Exhibit,Appendix: Andres Reyes v. Alfonsina Diaz Sanchez, Toyota Lease Trust

On December 03, 2019 a Exhibit,Appendix was filed involving a dispute between Andres Reyes, and Alfonsina Diaz Sanchez, Toyota Lease Trust, for Torts - Motor Vehicle in the District Court of Bronx County.

Preview
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EXHIBIT I
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX

ANDRES REYES, Index No.: 34242/2019E

Plaintiff,

-against-

ALFONSINA DIAZ SANCHEZ and TOYOTA LEASE :
TRUST,
Defendants.
-X

MEMORANDUM OF LAW IN SUPPORT OF
TOYOTA LEASE TRUST’S MOTION TO DISMISS

Of Counsel:
Doug Lazzaro

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PRELIMINARY STATEMENT

This Memorandum of Law with annexed exhibits, together with the Affidavit in

Support by Doug Lazzaro, sworn to on February 10, 2020, and the exhibits annexed thereto, are

respeetfully submitted in support of the instant motion by Defendant Toyota Lease Trust (“TLT”)

for an Order:

a. Pursuant to CPLR § 3211(a)(7), dismissing Plaintiffs Verified
Complaint and any eross-elaims as against TLT, on the grounds that
the pleadings fail to state a cause of action upon which relief may be
granted;

b. Severing the dismissed action against TLT from the remaining
action and directing the Clerk of Court to enter Judgment; and

c. Granting TLT such other and further relief as this Court deems just
and proper.

The Verified Complaint as against TLT should be dismissed on the grounds that

the enactment of 49 U.S.C. § 30106, commonly referred to as the “Graves Amendment,” preempts

New York Vehicle and Traffic Law (NYVTL) § 388, which imposed vicarious liability upon an

owner of a vehicle for the negligent acts of a permissive driver. The Graves Amendment bars all

state vicarious liability actions commenced on or after August 10, 2005 as against owners of

vehicles that are engaged in the business of renting or leasing motor vehicles. As such, the

Complaint fails to state a cause of action upon which relief may be granted as against TLT, a

company engaged in the business of leasing motor vehicles. Moreover, Plaintiff s claims of

negligent maintenance and respondeat superior similarly fail as a matter of law.

FACTS

The facts of this case are fully set forth in the Affidavit in Support. For the sake of

brevity, they will not be repeated herein except for purposes of amplification.

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ARGUMENT

POINT 1

TLT IS ENTITLED TO DISMISSAL OF PLAINTIFF’S
VERIFIED COMPLAINT BASED UPON THE GRAVES
AMENDMENT

It is well-established that a proponent of a Motion to Dismiss is entitled to have its

action dismissed upon demonstrating that a party’s complaint has failed to state a cause of action.

N.Y.C.P.L.R. § 3211(a)(7); see Guggenheimer v. Ginzburg, 43 N.Y.2d 268, 275, 372 N.E.2d 17,

401 N.Y.S.2d 182 (1977). The only factor in determining whether an action should be dismissed

pursuant to CPLR § 3211(a)(7) is whether the complaint “states a cause of action, and if from [the

Complaint’s] four corners factual allegations are discerned which taken together manifest any

cause of action cognizable at law.” Guggenheimer, 43 N.Y.2d at 275, 'ill N.E.2d at 20, 401

N.Y.S.2d at 185; see also Leon v. Martinez, 84 N.Y.2d 83, 88, 638 N.E.2d 511, 614 N.Y.S.2d 972

(1994); Foley v. D’Agostino, 21 A.D.2d 60, 64-65, 248 N.Y.S.2d 121 (1st Dep’t 1964).

In the instant matter, the factual allegations in the Verified Complaints make clear

that Plaintiffs theories of liability against TLT sound in negligence, premised upon vicarious

liability pursuant to NYVTL § 388. The enactment of the Graves Amendment preempts NYVTL

§ 388, and therefore. Plaintiffs Verified Complaint fails to state a cause of action upon which

relief may be granted as against TLT.

