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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had taken place on 5/31/22 as scheduled, and requested that the 6/1/22 motion be withdrawn.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At thistime, Iagain respectfully request that plaintiff's motion be withdrawn.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further I must do to have this motion withdrawn, please contact me and letme know.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