Party Statement: Phadia Jean, Vladimir Jean v. Orangetown Town Of, Orangetown Police Department, Orangetown Police Officer

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                                FILED:         ROCKLAND           COUNTY        CLERK        02/23/2018             12:07        PM                 INDEX    NO.   033456/2016
   NYSCEF     DOC.   NO.   18                                                                                 RECEIVED      NYSCEF:     02/23/2018
         Index   No.       033456/2016                         Year    2016


         SUPREME        COURT      OF   THE   STATE     OF   NEW     YORK
         COUNTY       OF   ROCKLAND
         PHADIA    JEAN   and  VLADIMIR     JEAN,


                                                                Plaintiffs,
                      -   against  -


         TOWN    OF   ORANGETOWN,         ORANGETOWN
         POLICE    DEPARTMENT,        POLICE    OFFICERS
                 DOE"
         "JOHN          One   through  Three  and  POLICE
                             DOE"
         OFFICER     "JANE          the names   being  fictitious
         but intended   to be the Police  Officers of the
         ORANGETOWN          POLICE   DEPARTMENT        who   engaged
         In illegaland  negligent  behavior  against  plaintiffs
         as set forth below
                                                               Defendants.




                                                      RESPONSE         TO   COMBINED          DEMANDS


                                    VALERIE       J CROWN,       ATTORNEY        AT   LAW,     P.C.

                                    Attorneys    for Plaintiff(s)
                                    Office   and  Post  Office  Address
                                    151   North  Main   Street  - 4th  Floor
                                    New    City, New    York   10956

                                    (845)    708-5900


                  Pursuant  to22  NYCRR   130-1.1-a, the undersigned,  an attorney admitted topractice in the courts ofNew   York State,certifies
         that,upon  information and  beliefand reasonable  inquiry, (1)the contentions contained  inthe annexed  document  are not frivolous and
         that (2)ifthe annexed  document  is an          pleading,
                                                initiating          (i)thematter was  not obtained through  illegalconduct, or thatifit was, the
         attorney or other persons responsible for the illegalconduct are not participating in thematter or sharing  inany fee earned  therefrom
         and  that(ii)ifthematter  involvespotential claims for personal injury or wrongful death, the matter was not obtained  in violationof
         22 NYCRR    1200.41-a


         Dated:   New  City, New  York                                  Signature:
                  February  23, 2018                                    Print Signer's Name     lienD. Lazarus, Esq.


                  Service   of a copy   of the within                                                    is

                  hereby   admitted.

                  Dated:



                                      Attorney(s)    for




         Dated:

                                                               Yours,   etc.

                                                               VALERIE       J CROWN,      ATTORNEY         AT   LAW,    P.C.
                                                               Attorneys    for Plaintiff(s)
                                                               Office  and  Post  Office   Address
                                                               151  North   Main   Street  - 4th Floor
                                                               New   City,  New   York    10956

                                                               (845)    708-5900




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