A. New York Vehicle and Traffic Law § 388

New York Vehicle and Traffic Law § 388 states, in relevant part, as follows:

§ 388. Negligence in use or operation of vehicle
attributable to owner.

1. Every owner of a vehicle used or operated in this state shall be
liable and responsible for death or injuries to person or property
resulting from negligence in the use or operation of such vehicle.

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in the business of such owner or otherwise, by a person using or
operating the same with the permission, express or implied, of
such owner.

[NYVTL § 388.]

As applied to the instant matter, the effect of NYVTL § 388, is to impose vicarious

liability upon entities such as TLT, which retains title ownership of a leased vehicle, for the

negligent acts of the permissive user of that vehicle.

B. Transportation Equity Act - 49 U.S.C. § 30106 (“Graves Amendment”)

On August 10, 2005, the Transportation Equity Act was signed into law by

President George W. Bush. As part of the Transportation Equity Act, subchapter 301 of title 49

of the United States Code was amended by adding at the end thereof, in relevant part, the following

statute:

Rented or leased motor vehicle safety and responsibility.

(a) In general. - An owner of a motor vehicle that rents or leases the
vehicle to a person (or an affiliate of the owner) shall not be liable
under the law of any State or political subdivision thereof, by reason
of being the owner of the vehicle (or an affiliate of the owner), for
harm to persons or property that results or arises out of the use,
operation, or possession of the vehicle during the period of the
rental or lease, if-

(1) the owner (or an affiliate of the owner) is engaged in the trade
or business of renting or leasing motor vehicles; and
(2) there is no negligence or criminal wrongdoing on the part of
the owner (or an affiliate of the owner).

(c) Applicability and effective date. - Notwithstanding any other
provision of law, this section shall apply with respect to any action
commenced on or after the date of enactment of this section without
regard to whether the harm that is the subject of the action, or the
conduct that caused the harm, occurred before such date of
enactment.
[49 U.S.C. § 30106.]

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The Graves Amendment preempts NYVTL § 388, whieh imposed vicarious

liability upon leasing companies, such as TLT, for the negligent acts of a permissive driver. The

Graves Amendment bars all state vicarious liability actions commenced on or after August 10,

2005 as against owners of the vehicles that are engaged in the business or trade of renting or leasing

motor vehicles.

C. Appellate Courts and Various State Trial Courts Have Upheld the Graves Amendment

Pursuant to the Graves Amendment, automotive vicarious liability actions are

barred as against entities such as TLT, which are engaged in the business of leasing motor vehicles.

This principle has been consistently reaffirmed by Appellate Courts throughout the State of New

York, including the First Department. See Hall v. Elrac, Inc., 52 A.D.3d 262, 859 N.Y.S.2d 641

(1st Dep’t 2008); Hernandez v. Sanchez, et al, 40 A.D.3D 446, 836 N.Y.S.2d 577 (1st Dep’t

2007). See also Cukoviq V. NILT, etal., 169 A.D.3d 766 (2d Dep’t 2019); ^v/aevv. Nissan Infiniti

LT, 150 A.D.3d 807 (2d Dep’t 2017); Antoine v. Nissan-Infiniti LT, 150 A.D.3d 941 (2d Dep’t

2017); Burrell v. NILT, Inc., 83 A.D.3d 984, 922 N.Y.S.2d 465 (2d Dep’t 2011); Gluck v. NILT,

Inc., 72 A.D.3d 1023, 898N.Y.S.2d 881 (2d Dep’t 2010), Iv. denied, 16N.Y.3D 703 (2011).

