On November 18, 2020 a
Party Notice
was filed
involving a dispute between
Patrick Ford,
and
Ysmael A. Torres,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022
SUPREME COURT OF STATE OF NEW YORK Index No. 522897/20
COUNTY OF KINGS
PATRICK FORD,
NOTICE TO ADMIT
PLAINTIFF(S)
FILE NO. 1084880
-Against-
YSMAEL TORRES,
DEFENDANT(S)
PURSUANT TO CPLR 3123, Defendant by their attorneys, Baker, McEvoy & Moskovits,
P.C., respectfully requests plaintiff Dashaun Shan Knight, admit or deny the following:
1. The photographs attached hereto demonstrate a fair and accurate depiction of the property
damage sustained to the 2007 Honda Odyssey EX-L following the occurrence and prior
to the repair of same.
Dated: New York, New York
September 9, 2022
To:
Cassisi & Cassisi, P.C. Baker, McEvoy & Moskovits, P.C.
Attorney for Plaintiff(s)
Patrick Ford
155 First Street, Suite 101
Mineola, New York 11501 ________________________________
By: Ronit Moskovits, Esq.
Attorneys for Defendants
5 Broadway, Suite 3
Freeport, New York 11520
(212) 857-8230
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06 07
ALABAMA, LLC
MFG. OF SlZE
HONDA RIM
MFD. BY HRE SlZE
2700KG(5952LBS) 16X7J
235/65R16 103T
G'WR
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SHJ 7
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AFFIRMATION OF SERVICE BY MAIL
STATE OF NEW YORK )
) SS:
COUNTY OF NEW YORK )
I, Ronit Moskovits, an attorney duly admitted to practice law before the Courts of the State of
New York, affirms the following to be true to under the penalty of perjury pursuant to CPLR
2106:
That I am not a party to this action; am over 18 years of age, and resides in New York County,
New York.
That on September 9, 2022, I served the within NOTICE TO ADMIT with accompanying
exhibits and attachments upon the attorneys listed below, at their listed addresses which were so
designated by said attorneys for said purpose, by depositing a true copy of same enclosed in a
post paid properly addressed wrapper in a post office under the exclusive care and custody of the
U.S. Postal Service within the State of New York.
To:
Cassisi & Cassisi, P.C.
Attorney for Plaintiff(s)
Patrick Ford
155 First Street, Suite 101
Mineola, New York 11501
________________________
Ronit Moskovits, Esq.
43 of 44
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SUPREME COURT OF THE STATE OF NEW YORK Index No. 522897/20
COUNTY OF KINGS
----------------------------------------------------------------------X
PATRICK FORD,
Plaintiff,
-against- FILE NO. 1084880
YSMAEL TORRES,
Defendants,
------------------------------------------------------------------------X
___
___________________ ________________ ______________________________
NOTICE TO ADMIT
Baker, McEvoy & Moskovits, P.C.
Attorneys for Defendant:
Office and Post Office Address, Telephone
Five Broadway
Freeport, New York 11520
(212)-857-8230
To:
Cassisi & Cassisi, P.C.
