On February 09, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
John W. Crawford Iii,
and
Robin E. Gardner,
for Torts - Motor Vehicle
in the District Court of Niagara County.
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FILED: NIAGARA COUNTY CLERK 11/28/2022 03:41 PM INDEX NO. E174178/2021
NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 11/28/2022
E174178/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NIAGARA
------------------------------------------------------------------X
JOHN W. CRAWFORD III,
Plaintiff, Index No. E174178/2021
-against- COUNTERSTATMENT OF
MATERIAL FACTS
ROBIN E. GARDNER,
Defendant.
------------------------------------------------------------------X
CHI WAI CHUCK CHANG, an attorney duly admitted to practice law before the Courts
of the State of New York, affirms the following to be true, upon information and belief, under
penalties of perjury:
1. Defendant submits that there are genuine issues of material facts as to the issue of
liability.
2. Defendant submits that there are genuine issues of material facts as to the issue of
liability.
3. Plaintiff did not sustain a “serious injury” under New York Insurance Law.
4. Plaintiff did not sustain a “serious injury” under New York Insurance Law.
5. Plaintiff did not sustain a “serious injury” under New York Insurance Law.
6. Plaintiff did not sustain a “serious injury” under New York Insurance Law.
7. Plaintiff did not sustain a “serious injury” under New York Insurance Law.
Dated: Hauppauge, New York
November 28, 2022
_______________________________
CHI WAI CHUCK CHANG
1 of 1
Document Filed Date
November 28, 2022
Case Filing Date
February 09, 2021
Category
Torts - Motor Vehicle
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FILED: NIAGARA COUNTY CLERK 11/28/2022 03:41 PM INDEX NO. E174178/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 11/28/2022 E174178/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NIAGARA ------------------------------------------------------------------X JOHN W. CRAWFORD III, Plaintiff, Index No. E174178/2021 -against- COUNTERSTATMENT OF MATERIAL FACTS ROBIN E. GARDNER, Defendant. ------------------------------------------------------------------X CHI WAI CHUCK CHANG, an attorney duly admitted to practice law before the Courts of the State of New York, affirms the following to be true, upon information and belief, under penalties of perjury: 1. Defendant submits that there are genuine issues of material facts as to the issue of liability. 2. Defendant submits that there are genuine issues of material facts as to the issue of liability. 3. Plaintiff did not sustain a “serious injury” under New York Insurance Law. 4. Plaintiff did not sustain a “serious injury” under New York Insurance Law. 5. Plaintiff did not sustain a “serious injury” under New York Insurance Law. 6. Plaintiff did not sustain a “serious injury” under New York Insurance Law. 7. Plaintiff did not sustain a “serious injury” under New York Insurance Law. Dated: Hauppauge, New York November 28, 2022 _______________________________ CHI WAI CHUCK CHANG 1 of 1