Specifically, in Hernandez, the Appellate Division, First Department reversed the

trial court’s denial of a leasing company’s Motion to Dismiss pursuant to CPLR 3211, holding that

“...49 use § 30106, the ‘Graves Amendment,’ bars State law vicarious liability actions

commenced on or after August 10, 2005, against owners of motor vehicles ‘engaged in the trade

or business of renting or leasing motor vehicles,’ such as FlUB [the lessor].” Hernandez, 40 A.D.3d

at 447.

Likewise, in Burrell, the Appellate Division, Second Department affirmed the

dismissal of an action against the leasing entity, and held that “to the extent that the complaint

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sought to hold NILT, Inc. vicariously liable for [the defendant-driver’s] allegedly negligent

operation of the leased vehicle based solely on its ownership of the vehicle, such a claim was

barred by the Graves Amendment.” Burrell, 83 A.D.3d at 986. Similarly, in Graham, the Second

Department held that beeause the federal statute preempts NYVTL § 388, “actions against rental

and leasing eompanies based solely on vicarious liability may no longer be maintained.” Graham,

50 A.D.3d at 62.

Moreover, this Court has previously dismissed virtually identical vicarious liability

actions commenced against leasing entities. In Martino v. Toyota Lease Trust, et al. Index No.

25192/2019E (Sup. Ct., Bronx Cty., December 12, 2019) (Brigantti, J.), this Court held that

dismissal of the Complaint against TLT, this precise lessor, was warranted pursuant to the federal

statute as “[t]he [company witness affidavit] and the lease agreement established that, at all

relevant times, the defendant was engaged in the business of leasing motor vehicles.” See also

Sprouse v. Toyota Lease Trust, et al. Index No. 24179/2017 (Sup. Ct., Bronx Cty., February 5,

2018) (Thompson Jr., J.);Diallo v. NILT, Inc., et al.. Index 300525/2016 (Sup Ct, Bronx Cty.,

October 7, 2016) (Taylor, J.); Ovenseri v. NILT, et al.. Index 21980/2015E (Sup Ct., Bronx Cty.,

December 22, 2015); Estevez v. NILT, Inc, et al.. Index 20606/2013E (Sup Ct, Bronx Cty.,

September 17, 2013) (Gonzalez, J.). Copies of these decisions are annexed eollectively hereto as

Exhibit “1.”

In addition to the above cited decisions, various trial courts throughout New York

have uniformly dismissed viearious liability actions commenced against entities engaged in the

business of leasing motor vehicles pursuant to the Graves Amendment. See Taveras v. Nissan-

Infiniti LT, Index No. 151089/2018 (Sup. Ct., New York County, May 16, 2018) (Silvera, J.);

DeMario v. Nissan-Infmiti LT, NILT, Inc., et al. Index No. 501454/2018 (Sup. Ct., Kings County,

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Sep. 5, 2018) (Velasquez, J.); Moreno v. Nissan-Infiniti LT, Index No. 708205/2017 (Sup. Ct,

Queens County, June 29, 2018) (Risi, J.); Wallace v. NILT, Inc., Index No. 617291/2017E (Sup.

Ct., Suffolk County, June 14, 2018) (Rebolini, J.). Copies of these decisions are annexed

collectively hereto as Exhibit “2.”

In the case at bar, the company witness Affidavit of Richard Torres, Lease

Agreement, and the Certificate of Title demonstrate that TLT is an entity unequivocally engaged

in the business of leasing motor vehicles, including the leased Toyota at issue. See Exhibits “C,”

“D,” and “H,” annexed to the Affidavit in Support.

It is undisputed that Plaintiff commenced this action long after the enactment of the

Graves Amendment. It is further undisputed that TLT is engaged in the business of leasing motor

vehicles. As such, this Court, in accordance with the cited precedent, should dismiss the Complaint

as against TLT.

POINT II

TLT CANNOT BE HELD LIABLE UNDER THEORIES OF
NEGLIGENT MAINTENANCE OR RESPONDEAT SUPERIOR

Plaintiffs claim of negligent maintenance should be dismissed on the grounds that:

(i) Plaintiff has failed to set forth any facts from which a cause of action for negligent maintenance

may lie, and (ii) the evidence unequivocally establishes that TLT was not responsible for any

maintenance or repairs to the leased vehicle at issue.

