On September 20, 2018 a
OTHER COURT FILED DOCUMENT - AFFIDAVIT OF MERIT
was filed
involving a dispute between
Christine Vanlew,
Parkwood Plaza Ii Llc As Third Party,
and
Clad Realty Llc,
Corri Inc As Third Party,
Parkwood Plaza Ii Llc,
for Torts - Other (Personal Injury)
in the District Court of Saratoga County.
Preview
FILED: SARATOGA COUNTY CLERK 03/17/2021 10:35 AM INDEX NO. 20183085
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 03/17/2021
STATE OF NEW YORK
SUPREME COURT COUNTY OF SARATOGA
CHRISTINE VANLEW, Index No.: 3085/18
Plaintiff, AFFIDAVIT OF MERIT
-against-
PARKWOOD PLAZA II, LLC, and as
CLAD REALTY, LLC,
Defendants.
STATE OF NEW YORK )
- C
25
) ss
.c-
COUNTY OF ALBANY )
Christine Vanlew, being duly sworn, deposes and says:
1. I am the plaintiff in the above-captioned action and make this Affidavit of Merit
in support of the within application for judgment by default pursuant to CPLR §3215.
2. I have a meritorious claim in this action as on October 12, 2015 at
approximately 10:30 a.m., I was leaving the Dunkin Donuts building through the rear porch
landing when I was caused to fall due to the porch and steps being in a dangerous, defective
and broken condition.
3. That as a result of the aforesaid accident and culpable conduct of the defendant,
Clad Realty, LLC, I was caused to sustain severe personal injuries, resulting in extensive
medical treatment, including ankle surgery, costs and lost wages, together with pain, suffering
and disability, all of which will continue into the future.
4. The above-entitled action by me was commenced by service of a Summnm and
Complaint on October 2, 2018.
1 of 2
FILED: SARATOGA COUNTY CLERK 03/17/2021 10:35 AM INDEX NO. 20183085
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 03/17/2021
5. It is my understanding that, to date, no Answer has been received by my
attorney as required by statute and the defendant, Clad Realty, LLC, is in default.
WHEREFORE, for the reasons stated above, deponent respectfully requests an Order
of the Court granting a default judgment agMnst the defendant, Clad Realty, LLC, and that an
inquest as to damages be scheduled, together with such other and further relief as the Court
deems just and proper.
CHRISTINE VANLEW
Sworn to before me this
day of May, 2019.
Christopher P. Meyer
Esq.
Notary Public, State of New
York
Qualified in
NOTARY DBLIC Albany County
Registration No.
02ME5049521
Commission
Expires9f9jMM
2 of 2
Document Filed Date
March 17, 2021
Case Filing Date
September 20, 2018
Category
Torts - Other (Personal Injury)
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FILED: SARATOGA COUNTY CLERK 03/17/2021 10:35 AM INDEX NO. 20183085 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 03/17/2021 STATE OF NEW YORK SUPREME COURT COUNTY OF SARATOGA CHRISTINE VANLEW, Index No.: 3085/18 Plaintiff, AFFIDAVIT OF MERIT -against- PARKWOOD PLAZA II, LLC, and as CLAD REALTY, LLC, Defendants. STATE OF NEW YORK ) - C 25 ) ss .c- COUNTY OF ALBANY ) Christine Vanlew, being duly sworn, deposes and says: 1. I am the plaintiff in the above-captioned action and make this Affidavit of Merit in support of the within application for judgment by default pursuant to CPLR §3215. 2. I have a meritorious claim in this action as on October 12, 2015 at approximately 10:30 a.m., I was leaving the Dunkin Donuts building through the rear porch landing when I was caused to fall due to the porch and steps being in a dangerous, defective and broken condition. 3. That as a result of the aforesaid accident and culpable conduct of the defendant, Clad Realty, LLC, I was caused to sustain severe personal injuries, resulting in extensive medical treatment, including ankle surgery, costs and lost wages, together with pain, suffering and disability, all of which will continue into the future. 4. The above-entitled action by me was commenced by service of a Summnm and Complaint on October 2, 2018. 1 of 2 FILED: SARATOGA COUNTY CLERK 03/17/2021 10:35 AM INDEX NO. 20183085 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 03/17/2021 5. It is my understanding that, to date, no Answer has been received by my attorney as required by statute and the defendant, Clad Realty, LLC, is in default. WHEREFORE, for the reasons stated above, deponent respectfully requests an Order of the Court granting a default judgment agMnst the defendant, Clad Realty, LLC, and that an inquest as to damages be scheduled, together with such other and further relief as the Court deems just and proper. CHRISTINE VANLEW Sworn to before me this day of May, 2019. Christopher P. Meyer Esq. Notary Public, State of New York Qualified in NOTARY DBLIC Albany County Registration No. 02ME5049521 Commission Expires9f9jMM 2 of 2