On January 23, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Janet Vega
As Mother And Natural Guardian Of F. R., An Infant, And Janet Vega, Individually,
and
Jewish Child Care Association Of New York,
Sco Family Of Services,
The City Of New York,
The New York City Administration For Children'S Services,
for Torts - Other Negligence (Foster Care Abuse)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 05/26/2020 06:45 PM INDEX NO. 154880/2018
NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 05/26/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------------X
JANET VEGA, as mother and natural guardian of F.R., an Index No. 154880/2018
infant, and JANET VEGA, Individually, Date Filed: 5/23/2018
Plaintiff(s), AFFIRMATION OF
GOOD FAITH
-against-
THE CITY OF NEW YORK, THE NEW YORK CITY
ADMINSTRATION FOR CHILDREN'S SERVICES, SCO
FAMILY OF SERVICES and JEWISH CHILD CARE
ASSOCIATION OF NEW YORK,
Defendant(s).
--------------------------------------------------------------------X
ROBERT S. DELMOND, an attorney admitted to practice law in the Courts
of the State of New York, hereby affirms the following statements under penalties of perjury
pursuant to CPLR § 2106:
1. I am A member of the law firm of CONWAY, FARRELL, CURTIN &
KELLY, P.C., attorneys for the Defendants, THE CITY OF NEW YORK,THE NEW
YORK CITY ADMINSTRATION FOR CHILDREN'S SERVICES and SCO FAMILY
OF SERVICES, in the captioned case, and I am fully familiar with the facts and circumstances
of this action.
2. This Affirmation is respectfully submitted in compliance with the
Special Rules of this Court relating to motions of a nature that is annexed hereto
3. The parties discussed the plaintiff’s demand and could not reach an
agreement as to whether any documents were subject to disclosure therefore intervention of the
Court is required to resolve this issue.
4. Affirmant states that a good faith effort to resolve by agreement the
dispute which is the subject matter of the annexed motion has been made, and that the within
dispute cannot be resolved without court intervention.
FILED: NEW YORK COUNTY CLERK 05/26/2020 06:45 PM INDEX NO. 154880/2018
NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 05/26/2020
Dated: New York, New York
May 26, 2020
________________________________
ROBERT S. DELMOND
FILED: NEW YORK COUNTY CLERK 05/26/2020 06:45 PM INDEX NO. 154880/2018
NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 05/26/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------------X
JANET VEGA, as mother and natural guardian of F.R., an Index No. 154880/2018
infant, and JANET VEGA, Individually, Date Filed: 5/23/2018
Plaintiff(s),
-against-
THE CITY OF NEW YORK, THE NEW YORK CITY
ADMINSTRATION FOR CHILDREN'S SERVICES, SCO
FAMILY OF SERVICES and JEWISH CHILD CARE
ASSOCIATION OF NEW YORK,
Defendant(s).
--------------------------------------------------------------------X
NOTICE OF MOTION and
AFFIRMATION IN SUPPORT with Supporting Exhibits
Pursuant to 22 NYCRR §130-1.1-a, the undersigned, an Attorney admitted to practice law in the
Courts of the State of New York, does hereby certify the attached papers.
______________________________
Document Filed Date
May 26, 2020
Case Filing Date
January 23, 2018
Category
Torts - Other Negligence (Foster Care Abuse)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: NEW YORK COUNTY CLERK 05/26/2020 06:45 PM INDEX NO. 154880/2018 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 05/26/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------X JANET VEGA, as mother and natural guardian of F.R., an Index No. 154880/2018 infant, and JANET VEGA, Individually, Date Filed: 5/23/2018 Plaintiff(s), AFFIRMATION OF GOOD FAITH -against- THE CITY OF NEW YORK, THE NEW YORK CITY ADMINSTRATION FOR CHILDREN'S SERVICES, SCO FAMILY OF SERVICES and JEWISH CHILD CARE ASSOCIATION OF NEW YORK, Defendant(s). --------------------------------------------------------------------X ROBERT S. DELMOND, an attorney admitted to practice law in the Courts of the State of New York, hereby affirms the following statements under penalties of perjury pursuant to CPLR § 2106: 1. I am A member of the law firm of CONWAY, FARRELL, CURTIN & KELLY, P.C., attorneys for the Defendants, THE CITY OF NEW YORK,THE NEW YORK CITY ADMINSTRATION FOR CHILDREN'S SERVICES and SCO FAMILY OF SERVICES, in the captioned case, and I am fully familiar with the facts and circumstances of this action. 2. This Affirmation is respectfully submitted in compliance with the Special Rules of this Court relating to motions of a nature that is annexed hereto 3. The parties discussed the plaintiff’s demand and could not reach an agreement as to whether any documents were subject to disclosure therefore intervention of the Court is required to resolve this issue. 4. Affirmant states that a good faith effort to resolve by agreement the dispute which is the subject matter of the annexed motion has been made, and that the within dispute cannot be resolved without court intervention. FILED: NEW YORK COUNTY CLERK 05/26/2020 06:45 PM INDEX NO. 154880/2018 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 05/26/2020 Dated: New York, New York May 26, 2020 ________________________________ ROBERT S. DELMOND FILED: NEW YORK COUNTY CLERK 05/26/2020 06:45 PM INDEX NO. 154880/2018 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 05/26/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------X JANET VEGA, as mother and natural guardian of F.R., an Index No. 154880/2018 infant, and JANET VEGA, Individually, Date Filed: 5/23/2018 Plaintiff(s), -against- THE CITY OF NEW YORK, THE NEW YORK CITY ADMINSTRATION FOR CHILDREN'S SERVICES, SCO FAMILY OF SERVICES and JEWISH CHILD CARE ASSOCIATION OF NEW YORK, Defendant(s). --------------------------------------------------------------------X NOTICE OF MOTION and AFFIRMATION IN SUPPORT with Supporting Exhibits Pursuant to 22 NYCRR §130-1.1-a, the undersigned, an Attorney admitted to practice law in the Courts of the State of New York, does hereby certify the attached papers. ______________________________