On December 14, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Brittany Stevens,
and
Ali George,
David Rivas Luna,
Emmanuel Morgan,
Ino Transportation Corp.,
Marino Rivas,
Rivas Construction Corp.,
for Torts - Motor Vehicle
in the District Court of Kings County.
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___-_____________
FILED: BRITTANY
KINGS INDEX NO. 524933/2020
COUNTY CLERK 02/14/2023
STEVENS, 10:35
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/14/2023
Plaintiff,
AFFIDAVIT
-against-
RIVASCONSTRUCTIONCORP.,DAVID RIVAS LUNA,
EMMANUELMORGAN,AU GEORGE,INO
TRANSPORTATIONCORP.MARINO RivAS,
Defendants.
AU GEORGE,being duly swom deposes and says under penalties of perjury:
1. I reside a Brooklyn, New York.
2. On January 21, 2020, I was operating an Infiniti sedan owned by my friend,
Emmanuel Morgan, with his permission and consent, when I was involved in
an accident on Eastern Parkway near its intersection with Rockaway Avenue.
3. It was light out and the weather was dry at the time of the accident.
A. In the area where the accident occurred, Eastern Parkway has three lanes for
moving traffic in each direction. The different directions of travel are
separated by a median.There is a traffic light which governs the intersection,
which includes a left-tum only arrow for each direction of travel for vehicles
making a left turn onto Rockaway Avenue.
5. Rockaway Avenue is a two-way roadway which runs north-south with two
lanes for each direction of travel, with the different directions of travel
separated by a double yellow line.
6. At the time of the accident, I had been
traveling in the eastbound middle lane
on Eastem Parkway for five minutes.
7. The light was a sold green circle for
my direction of travel at the time of the
accident.
8.
FILED: Prior to the accident
KINGS COUNTY occurring,CLERK INDEX
I observed a02/14/2023NO. with
police vehide 524933/2020
sirens10:35
activated a left turn from westbound
making Eastem to
southbound
NYSCEF DOC.Rockaway
NO. 49 Avenue. RECEIVED Parkway
NYSCEF: 02/14/2023
9. When the police vehide executed its left tun, the vehide in front of me, a
cab,
came to a stop at the intersection. The cab was the first vehide at the
intersection.
10. At the time the police vehide executed its left turn, I was traveling 20 miles
per hour.
11. When the cab in front of me came to a stop, I brought my vehlde to a stop.
Approximately two seconds passed from the time the cab ame to a stop to
the time my vehide came to a stop. I did not come into contact with the
vehide ahead of me at this time. I brought my vehicle to a full stop behind
the cab without coming into contact with it.
12. Approximately two to three seconds after I brought my vehide to a stop, I
experienced an Impact to the rear of my vehide, when my vehlde was struck
in the rear by a silver vehide.
13. As a result of the impact to the rear of my vehicle, I was propelled forward
into the vehide ahead of me, and my vehide came into contact with the cab
ahead of me.
14. I believe I am not at fault for this acddent, as I came to a full stop without
contacting the vehicle ahead of me, before being struck In the rear and
propelled forward Into the vehide ahead of me.
Sworn fore me this
day o ructm , 2023
A GEOR E
NOTARY PUBUC
ass MadsaSamud
StateofNewWB
Nggy Public,
No.01S
commis
Document Filed Date
February 14, 2023
Case Filing Date
December 14, 2020
Category
Torts - Motor Vehicle
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___-_____________ FILED: BRITTANY KINGS INDEX NO. 524933/2020 COUNTY CLERK 02/14/2023 STEVENS, 10:35 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/14/2023 Plaintiff, AFFIDAVIT -against- RIVASCONSTRUCTIONCORP.,DAVID RIVAS LUNA, EMMANUELMORGAN,AU GEORGE,INO TRANSPORTATIONCORP.MARINO RivAS, Defendants. AU GEORGE,being duly swom deposes and says under penalties of perjury: 1. I reside a Brooklyn, New York. 2. On January 21, 2020, I was operating an Infiniti sedan owned by my friend, Emmanuel Morgan, with his permission and consent, when I was involved in an accident on Eastern Parkway near its intersection with Rockaway Avenue. 3. It was light out and the weather was dry at the time of the accident. A. In the area where the accident occurred, Eastern Parkway has three lanes for moving traffic in each direction. The different directions of travel are separated by a median.There is a traffic light which governs the intersection, which includes a left-tum only arrow for each direction of travel for vehicles making a left turn onto Rockaway Avenue. 5. Rockaway Avenue is a two-way roadway which runs north-south with two lanes for each direction of travel, with the different directions of travel separated by a double yellow line. 6. At the time of the accident, I had been traveling in the eastbound middle lane on Eastem Parkway for five minutes. 7. The light was a sold green circle for my direction of travel at the time of the accident. 8. FILED: Prior to the accident KINGS COUNTY occurring,CLERK INDEX I observed a02/14/2023NO. with police vehide 524933/2020 sirens10:35 activated a left turn from westbound making Eastem to southbound NYSCEF DOC.Rockaway NO. 49 Avenue. RECEIVED Parkway NYSCEF: 02/14/2023 9. When the police vehide executed its left tun, the vehide in front of me, a cab, came to a stop at the intersection. The cab was the first vehide at the intersection. 10. At the time the police vehide executed its left turn, I was traveling 20 miles per hour. 11. When the cab in front of me came to a stop, I brought my vehlde to a stop. Approximately two seconds passed from the time the cab ame to a stop to the time my vehide came to a stop. I did not come into contact with the vehide ahead of me at this time. I brought my vehicle to a full stop behind the cab without coming into contact with it. 12. Approximately two to three seconds after I brought my vehide to a stop, I experienced an Impact to the rear of my vehide, when my vehlde was struck in the rear by a silver vehide. 13. As a result of the impact to the rear of my vehicle, I was propelled forward into the vehide ahead of me, and my vehide came into contact with the cab ahead of me. 14. I believe I am not at fault for this acddent, as I came to a full stop without contacting the vehicle ahead of me, before being struck In the rear and propelled forward Into the vehide ahead of me. Sworn fore me this day o ructm , 2023 A GEOR E NOTARY PUBUC ass MadsaSamud StateofNewWB Nggy Public, No.01S commis