On January 20, 2023 a
No Value
was filed
involving a dispute between
Charles Salomon,
and
Copart, Inc.,
Mico Cooling Corporaton,
Utica National Insurance Group,
for Torts - Motor Vehicle
in the District Court of Dutchess County.
Preview
FILED: DUTCHESS COUNTY CLERK 01/20/2023 11:56 AM INDEX NO. 2023-50230
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/20/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF DUTCHESS
--------------------------------------------------------------------)(
CHARLES SALOMON, INDE)(NO.:
Petitioner,
-against-
COPART, INC., MICO COOLING CORPORATION,
and UTICA NATIONAL INSURANCE GROUP,
Respondents
------------------------------------------------------------------)(
ATTORNEY'S AFFIRMATION OF GOOD FAITH
CHRISTOPHER JAMES PATSOS, an attorney duly admitted to practice law in the
courts of the State of New York, pursuant to CPLR 2106 and under the penalties of perjury,
affirms as follows:
1. I am the sole member of The Law Offices of Christopher James Patsos
LLC, attorneys for the Petitioner, Charles Salomon, and I submit this
Affirmation in support of an application for pre-action inspection to
preserve evidence.
2. The relief sought in this Order To Show Cause, pre-action discovery,
cannot be obtained without a Court Order. Section 3102 of the CPLR
provides, specifically, that "before an action is commenced, disclosure to
aid in bringing an action (or) to preserve information ... may be obtained,
but only by court order. "
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FILED: DUTCHESS COUNTY CLERK 01/20/2023 11:56 AM INDEX NO. 2023-50230
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/20/2023
3. Accordingly, because Court intervention is required for the relief sought,
this application has been brought in good faith.
Dated: New York, New York
January 18,2023
Yours etc.
Respondents' Addresses
CoPali
25 Riverview Drive
Marlboro, New York 12542
Mico Cooling Corporation
30 Ramland Road, Suite 103
Orangeburg, NY 10962
Utica National Insurance Group
P.O. Box 6610
Utica, NY 13504
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Document Filed Date
January 20, 2023
Case Filing Date
January 20, 2023
Category
Torts - Motor Vehicle
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