Plaintiffs Complaint contains the erroneous allegation that TLT “maintained” the

leased vehicle at issue. See Summons and Complaint, annexed to the Affidavit in Support as

Exhibit “A.” Conspicuous by their absence are any facts alleged by Plaintiff in support of this

claim, as indeed none exist. It is well settled that if the factual assertions do not manifest any cause

of action, then the pleading fails to state a claim upon which relief may be granted. See

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Guggenheimer, 43 N.Y.2d at 275. Accordingly, as Plaintiff has failed to set forth any specific

facts supporting the claim of negligent maintenance, the Complaint must he dismissed as a matter

of law.

Even if this Court finds that the Complaint sets forth “adequate factual assertions,”

it is respectfully submitted that those facts are contradicted by the documentary evidence and proof

submitted in support of the instant motion. The Appellate Division, First Department has held that

although plaintiffs are accorded the benefit of every inference, “claims consisting of bare legal

conclusions with no factual specificity—are insufficient to survive a motion to dismiss.” Barnes

V. Hodge, 118 A.D.3d633,989N.Y.S.2d 467 (D‘Dep’t 2014) {citing Godfrey v. Spano, 13N.Y.3d

358, 373, 892 N.Y.S.2d 272, 920 N.E.2d 328 (2009)). In the instant matter, the “factual assertion”

of negligent maintenanee on the part of the lessor is contradicted by the Lease Agreement and

leasing company witness affidavit which make clear that maintenance during the lease term was

solely the responsibility of the lessee. See Exhibits “C” and “H,” annexed to the Affidavit in

Support.

In Cukoviq, the Appellate Division, Second Department reversed the trialcourt’s

denial of the leasing companies’ Motion to Dismiss and held that “to the extent that the plaintiffs

theory of negligent maintenance or mechanical malfunction was supported by factual allegations,

the Nissan defendants established that the allegations were not facts at all through its submissions

showing that the Nissan defendants never possess, inspect, repair, maintain, or service the vehicles

they lease and that it was the sole responsibility of the lessee of the subject vehicle to maintain that

vehicle.” 169 A.D.3d at 766; see also Khan v. MMCA Lease, Ltd., 100 A.D.3d 833, 834 (2d Dep’t

2012); Aviaev v. Nissan Infiniti LT, 150 A.D.3d 807 (2d Dep’t 2017). In the case at bar, the

company witness Affidavit submitted on behalf of the lessor, the Notice to Admit, and the lease

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agreement unequivocally establish that TLT was not responsible for the maintenance or repair of

the vehicle at issue during the lease term. See Exhibits “C,” f 21, “G,” and “H,” ^ 10, annexed to

the Affidavit in Support. Based upon the aforementioned precedent. Plaintiffs claim must be

dismissed.

In addressing claims of respondeat superior. Courts have held that the affidavit

submitted by the company witness attesting to the fact that a co-defendant was not an agent,

servant, or employee of the leasing company was sufficient to dismiss plaintiff s claim. See Bass

V. Toyota Lease Trust, Index No. 30350/2017E (Sup. Ct., Bronx County, April 5, 2018) (Sherman,

J.); Moreno v. Nissan-Infmiti LT, Index No. 708205/2017 (Sup. Ct., Queens County, June 29,

2018) (Risi, J.); Mashriqiv. NILTlnc.,lndexNo. 704673/2017 (Sup. Ct., Queens County, January

3, 2018) (Raffaele, J.); Cappas v. Toyota Lease Trust, Index No. 19350/13 (Sup. Ct., Kings

County, June 18, 2014) (Ruchelsman, J.). Copies of these decisions are annexed collectively

hereto as Exhibit “3.”

