-9762 Website: https://www.nycourts.gov/courts/2jd/kingsclerk/index.shtmI NYSCEF Resource Center, nyscef@nycourts.gov Phone: (646) 386-3033 | Fax: (212) 401-9146 | Website: www.nycourts.gov/efile Page 1 of 2 NYSCEF Confirmation Notice Kings County Supreme Court 504481/2021 Lalita Crews v-JAM Services and Repairs LLC at al Assignedjudge: Richard Montellone Email Notifications NOT Sent Role Party Attorney Respondent QSR East LLC No consent on record. * Court rulesrequire hard service upon parties and attorneys who have opted-out or declined copy non-participating consent. Hon. T. Sunshine, Kings Clerk and Clerk of the Supreme Court - kcco-efile@nycourts.gov Nancy County Phone: Phone: 347-404-9766 or 347-404-9762 website: https://www.nycourts.gov/courts/2jd/kingsclerk/index.shtml NYSCEF Resource Center, nyscef@nycourts.gov Phone: (646) 386-3033 | Fax: (212) 401-9146 | Website: www.nycourts.gov/efile Page 2 of 2 LAw OFFICE OF RONALD W. RAMIREZ OFFICE MANAGER LEGAL ASSISTANT ATTORNEY AT LAW SU2ANNE SHEAR Q7. ST WENDY MADDEN 9 7 AVENW FOREST HILLS, N.Y.1 1375-4762 (7 1 8) 26 1 -6 1 6 1 F A X: (7 1 8) 268-3045 RR@ RWRAMIREZ.COM May J/, 2022 Hon. Richard J. Montelione Part 99 Supreme Court, Kings County 360 Adams Street Brooklyn, NY I1210 Re: Crews v. JAM Services and Repairs LLCet al. Index No.: 504481/21 Your Honor: I represent the plaintiff in this action who was injured in an accident at the KFC Restaurant located at 1040 Bedford Avenue, Brooklyn, New York on 3/11/20. Plaintiff's motion (Mot. Seq. #1), which is returnable before you on 6/1/22, seeks an order permitting the entry of plaintiff's counsel and expert onto the aforesaid premises for the purposes of performing an inspection of, testing of and taking photographs of the pressure fryer that was involved in the subject accident. Please be advised that the inspection of the aforesaid pressure fryer was conducted today. Accordingly, please withdraw plaintiff's 6/1/22 motion. Thank you for your courtesy in this matter. If you have any questions or concerns, please contact me. V truly o RWR:wm ONALD W. R MIREZ cc: QSR East LLC via email to: craig@valuefoodservice.com denise.springer@val.uefoodservice.com . NYSCEF Confirmation Notice Kings County Supreme Court The NYSCEF website has received an electronic filingon 05/31/2022 02:03 PM. Please keep this notice as a confirmation of thisfiling. 504481/2021 Lalita Crews v. JAM Services and Repairs LLC et al Assigned Judge: Richard Monte1lone Documents Received on 05/31/2022 02:03 PM Doc # Document Type 58 LETTER / CORRESPONDENCE TO JUDGE, Motion #1 Filing User Ronald W Ramirez | RR@RWRamirez.com | 718-261-6161 107-19 71st Avenue, Forest Hills, NY 11375 E-mail Notifications An email regarding thisfilinghas been sent to the following on 05/31/2022 02:03 PM: MEGAN F. ORGANEK - organek@hagelinspencer.com RONALD W. RAMIREZ - RR@RWRamirez.com RICHARD A. SALVATO - Richard.A.Salvato@peircesalvato.com SEAN M. SPENCER - spencer@hagelinspencer.com RHONDA D. THOMPSON - thomr5@nationwide.com KELLY M. ZIC - kelly.m.zic@peircesalvato.com MARIA ZOUROS - mzouros@gvlaw.com Hon. T. Sunshine, Kings Clerk and Clerk of the supreme Court - kcco-efile@nycourts.gov Nancy County Phone: Phone: 347-404-9766 or 347-404-9762 Website: https://www.nycourts.gov/courts/2jd/kingsclerk/index.shtml NYSCEF Resource Center, nyscef@nycourts.gov Phone: (646) 386-3033 | Fax: (212) 401-9146 | Website: www.nycourts.gov/efile Page 1 of 2 NYSCEF Confirmation Notice Kings County Supreme Court 504481/2021 Lalita Crews v. JAM Services and Repairs LLC et al Assigned Judge: Richard Montellone Email Notifications NOT Sent Role