On October 30, 2017 a
Motion-Secondary
was filed
involving a dispute between
Sarah Rodriguez,
and
Cdc 111Th Street Realty, L.P.,
Cdc East 105Th Street Realty, L.P.,
for Torts - Other Negligence (Premises)
in the District Court of Bronx County.
Preview
FILED: BRONX COUNTY CLERK 01/05/2023 03:48 PM INDEX NO. 30287/2017E
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 01/05/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
SARAH RODRIGUEZ, Index No. 30287/2017E
Plaintiff,
-against- SUPPLEMENTAL AFFIDAVIT
WILLIAM GUERRERO IN
105"
CDC EAST STREET REALTY, L.P. and CDC FURTHER SUPPORT OF MOTION
111"
STREET REALTY, L.P., TO VACATE DEFAULT
Defendants.
STATE OF NEW YORK )
) ss.:
COUNTY OF )
William Guerrero, being duly sworn, deposes and states:
105"
1. I am the sole principal of Defendants CDC EAST STREET REALTY, L.P.
111"
and CDC STREET REALTY, L.P. (collectively, the "Defendants") and as such I am
responsible for the management and operation of both entities and the properties they own.
2. As such I am familiar with the operations of the Defendants including their
maintenance records, incident reports and legal matters, record keeping practices and employees.
3. I am also a licensed NY real estate broker and routinely provide updates regarding
my business address to the NY Secretary of State office as part of the licensing process.
Defendants'
4. I make the following statements based on review of the records,
Defendants'
interviews with employees and agents, and my personal knowledge including
interviews with the superintendent of the subject building, Mr. Jose Tejada, and review of records
concerning complaints and repairs for the subject building.
1 of 2
FILED: BRONX COUNTY CLERK 01/05/2023 03:48 PM INDEX NO. 30287/2017E
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 01/05/2023
5. In the year 2017, Defendants moved their offices to 1140 Broadway, Suite 904,
New York, New York and since 2017 a Google search of Defendants would have revealed their
correct address.
6. During this time, I updated my information with the Secretary of State for my
realtor's license but was unaware the addresses for Defendants had to be separately updated.
7. I am the sole principal of Defendants and based on my personal review of records
concerning complaints and repairs for the subject building, Defendants do not possess any records
documenting either the incident alleged in the Complaint or any related repairs.
Dated: , New York
December.2/_ 022
William Guerrero
Sworn to before me this .2/
day of hmled , 2022
Notary Publi
DALIANA MONTERO
NotaryPublic- Stateof New York
No. 01M08277111
Qualifiedin New York Coun
My Commission BÆires 03f
2 of 2
Document Filed Date
January 05, 2023
Case Filing Date
October 30, 2017
Category
Torts - Other Negligence (Premises)
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FILED: BRONX COUNTY CLERK 01/05/2023 03:48 PM INDEX NO. 30287/2017E NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 01/05/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX SARAH RODRIGUEZ, Index No. 30287/2017E Plaintiff, -against- SUPPLEMENTAL AFFIDAVIT WILLIAM GUERRERO IN 105" CDC EAST STREET REALTY, L.P. and CDC FURTHER SUPPORT OF MOTION 111" STREET REALTY, L.P., TO VACATE DEFAULT Defendants. STATE OF NEW YORK ) ) ss.: COUNTY OF ) William Guerrero, being duly sworn, deposes and states: 105" 1. I am the sole principal of Defendants CDC EAST STREET REALTY, L.P. 111" and CDC STREET REALTY, L.P. (collectively, the "Defendants") and as such I am responsible for the management and operation of both entities and the properties they own. 2. As such I am familiar with the operations of the Defendants including their maintenance records, incident reports and legal matters, record keeping practices and employees. 3. I am also a licensed NY real estate broker and routinely provide updates regarding my business address to the NY Secretary of State office as part of the licensing process. Defendants' 4. I make the following statements based on review of the records, Defendants' interviews with employees and agents, and my personal knowledge including interviews with the superintendent of the subject building, Mr. Jose Tejada, and review of records concerning complaints and repairs for the subject building. 1 of 2 FILED: BRONX COUNTY CLERK 01/05/2023 03:48 PM INDEX NO. 30287/2017E NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 01/05/2023 5. In the year 2017, Defendants moved their offices to 1140 Broadway, Suite 904, New York, New York and since 2017 a Google search of Defendants would have revealed their correct address. 6. During this time, I updated my information with the Secretary of State for my realtor's license but was unaware the addresses for Defendants had to be separately updated. 7. I am the sole principal of Defendants and based on my personal review of records concerning complaints and repairs for the subject building, Defendants do not possess any records documenting either the incident alleged in the Complaint or any related repairs. Dated: , New York December.2/_ 022 William Guerrero Sworn to before me this .2/ day of hmled , 2022 Notary Publi DALIANA MONTERO NotaryPublic- Stateof New York No. 01M08277111 Qualifiedin New York Coun My Commission BÆires 03f 2 of 2