Here, Richard Torres, Lease Collections Manager for Toyota Motor Credit

Corporation (“TMCC”), a servicer for TLT, not only searched the files and records, but also the

electronic databases of TLT, and confirmed that Defendant Diaz Sanchez was not an agent,

servant, or employee of TLT on the date of the accident. See Exhibit “H,” 11-12, annexed to

the Affidavit in Support. Additionally, Diaz Sanchez, in her Answer, admits that she was not

operating the Toyota vehicle within the scope of any employment to TLT at the time of the

accident. See Exhibit “F,” ^ 1. Moreover, the Notice to Admit, deemed fully admitted by operation

of law, confirms that Diaz Sanchez, at all relevant times, including the date of the accident at issue,

was not an employee of TLT, and was not acting within the authority or any scope of duty or

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employment to TLT. See Exhibit “G,” annexed to the Affidavit in Support. Based upon the

foregoing, TLT cannot be held responsible under a theory of respondeat superior.

CONCLUSION

For the foregoing reasons, it is respectfully submitted that the instant motion be

granted, and Plaintiffs Complaint and any cross-claims as against TLT be dismissed.

Dated: New York, New York
February 10, 2020

LONDON FISCHER LLP

By:
Doug Lazzaro
Attorneys for Defendant
Toyota Lease Trust
59 Maiden Lane
New York, New York 10038
(212) 972-1000

Of Counsel:
Doug Lazzaro

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Exhibit 1
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INDEX NO. 25192/2019E
IFILED; BRONX COUNTY CLERK 12/20/2019 03;41 PMI
NYSCEF DOC. NO. 110 RECEIVED NYSCEF.^2/20/2019
SUPREME COURT OF rilE STATE OF NEW YORK
COUNTY OF BRONX, PART __15
-X
CHENILLE MARTINO IndexNo. 25192/2019E

-againsl- Hon. MARY ANN BRICANTTI
FAREED ASAD, et al. .Justice Supreme Court
-X
The following papers numbered 1 to_3__ were read on this motion ( Seq .No.
for DISMISSAL noticed on___September 9, 2019.

Notice of Motion - Order to Show Cause - E.xhibits and Affidavits Annexed No(s)l,2
.Answering Affidavit and Exhibits No(s).3
Replying Affidavit and Exhibits No(s).