Attorney for Plaintiff(s)
Patrick Ford
155 First Street, Suite 101
Mineola, New York 11501
Service of a copy of the within
Is hereby admitted
Dated,
Attorney(s) for
____________________________________ ______________________________
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Document Filed Date
September 09, 2022
Case Filing Date
November 18, 2020
Category
Torts - Motor Vehicle
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 SUPREME COURT OF STATE OF NEW YORK Index No. 522897/20 COUNTY OF KINGS PATRICK FORD, NOTICE TO ADMIT PLAINTIFF(S) FILE NO. 1084880 -Against- YSMAEL TORRES, DEFENDANT(S) PURSUANT TO CPLR 3123, Defendant by their attorneys, Baker, McEvoy & Moskovits, P.C., respectfully requests plaintiff Dashaun Shan Knight, admit or deny the following: 1. The photographs attached hereto demonstrate a fair and accurate depiction of the property damage sustained to the 2007 Honda Odyssey EX-L following the occurrence and prior to the repair of same. Dated: New York, New York September 9, 2022 To: Cassisi & Cassisi, P.C. Baker, McEvoy & Moskovits, P.C. Attorney for Plaintiff(s) Patrick Ford 155 First Street, Suite 101 Mineola, New York 11501 ________________________________ By: Ronit Moskovits, Esq. Attorneys for Defendants 5 Broadway, Suite 3 Freeport, New York 11520 (212) 857-8230 1 of 44 FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 2 of 44 FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 3 of 44 FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 4 of 44 scang2 FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 .- -.... --- 5 USAA of 44 Confieleretsal 0901119ca78252h5 FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 0901119ca7825ths ace6 of 44 . FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 128BKO 833088 235 86R18 1937 18X7J QA IttF 3197085 235 65R16 1937 SSK7J QAWR R 14BOKG THis VIHlCLE CONF ORMS TO ALL APPLICASLE S L DI RAL MO1OR VIHlCLE SAF E TY AND 1HEIT PRLVINTSON STANDAROS IN E F F E C T ON 1HE DAll Of MANUF AC T URE SHOWN ABOVE v i n SFNRL387978452266 T YPE : MPV stanunnanmpuse SMJ 7 AOB - NH578 - F 7 of acensw.mmi 44 0901119ca7825ths FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 0901119ca7825ths ace8 of 44 . FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 0901119ca7825ths ace9 of 44 . FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 ace10 of 44 . 0901119ca7825ths FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. 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BY HRE SlZE 2700KG(5952LBS) 16X7J 235/65R16 103T G'WR 1285KG(2833LBS) 16X7J 103T GAWR F 235/65R16 R1450KG(3197LBS) GAWR APPLICASLE CONFORMS TO ALL VEHlCLE TMlS SAFETY VEHICLE FEDERAL MOTOR 7 EFFECT PREVENTION STANDA AMD THEFT iuwN ABOVE. MANUFACTURE S DATE OF ON THE MPV 5FMRL38797B452266 TYPE: VLM B5581M11M5 - AD6 - NH578 -F g SHJ 7 28 of 44 0901119ca7sa4the FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 ace29 of 44 . 0901119ca7984th4 FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 . ace30 of 44 . t i 0901119ca7984th4 FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 ace31 of 44 . 0901119ca7984th4 FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. 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NO. 17 RECEIVED NYSCEF: 09/09/2022 AFFIRMATION OF SERVICE BY MAIL STATE OF NEW YORK ) ) SS: COUNTY OF NEW YORK ) I, Ronit Moskovits, an attorney duly admitted to practice law before the Courts of the State of New York, affirms the following to be true to under the penalty of perjury pursuant to CPLR 2106: That I am not a party to this action; am over 18 years of age, and resides in New York County, New York. That on September 9, 2022, I served the within NOTICE TO ADMIT with accompanying exhibits and attachments upon the attorneys listed below, at their listed addresses which were so designated by said attorneys for said purpose, by depositing a true copy of same enclosed in a post paid properly addressed wrapper in a post office under the exclusive care and custody of the U.S. Postal Service within the State of New York. To: Cassisi & Cassisi, P.C. Attorney for Plaintiff(s) Patrick Ford 155 First Street, Suite 101 Mineola, New York 11501 ________________________ Ronit Moskovits, Esq. 43 of 44 FILED: KINGS COUNTY CLERK 09/09/2022 01:39 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 09/09/2022 SUPREME COURT OF THE STATE OF NEW YORK Index No. 522897/20 COUNTY OF KINGS ----------------------------------------------------------------------X PATRICK FORD, Plaintiff, -against- FILE NO. 1084880 YSMAEL TORRES, Defendants, ------------------------------------------------------------------------X ___ ___________________ ________________ ______________________________ NOTICE TO ADMIT Baker, McEvoy & Moskovits, P.C. Attorneys for Defendant: Office and Post Office Address, Telephone Five Broadway Freeport, New York 11520 (212)-857-8230 To: Cassisi & Cassisi, P.C. Attorney for Plaintiff(s) Patrick Ford 155 First Street, Suite 101 Mineola, New York 11501 Service of a copy of the within Is hereby admitted Dated, Attorney(s) for ____________________________________ ______________________________ 44 of 44