On December 06, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Franchesca Guzman,
Maria T. Guzman,
and
Christopher James Hipple,
Jonaid I. Yousaf,
Mohammad Muni Yousaf,
for Torts - Motor Vehicle
in the District Court of Richmond County.
Preview
FILED: RICHMOND COUNTY CLERK 01/03/2020 01:06 PM INDEX NO. 153417/2018
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 01/03/2020
I
'I
EXHIBIT D
FILED: RICHMOND COUNTY CLERK 01/03/2020 01:06 PM INDEX NO. 153417/2018
NYSCEF INDEX NYSCEF:
NO. 153417/2018
[FILED DOC.
: NO. 22
RICHMOND COUNTY CLERK 06/04/2019 0 4:05 PM)
RECEIVED 01/03/2020
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/04/2019
SUPREME COURT OP THE STATE OF NEW YORK Index No.: 153417/18
COUNTY OF RICHMOND
MARIA T. GUZMAN AND FRANCHESCA GUZMAN,
Plaintiff, NOTICE OF
APPEARANCE AND
-against- VERIFIED ANSWER
TO DEFENDANT'S
MOHAMMAD MUNI YOUSAF, JONAID I. YOUSAF COUNTER-CLAIM
AND CHRISTOPHER JAMES HIPPLE,
Defendant.
S I R S:
PLEASE TAKE NOTICE, that the above named Plaintiff on the Counter-Claim,
MARIA T. GUZMAN, hereby appears in this action and that theundersigned has been retained
as attorneys for said Plaintiff on the Counter-Claim and demands that you serve all papers in this
proceeding upon them at the address stated below.
PLEASE TAKE FURTHER NOTICE, that the said Plaintiff on the Counter-Claim
hereby interposes the following Verified Answer to the Defendant Christopher James Hipple's
Counter-Claim;
ANSWERING THE COUNTER-CLAIM
Plaintiff on the Counter-Claim, MARIA T, GUZMAN, denies each and every allegation
contained in the counter-claim by the Defendant, CHRISTOPHER JAMES HIPPLE.
AS AND FOR AN AFFIRMATIVE DEFEN8E
That any verdict in the within action, for past, present and future medical care, dental
care, etwedial care, or rehabilitation services, loss of earnings or other economic loss, should be
reduced by the amount that any such expense has or will with reasonable certainty be replaced or
indemnified in whole or in part from any collateral source, in accordance with the provisions and
limitations of Section 4545(c) of the CPLR.
1 of 21
FILED: RICHMOND COUNTY CLERK 01/03/2020 01:06 PM INDEX NO. 153417/2018
NYSCEF INDEX NYSCEF:
NO. 153417/2018
FILED DOC.
: NO. 22
RICHMOND COUNTY CLERK 06/04/2019 04:05 PM)
RECEIVED 01/03/2020
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/04/2019
WHEREFORE, the defendants demand judgment dismissing this Compht, together
with the costs and disbursements of this action.
Dated: East Meadow, New York
May 31, 2019
LAW OFFICES OF BURATTI,
ROTHENBERG & BURNS
By: MARŸÁNA FEIGEN, ESQ.
Attorney for Plaintiff on the Counter-Claim
Mailing Address
P.O. Box 258829
Oldahoma City OK 73125-8829
Physical Address
90 Merrick Avenue, Suite 300
East Meadow NY 11554
(630) 370-1088
Our File No.: 19-539606
TO: Goldin & Rivin, PLLC
Attorney for Plaintiff
225 Broadway, Ste 1015
New York, NY 10007
(212) 571-7111
Martyn and Martyn
Attorney for Defendants
Mohammad Muni Yousaf and
Jonaid L Yousaf
330 Old Country Road, Suite 211
Mineola, New York 11501
(516) 739-0000
The Law Office of Nicole Lesperance
Attorney for Defendant
Christopher James Hipple
1400 Old Country Road, Ste. 201
Westbury, NY 11590
(516) 247-4720
2 of 21
Document Filed Date
January 03, 2020
Case Filing Date
December 06, 2018
Category
Torts - Motor Vehicle
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Preview
FILED: RICHMOND COUNTY CLERK 01/03/2020 01:06 PM INDEX NO. 153417/2018 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 01/03/2020 I 'I EXHIBIT D FILED: RICHMOND COUNTY CLERK 01/03/2020 01:06 PM INDEX NO. 153417/2018 NYSCEF INDEX NYSCEF: NO. 153417/2018 [FILED DOC. : NO. 22 RICHMOND COUNTY CLERK 06/04/2019 0 4:05 PM) RECEIVED 01/03/2020 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/04/2019 SUPREME COURT OP THE STATE OF NEW YORK Index No.: 153417/18 COUNTY OF RICHMOND MARIA T. GUZMAN AND FRANCHESCA GUZMAN, Plaintiff, NOTICE OF APPEARANCE AND -against- VERIFIED ANSWER TO DEFENDANT'S MOHAMMAD MUNI YOUSAF, JONAID I. YOUSAF COUNTER-CLAIM AND CHRISTOPHER JAMES HIPPLE, Defendant. S I R S: PLEASE TAKE NOTICE, that the above named Plaintiff on the Counter-Claim, MARIA T. GUZMAN, hereby appears in this action and that theundersigned has been retained as attorneys for said Plaintiff on the Counter-Claim and demands that you serve all papers in this proceeding upon them at the address stated below. PLEASE TAKE FURTHER NOTICE, that the said Plaintiff on the Counter-Claim hereby interposes the following Verified Answer to the Defendant Christopher James Hipple's Counter-Claim; ANSWERING THE COUNTER-CLAIM Plaintiff on the Counter-Claim, MARIA T, GUZMAN, denies each and every allegation contained in the counter-claim by the Defendant, CHRISTOPHER JAMES HIPPLE. AS AND FOR AN AFFIRMATIVE DEFEN8E That any verdict in the within action, for past, present and future medical care, dental care, etwedial care, or rehabilitation services, loss of earnings or other economic loss, should be reduced by the amount that any such expense has or will with reasonable certainty be replaced or indemnified in whole or in part from any collateral source, in accordance with the provisions and limitations of Section 4545(c) of the CPLR. 1 of 21 FILED: RICHMOND COUNTY CLERK 01/03/2020 01:06 PM INDEX NO. 153417/2018 NYSCEF INDEX NYSCEF: NO. 153417/2018 FILED DOC. : NO. 22 RICHMOND COUNTY CLERK 06/04/2019 04:05 PM) RECEIVED 01/03/2020 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 06/04/2019 WHEREFORE, the defendants demand judgment dismissing this Compht, together with the costs and disbursements of this action. Dated: East Meadow, New York May 31, 2019 LAW OFFICES OF BURATTI, ROTHENBERG & BURNS By: MARŸÁNA FEIGEN, ESQ. Attorney for Plaintiff on the Counter-Claim Mailing Address P.O. Box 258829 Oldahoma City OK 73125-8829 Physical Address 90 Merrick Avenue, Suite 300 East Meadow NY 11554 (630) 370-1088 Our File No.: 19-539606 TO: Goldin & Rivin, PLLC Attorney for Plaintiff 225 Broadway, Ste 1015 New York, NY 10007 (212) 571-7111 Martyn and Martyn Attorney for Defendants Mohammad Muni Yousaf and Jonaid L Yousaf 330 Old Country Road, Suite 211 Mineola, New York 11501 (516) 739-0000 The Law Office of Nicole Lesperance Attorney for Defendant Christopher James Hipple 1400 Old Country Road, Ste. 201 Westbury, NY 11590 (516) 247-4720 2 of 21