Upon the foregoing papers, the defendant Toyota Lease Trust ("TLT") moves for an order (1)
pursuant to CPLR 321,l(a)(7), dismissing the complaint of the plaintiff Chenille Martino (“Plaintiff”)
and all cross-claims asserted against TLT on the grounds that the pleadings fail to state a cause of action
upon which relief may be granted; (2) severing the dismissed action against TLT from the remaining
action and directing the Clerk of the Court to enter judgment, and (3) for such other and further relief as
iheCbtirtdeemsjust and proper. Plaintiff submits an affirmation in response to the motion asseiling
that counsel has attempted to discontinue the action against TLT, but co-defendants have failed to sign
the stipulation of discontinuance. Thus this motion is substantively unopposed.
“Under the Graves Amendment, the owner of a leased or rented motor vehicle cannot be held
vicariously liable ‘for harm to persons or properly that results or arises out of the use, operation, or
possession of the vehicle during the period of the rental or lease, if-—(1) the owner (or an affiliate oi the
owner) is engaged in the trade or business of renting or leasing motor vehicles; and (2) there is no
negligence or criminal wrongdoing on the part of the owner (or an affiliate of the ovyiieij’ (see Villa-
CapeUan v. Mendoza, 135 A.D.3d 555 [1st Dept. 2016], citing 49 U.S.C.§30106]; Jones v. Bill,lO
N.Y.3d 550 [2008], cert dismd 555 U.S. 1028, 129 S.Cl. 593, 172 L.Ed.2d 451 [2008]). In this case,
the affidavit from Richard Toires and the annexed lease agreement establishes that at relevant times,
TLT was engaged in the business of leasing motor vehicles including the vehicle at issue in this case.
TLT is thus entitled to the protection of the Graves Amendment (see Antoine Kalandrishvili, 150
A.D.3d 941 [2"‘' Dept. 2017]; USC § 30l06[aJ[lJ). While the Graves Amendment does not apply where a
plaintiff seeks to hold a defendant-owner liable for its own negligence (Collazo v. MTA-New York City Ti\,
74 A.D.3d 64), the Torres affidavit and lease agreement establish that the vehicle's lessee - co-defendant
Naheed Shaikh - was solely responsible for repair and maintenance of the vehicle during the lease term.
Accordingly, any factual allegations in the complaint asserting that TLT, inter alia, negligently maintained
the subject vehicle, "are not facts at all" and thus must be dismissed (see Antoine, 150 A.D.3d at 942]).
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[FILED; BRONX COUNTY CLERK 12/20/2019 03; 41 PMI 25192/2019E
NYSCEF DOC NO 110 RECEIVED NYSCEF; 12/2p/2019
Furthermore Torres avers that defendants Naheed Shaikh and Farced Asad were not agents or employees oti
TLT or acting withing the scope of any duty or employment to TLT at relevant times, therefore any claim |
that TLT is liable pursuant to the doctrine of respondeat superior are also dismissed.
Accordingly, it is hereby
ORDERED, that TLT's motion to dismiss is granted, and it is further,
ORDERED, that Plaintiffs complaint and any cross-claims asserted against TLT are dismissed, and
the Clerk of this Court is hereby directed to enter judgment accordingly.
This constitutes the Decision and Order of this Court.

Dated : NiA n Hon. /
J.S.C.
Hon. Mary Ann Brigantti
1. CHECK ONE.........................................
□ CASE DISPOSED IN ITS ENTIRETY ^CASE STILL ACTIVE
2. MOTION IS..........................................
GRANTED □ DENIED □ GRANTED IN PART □ OTHER
3. CHECK IF APPROPRIATE................... Q SETTLE ORDER □ SUBMIT ORDER □ SCHEDULE APPEARANCE
□ FIDUCIARY APPOINTMENT □ REFEREE APPOINTMENT

2 ol
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Iu/liV/iium n 1yy*! 'yf'yf UHilED LAWYERS SERVICE @001/001

FILED Oct 18 2016 Bronx County Clerk

SUPREME COURT OP THE STATE OF NEW YORK
OOUNTY OF BRONX,. 1.A.S..PARI2
ALPHA R, DIALLO,
Plslnllff, Index No, 300526/16
DECISION/ORDER
-aoalnot"
Pros Blit:
HQN. ELIZABETH A. TAYLOR
NILT, INC., DAYBREAK INDEPENDENT SERVES, INC,
and VILAS LOBAN, > „ . . ,
Defsniiants,
Tho Ibllowing papers numliered I ir__ rood on this motion,
----------

No On CttlwidBror PAPERS NUM'BEMD
Nolice of Moilon'Order W Slww Cause - BxhlWU wd Amdavita Annexed- ...... J-a
AMWerlns Affidavit and BxKIWk—-.... ......
Replying Affidavit and Sxlilbib-—'———^------------------
AflidaYit-'—"—r----- ---------- —........ ....... .
~~
Pleadings -- Exhibit—................ .....................................
Slipulndoii - Rolbreo’S Report -Minutes-'—----------- -------
Filed papors-'—— ---- —^ , — ..................... .—
------
U^ the foregoing papers gnd dii^lolTbersllon IhareDf, the Decl^ri/Order on this motion Is as "foliowa:
Motion pursuant to CPLR 3211(a)(7) and 49 U,8,C, § 30106 for an ord&r
dismissing the action against NILT, lno„ for failure to state a oaiiso of action, Is granted

