On July 12, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Luis Alberto Herrera,
and
Belmont Re, Llc,
Sutter Avenue Realty Co. Llc,
The City Of New York,
Trinchese Iron Works & Construction Inc,
for Torts - Other Negligence (Personal Injury)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 01/28/2021 05:28 PM INDEX NO. 512147/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 01/28/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------x Index No.: 512147/2020(ECF)
LUIS ALBERTO HERRERA,
Plaintiff, AFFIRMATION
v. OF GOOD FAITH
THE CITY OF NEW YORK, BELMONT RE, LLC AND
SUTTER AVENUE REALTY CO., LLC.,
Defendants.
---------------------------------------------------------------------x
SUTTER AVENUE REALTY CO., LLC
Third-Party Plaintiff,
v.
TRINCHESE IRON WORKS & CONSTRUCTION INC.,
Third-Party Defendant,
---------------------------------------------------------------------x
Daniel P. Rocco, under the penalties of perjury, hereby makes the following affirmation:
1. I am an attorney duly licensed to practice law in the Courts of the State of New
York.
2. I make this affirmation in support of the annexed motion.
3. Your affirmant has attempted to obtain the necessary pre-trial disclosure from
plaintiff as indicated by the letter dated December 15, 2020 a copy of which is annexed to the
motion papers.
4. It appears that without the direct intervention of the Court these matters will not
be resolved and the Defendant/Third Party Plaintiff will be delayed to its detriment.
WHEREFORE, it is respectfully requested that the within motion be granted in all
1 of 2
FILED: KINGS COUNTY CLERK 01/28/2021 05:28 PM INDEX NO. 512147/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 01/28/2021
respects and that this Court grant such other and further relief as it deems just and proper.
DATED: January 28, 2021
New York, New York
Daniel P. Rocco
2 of 2
Document Filed Date
January 28, 2021
Case Filing Date
July 12, 2020
Category
Torts - Other Negligence (Personal Injury)
Status
Disposed-Court Date/Application Pending
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: KINGS COUNTY CLERK 01/28/2021 05:28 PM INDEX NO. 512147/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 01/28/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------------x Index No.: 512147/2020(ECF) LUIS ALBERTO HERRERA, Plaintiff, AFFIRMATION v. OF GOOD FAITH THE CITY OF NEW YORK, BELMONT RE, LLC AND SUTTER AVENUE REALTY CO., LLC., Defendants. ---------------------------------------------------------------------x SUTTER AVENUE REALTY CO., LLC Third-Party Plaintiff, v. TRINCHESE IRON WORKS & CONSTRUCTION INC., Third-Party Defendant, ---------------------------------------------------------------------x Daniel P. Rocco, under the penalties of perjury, hereby makes the following affirmation: 1. I am an attorney duly licensed to practice law in the Courts of the State of New York. 2. I make this affirmation in support of the annexed motion. 3. Your affirmant has attempted to obtain the necessary pre-trial disclosure from plaintiff as indicated by the letter dated December 15, 2020 a copy of which is annexed to the motion papers. 4. It appears that without the direct intervention of the Court these matters will not be resolved and the Defendant/Third Party Plaintiff will be delayed to its detriment. WHEREFORE, it is respectfully requested that the within motion be granted in all 1 of 2 FILED: KINGS COUNTY CLERK 01/28/2021 05:28 PM INDEX NO. 512147/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 01/28/2021 respects and that this Court grant such other and further relief as it deems just and proper. DATED: January 28, 2021 New York, New York Daniel P. Rocco 2 of 2