On December 14, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Simone Joseph,
and
John Doe
The Party Intended Being The Operator Of Bus Number 6114 At The Time Of The Occurrence Alleged In The Complaint,
New York City Transit Authority,
The City Of New York,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 02/27/2023 05:56 PM INDEX NO. 524944/2020
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/27/2023
EXHIBIT D
FILED: KINGS COUNTY CLERK 02/27/2023 05:56 PM INDEX NO. 524944/2020
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/27/2023
SUPREME COURT OF TIlE STATE OF NEW YORK
COUNTY OF KINGS
-----------_______________________________--------------_______----- x
SIMONE JOSEPH
Plaintiff,
AFFIDAVIT
-against-
Index No: 524944/2020
THE CITY OF NEW YORK, NEW YORK CITY
TRANSIT AUTHORITY, AND "JOHN DOE", THE City Number: 2020-047398
PARTY INTENDED BEING THE OPERATOR OF BUS
NUMBER 6114 AT THE TIME OF THE OCCURRENCE
ALLEGED IN THE COMPLAINT,
Defendant.
____------------------------------_________--___________________ x
STATE OF NEW YORK )
: SS.:
COUNTY OF NEW YORK )
JERRY BRADSHAW, being duly sworn, deposes and says:
1. I am Unit Chief of the Communications & Docketing Services Unit in the
Operations Division of the Law Department of the City of New York, Office of the Corporation
Counsel. This affidavit is based on my personal knowledge as well as the books and records of
the City of New York and conversations with City employees. I submit this affidavit in support
of Defendant THE CITY OF NEW YORK's Motion for Summary Judgement in the above-
captioned proceeding.
2. As part of my official duties, I am responsible for supervising the
Communication & Docketing Services Unit, the unit responsible for processing claims filed in
the Office of The Corporation Counsel including the supervision of the receipt and maintenance
of all notice of claim, written verified claims, summonses, complaints and all other legal papers
FILED: KINGS COUNTY CLERK 02/27/2023 05:56 PM INDEX NO. 524944/2020
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/27/2023
and for searching the books and records of the Office of The Corporation Counsel to ascertain
whether a party has filed a Notice of Claim.
3. The Communications and Docketing Services Unit is also responsible for
accepting service on behalf of the City and all covered city agencies according to CPLR
§31l(a)2., and keeping a detailed database of the date, time, method of service, and the name of
plaintiff or claimant responsible for service of such papers, of all legal papers received by the
Office of the Corporation counsel, including notice of claims.
4. In the regular course of business, I directed a member of my staff to make
a search of the files, log books and computerized filing system for information relating to
Plaintiff, SIMONE JOSEPH, and the subject matter of the above referenced action. Such
diligent search did not reveal any notice of claim, written verified claim, or claim letter filed by
or on behalf of the Plaintiff, SIMONE JOSEPH, from (January 31, 2020 to present).
JEI Y BRADSHAW
Sworn to me this l•day of hboxuy, 2023
Notary Public
MEZ CONTRERAS
Commisatoner d Deeds
d New York No. 1-101N
Med In New YoA
commission Expires Nowrnber 01.
Document Filed Date
February 27, 2023
Case Filing Date
December 14, 2020
Category
Torts - Motor Vehicle
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FILED: KINGS COUNTY CLERK 02/27/2023 05:56 PM INDEX NO. 524944/2020 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/27/2023 EXHIBIT D FILED: KINGS COUNTY CLERK 02/27/2023 05:56 PM INDEX NO. 524944/2020 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/27/2023 SUPREME COURT OF TIlE STATE OF NEW YORK COUNTY OF KINGS -----------_______________________________--------------_______----- x SIMONE JOSEPH Plaintiff, AFFIDAVIT -against- Index No: 524944/2020 THE CITY OF NEW YORK, NEW YORK CITY TRANSIT AUTHORITY, AND "JOHN DOE", THE City Number: 2020-047398 PARTY INTENDED BEING THE OPERATOR OF BUS NUMBER 6114 AT THE TIME OF THE OCCURRENCE ALLEGED IN THE COMPLAINT, Defendant. ____------------------------------_________--___________________ x STATE OF NEW YORK ) : SS.: COUNTY OF NEW YORK ) JERRY BRADSHAW, being duly sworn, deposes and says: 1. I am Unit Chief of the Communications & Docketing Services Unit in the Operations Division of the Law Department of the City of New York, Office of the Corporation Counsel. This affidavit is based on my personal knowledge as well as the books and records of the City of New York and conversations with City employees. I submit this affidavit in support of Defendant THE CITY OF NEW YORK's Motion for Summary Judgement in the above- captioned proceeding. 2. As part of my official duties, I am responsible for supervising the Communication & Docketing Services Unit, the unit responsible for processing claims filed in the Office of The Corporation Counsel including the supervision of the receipt and maintenance of all notice of claim, written verified claims, summonses, complaints and all other legal papers FILED: KINGS COUNTY CLERK 02/27/2023 05:56 PM INDEX NO. 524944/2020 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 02/27/2023 and for searching the books and records of the Office of The Corporation Counsel to ascertain whether a party has filed a Notice of Claim. 3. The Communications and Docketing Services Unit is also responsible for accepting service on behalf of the City and all covered city agencies according to CPLR §31l(a)2., and keeping a detailed database of the date, time, method of service, and the name of plaintiff or claimant responsible for service of such papers, of all legal papers received by the Office of the Corporation counsel, including notice of claims. 4. In the regular course of business, I directed a member of my staff to make a search of the files, log books and computerized filing system for information relating to Plaintiff, SIMONE JOSEPH, and the subject matter of the above referenced action. Such diligent search did not reveal any notice of claim, written verified claim, or claim letter filed by or on behalf of the Plaintiff, SIMONE JOSEPH, from (January 31, 2020 to present). JEI Y BRADSHAW Sworn to me this l•day of hboxuy, 2023 Notary Public MEZ CONTRERAS Commisatoner d Deeds d New York No. 1-101N Med In New YoA commission Expires Nowrnber 01.