on default.
Plaintiff commenced this action seeking damages for personal Injuries^ sustained
as a result of a motor vehiola accident that occurred on October 7, 2014. Plaintiff does'
not allege any affirmative negligence on the part of movant, but seeks damages from
movant based solely on vicarious liability (sea Oraham v Dunkley, 80 AD3d 65 (2ncj
Dept 2008]). As a result, plaintiff fails to state a cause of action against Nilt, ino,, as per
the Graves Amendment.
Upon receipt of this order with notice of entry, the Clerk shall dismiss the insteni
action against defendant Nilt, Ino, and amend the caption to reflect such dismissal.
The foregoing shall constitute tho decision and ord^ of this court.
Dated: _mJLmL -------- , A.j.s.c. ,
A. 1A.V-C-

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The follo\ving'pap.isi,snutp,bet:e,el']
to____-
Noliced on Nok>yhib>■/>>

' '■ ' ^^WZEsZIMqL^
............................................ ... {t.!s:,„Q^/AT/

MUT.

AiiorncyfO!- PMnfijfffs) Aitorneyfor Defendani^

'Xiiorneyfo^ Defendant ^ A Itor/i tiyf(fr Xfefetidaitt,

Dated ^AV le 2o?e
FILED: BRONX COUNTY CLERK 02/10/2020 04:49 PM INDEX NO. 34242/2019E
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/10/2020

[FILED: KINGS "COUNTY CLlUC 09/0T7?018 111 55 AM) INDEX NO, 50145'1/20'i^
^5)1:EF DOC. NO. 37 RECEIVED NYSCEF; 09/07/2^

At ail I.A.S, Trisi Term, tbe Supreme
Court of the State of New Yorttf held iu ant) for tbe
County of Kiug.«,at the Courthouse, located a(
Civic Center, Borough orErooklyn, Clfj' and State
ZQIBSEP'-'/ RH9'50 of New York, on tbe^^t^ day
V R E SENT
Hon, ^(A d Uf^'i
Justice

Cal. No, 5
Lo.' r,a Plain tiff(s) index No.

- against -

tT, KjZ^f, Joc-,
»ef=ndant(s)

The following papers nuirtbered 1 to read on this motion Papers Numbered
Nonce of Motion - Order lo Shaw Cau-ie
and Affioavita (Affimiationsl Annexed _________ _
Answering Affidavit (Affirmation)_________________ _______ ______________
Reply Affidavil (Affirmarion)^
_Affidavit (AffiroiJuion)_„
Picadmps - Exhibits
Stipulalian.i - M)nme.v
Filed paper,■!________

y^iirvigh-f^ milhn PA
LI o,.cJ iLftl, Inc Spfih, nO , / r ro ' 1

wrA’ifLP Vl

Case Info

Judge

Ben Barbato Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

February 10, 2020

Case Filing Date

December 03, 2019

County

Parties

Alfonsina Diaz sanchez Defendant
Andres Reyes Plaintiff
DIAMOND, BETH MICHELLE Attorney for the Plaintiff
Flynn, Neil Attorney for the Plaintiff
LAZZARO, DOUGLAS ROBERT Attorney for the Defendants
RUMPH, KARL SEBRING Attorney for the Defendant
SCAHILL, FRANCIS J Attorney for the Defendant
SLOTNICK, MICHAEL JONATHAN Attorney for the Defendants
TOYOTA LEASE TRUST Defendant
JOHN MARTIN Attorney
DEBORAH SOMMERS Attorneys for Defendants
TIMOTHY JONES Attorneys for Defendants
SCOTT APPELBAUM Attorney
DEBORAH REED Attorneys for Defendants
SCOTT REED Attorneys for Plaintiffs
LISA DENIG Attorney
JONATHAN NOBLE Attorneys for Plaintiffs
JOHN MERINGOLO Attorney
EDWARD STEVES Attorneys for Plaintiffs
JONATHAN HURWITZ Attorneys for Plaintiffs

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