On November 19, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Michelle Santos,
and
Michelle Y. Lawrence,
for Torts - Motor Vehicle
in the District Court of Dutchess County.
Preview
FILED: DUTCHESS COUNTY CLERK 10/21/2020 04:30 PM INDEX NO. 2019-54690
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/21/2020
NEW YORK STATE
SUPREME COURT: DUTCHESS COUNTY
MICHELLE SANTOS,
ATTORNEY
Plaintiff,
AFFIRMATION
-against-
MICHELLE Y. LAWRENCE, Index No. 2019-54690
Defendant.
JOHN A. DeGASPERIS, ESQ., an attorney admitted to practice law in
the Courts of the State of New York, affirms the following under penalties of
perjury:
1. I am a partner at the law office of Basch & Keegan, LLP. As such, I am
fully familiar with the facts and circumstances addressed in this affirmation.
2. I respectfully submit this affirmation in response to the "Notice of
Consolidate"
Motion to filed by defense counsel, Martyn, Martyn, Smith &
Murray.
3. I have no objection to the request made by defense counsel to have this
matter consolidated.
WHEREFORE, the Plaintiff respectfully requests the Court consolidate
this action with the action of Laquise Newman again Michelle Y. Lawrence
and Michelle Santos, Index No.: 051459/2020, and grant all such other and
further relief as the Court deems just and proper.
Dated: October 14, 2020
Kingston, New York
Respect sub e
JÒÍIN . DeGASPERIS, ES .
BASC & KEEGAN, LLP
Attor eys for Plaintiff
1 of 2
FILED: DUTCHESS COUNTY CLERK 10/21/2020 04:30 PM INDEX NO. 2019-54690
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/21/2020
Office and P.O. Address
307 Clinton Avenue
P.O. Box 4235
Kingston, New York 12402
(845) 338-8884
cc: Martyn & Martyn, Esqs.
Attorney for Defendant
Office and P.O. Address
330 Old County Road, Suite 211
Mineola, New York 11501
Tel: (516) 739-0000
EL
2 of 2
Document Filed Date
October 21, 2020
Case Filing Date
November 19, 2019
Category
Torts - Motor Vehicle
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FILED: DUTCHESS COUNTY CLERK 10/21/2020 04:30 PM INDEX NO. 2019-54690 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/21/2020 NEW YORK STATE SUPREME COURT: DUTCHESS COUNTY MICHELLE SANTOS, ATTORNEY Plaintiff, AFFIRMATION -against- MICHELLE Y. LAWRENCE, Index No. 2019-54690 Defendant. JOHN A. DeGASPERIS, ESQ., an attorney admitted to practice law in the Courts of the State of New York, affirms the following under penalties of perjury: 1. I am a partner at the law office of Basch & Keegan, LLP. As such, I am fully familiar with the facts and circumstances addressed in this affirmation. 2. I respectfully submit this affirmation in response to the "Notice of Consolidate" Motion to filed by defense counsel, Martyn, Martyn, Smith & Murray. 3. I have no objection to the request made by defense counsel to have this matter consolidated. WHEREFORE, the Plaintiff respectfully requests the Court consolidate this action with the action of Laquise Newman again Michelle Y. Lawrence and Michelle Santos, Index No.: 051459/2020, and grant all such other and further relief as the Court deems just and proper. Dated: October 14, 2020 Kingston, New York Respect sub e JÒÍIN . DeGASPERIS, ES . BASC & KEEGAN, LLP Attor eys for Plaintiff 1 of 2 FILED: DUTCHESS COUNTY CLERK 10/21/2020 04:30 PM INDEX NO. 2019-54690 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 10/21/2020 Office and P.O. Address 307 Clinton Avenue P.O. Box 4235 Kingston, New York 12402 (845) 338-8884 cc: Martyn & Martyn, Esqs. Attorney for Defendant Office and P.O. Address 330 Old County Road, Suite 211 Mineola, New York 11501 Tel: (516) 739-0000 EL 2 of 2