On August 03, 2015 a
Exhibit,Appendix
was filed
involving a dispute between
Tanya Mallory,
and
Consolidated Edison Company Of New York, Inc.,
Jacob A. Rivers,
Robinson S. Kassiem,
The City Of New York,
Verizon New York, Inc.,
for Tort
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 09/19/2022 02:07 PM INDEX NO. 452540/2015
NYSCEF DOC. NO. 152 RECEIVED NYSCEF: 09/19/2022
EXHIBIT M
FILED: NEW YORK COUNTY CLERK 09/19/2022 02:07 PM INDEX NO. 452540/2015
NYSCEF DOC. NO. 152 RECEIVED NYSCEF: 09/19/2022
SUPREME COURT OF TIIE STATE OF NEW YORK
COUNTY OF NEW YORK
______________________________________..____________________Ç
TANYA MALLORY,
Plaintiff, Index No. 157104/2016
-against- AFFIDAVIT
CONSOLIDATED EDISON COMPANY OF NEW
YORK, INC.,and VERIZON NEW YORK, INC.,.
Defendants.
______________------....._________________________________________Ç
NAI ZHANG, being duly sworn deposes and states under penalty of perjury:
1. I am employed by the Defendant VERIZON NEW YORK INC. i/s/h/a
VERIZON NEW YORK, INC., (hereafter VERIZON) as an Engineering
Specialist- Network
Engineering and Operations. I have worked for VERIZON, and itspredecessors since June 1989.
I am responsible for VERIZON facilities for the territory of Manhattan that is composed of the
640' 130th
area north of East Street, south of East Street, west of the FDR and Ilarlem River Drives
and cast of Fifth/Lennox Avenues. This territory includes the accident location: the intersection of
86th
East Street and First Avenue, in the City, County and State of New York.
2. 1 am familiar with the location of manholes owned by VERIZON in the
territory for which I am responsible, and have also consulted the records of VERIZON regarding
same,
3. VERIZON does not, nor did itat the time of plaintiff's accident on October
86th
2, 2013, own, install or maintain any manholes within the intersection of East Street and First
Avenue in the City, County and State of New York.
1-23-2017 B533115438000101 5820170123000214
FILED: NEW YORK COUNTY CLERK 09/19/2022 02:07 PM INDEX NO. 452540/2015
NYSCEF DOC. NO. 152 RECEIVED NYSCEF: 09/19/2022
Dated: New York, New York
January , 2017
NAI ZHANG
Sworn to before me on this
day of Jaeaary , 20+7
GEANCARLO CARDENAS
Notary Public
State of New Jersey
My Commission ExpiresMar. 25, 2025
I.D.#50012822
1-23-2017
B533115438000101
582017012300021
Document Filed Date
September 19, 2022
Case Filing Date
August 03, 2015
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: NEW YORK COUNTY CLERK 09/19/2022 02:07 PM INDEX NO. 452540/2015 NYSCEF DOC. NO. 152 RECEIVED NYSCEF: 09/19/2022 EXHIBIT M FILED: NEW YORK COUNTY CLERK 09/19/2022 02:07 PM INDEX NO. 452540/2015 NYSCEF DOC. NO. 152 RECEIVED NYSCEF: 09/19/2022 SUPREME COURT OF TIIE STATE OF NEW YORK COUNTY OF NEW YORK ______________________________________..____________________Ç TANYA MALLORY, Plaintiff, Index No. 157104/2016 -against- AFFIDAVIT CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.,and VERIZON NEW YORK, INC.,. Defendants. ______________------....._________________________________________Ç NAI ZHANG, being duly sworn deposes and states under penalty of perjury: 1. I am employed by the Defendant VERIZON NEW YORK INC. i/s/h/a VERIZON NEW YORK, INC., (hereafter VERIZON) as an Engineering Specialist- Network Engineering and Operations. I have worked for VERIZON, and itspredecessors since June 1989. I am responsible for VERIZON facilities for the territory of Manhattan that is composed of the 640' 130th area north of East Street, south of East Street, west of the FDR and Ilarlem River Drives and cast of Fifth/Lennox Avenues. This territory includes the accident location: the intersection of 86th East Street and First Avenue, in the City, County and State of New York. 2. 1 am familiar with the location of manholes owned by VERIZON in the territory for which I am responsible, and have also consulted the records of VERIZON regarding same, 3. VERIZON does not, nor did itat the time of plaintiff's accident on October 86th 2, 2013, own, install or maintain any manholes within the intersection of East Street and First Avenue in the City, County and State of New York. 1-23-2017 B533115438000101 5820170123000214 FILED: NEW YORK COUNTY CLERK 09/19/2022 02:07 PM INDEX NO. 452540/2015 NYSCEF DOC. NO. 152 RECEIVED NYSCEF: 09/19/2022 Dated: New York, New York January , 2017 NAI ZHANG Sworn to before me on this day of Jaeaary , 20+7 GEANCARLO CARDENAS Notary Public State of New Jersey My Commission ExpiresMar. 25, 2025 I.D.#50012822 1-23-2017 B533115438000101 582017012300021