Party Attorney Respondent QSR East LLC No consent on record. * Court rulesrequire hard serviceupon partiesand attorneys who have opted-out or declined copy non-participating consent. Hon. T. Sunshine, Kings County Clerk and Clerk of the Supreme Court - kcco-efile@nycourts.gov Nancy Phone: Phone: 347-404-9766 or 347-404-9762 Website: https://www.nycourts.gov/courts/2jd/kingsclerk/index.shtml NYSCEF Resource Center, nyscef@nycourts.gov Phone: (646) 386-3033 | Fax: (212) 401-9146 | Website: www.nycourts.gov/efile Page 2 of 2 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 06/01/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------.---------------..-----------------------------Ç LALITA CREWS, STIPULATION Plaintiff. DISCONTINUING ACTION ONLY - against - AGAINST DEFENDANT QSR JAM SERVICES AND REPAIRS LLC, JOSE M. EAST LLC NINA BONILLA, QSR EAST LLC, 1040 KFC LLC and KFC CORPORATION, Index No.: 504481/2021 Defendants. --------------------------------------------------------------Ç IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned, the attorneys of record for the plaintiff to the above-entitled action, that whereas no party hereto is an infant or incompetent person for whom a committee has been appointed and no person not a party has an interest in the subject matter of the action, the above-entitled action be, and the same hereby is discontinued only as against defendant QSR EAST LLC, with prejudice, without costs to either party as against the other. Dated: Forest Hills,New York June 1, 2022 LA OFF OF AL . MIREZ By: Ronald W. Attorneys for Plaintiff 71" 107-19 Avenue Forest Hills, New York 11375 (718) 261-6161 1 of 1 NYSCEF Confirmation Notice Kings County Supreme Court The NYSCEF website has received an electronic filingon 06/01/2022 03:00 PM. Please keep this notice as a confirmation of thisfiling. 504481/2021 Latita Crews v. JAM Services and Repairs LLC et al Assigned Judge: Richard Montellone Documents Received on 06/01/2022 03:00 PM Doc # Document Type 60 STIPULATION - PARTIAL DISCONTINUANCE (POST RJI) Filing User Ronald W Ramirez | RR@RWRamirez.com | 718-261-6161 107-19 71st Avenue, Forest Hills, NY 11375 E-mail Notifications An email regarding thisfilinghas been sent to thefollowing on 06/01/2022 03:00 PM: MEGAN F. ORGANEK - organek@hagelinspencer.com RONALD W. RAMIREZ - RR@RWRamirez.com RICHARD A. SALVATO - Richard.A.Salvato@pelrcesalvato.com SEAN M. SPENCER - spencer@hagelinspencer.com RHONDA D. THOMPSON - thomr5@nationwide.com KELLY M. ZIC - kelly.m.zic@pelrcesalvato.com MARIA ZOUROS - mzouros@gulaw.com Hon. Nancy T. Sunshine, Kings County Clerk and Clerk of the Supreme Court - kcco-efile@nycourts.gov Phone: Phone: 347-404-9766 or 347-404-9762 Website: https://www.nycourts.gov/courts/2jd/kingsclerk/index.shtmi NYSCEF Resource Center, nyscef@nycouns.gov Phone: (646) 386-3033 | Fax: (212) 401-9146 | Website: www.nycourts.gov/efile Page 1 of2 NYSCEF Confirmation Notice Kings County Supreme Court 504481/2021 Lalita Crews v. JAM Services and Repairs LLC et al Assigned Judge: Richard Montellone Email Notifications NOT Sent Role Party Attorney Respondent QSR East LLC No consent on record. * Court rulesrequire hard service upon parties and attorneys who have opted-out or declined copy non-participating consent. Hon. T. sunshine, Kings Clerk and Clerk of the Supreme Court - kcco-efile@nycourts.gov Nancy County Phone: Phone: 347-404-9766 or 347-404-9762 Website: https://www.nycourts.gov/courts/2jd/kingsclerk/Index.shtml NYSCEF Resource Center, nyscaf@nycourts.gov Phone: (646) 386-3033 | Fax: (212) 401-9146 | Website: www.nycourts.gov/efile Page 2 of 2