Preview
FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020
NYSCEF DOC. NO. 5 LAW OFFICES RECEIVED NYSCEF: 01/04/2021
OF
ADAM L. SHAPIRO & ASSOCIATES, P.C. 7
www.Shapirolawoffice.com
QUEENS OFFICE NASSAU OFFICE
70 - 20 Austin St., Ste. 111 6 Willow Lane
Forest Hills, NY 11375 Hewlett Harbor. NY 11557
(718)261- 8500 Phone (516)749-1626Phone
- 2102 Facsimile - 3825 Facsimile
(718) 732 (516) 908
e-mail: Adam@Shapirolawoffice.com Reply To: QUEENS Office
*New York and Florida Bars
December 1, 2020
PEDRO MONTES-ROJAS
102-29 47th Avenue Apt. IB
Corona, NY 11368
Re: Your accident of September 15, 2020
Our File No.: 20-039
Dear Mr. PEDRO
Enclosed is an Affidavit of Merit needed for your Motion of Default Judgment.
"X"
Please read it and sign everywhere that is indicated by the on all pages and return the
Affidavit to me in the envelope provided for your convenience. Please do so immediately.
Thank you for your time and consideration.
Very truly yours,
Salah Shawa
ALS/SS
FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS AFFIDAVIT OF MERIT
----------------------------------------------------------------------X Index No. 705437/2020
PEDRO MONTES-ROJAS,
Plaintiff,
- against -
PUGLIA OF HESTER STREET INC., and PUGLIA
OF HESTER STREET INC. D/B/A PUGLIA
RESTAURANT,
Defendants.
----------------------------------------------------------------------X
STATE OF NEW YORK
COUNTY OF
PEDRO MONTES-ROJAS, being duly sworn deposes and says as follows, under the
penalties of perjury:
1. My name is PEDRO MONTES-ROJAS, and I am the Plaintiff in the above captioned
matter.
2. I make this affidavit to verify the truthfulness of the allegations contained within my
Complaint, and to the merit of said allegations, all in support of my instant motion for a
Default Judgement against Defendants, PUGLIA OF HESTER STREET INC., and
PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT,. A copy of my
complaint is annexed hereto as Plaintiff's Exhibit "A".
3. On September 15, 2019 while I was lawfully in, at, or about the premises located at 189
Hester Street, County of New York, State of New York, I was caused to slip, trip and/or
fall and sustain severe, serious and permanent injuries.
4. I retained the law firm of Adam L. Shapiro & Associated, P.C. who commenced a lawsuit
on my behalf and brought suit against Defendants, PUGLIA OF HESTER STREET INC.,
and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT.
5. My attorneys informed me that Defendants have been served but have not interposed an
Answer in this matter despite letters to them requesting same.
6. I have read the annexed Summons and Complaint and swear and affirm the truthfulness
of the allegations contained therein.
Dated: New York
December 1, 2020
FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021
EDRO MONTES-ROJ ,
Sworn to before me this
day of August, 2020
N
FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS AFFIDAVIT OF MERIT
----------------------------------------------------------------------X Index No. 705437/2020
PEDRO MONTES-ROJAS,
Plaintiff,
- against -
PUGLIA OF HESTER STREET INC., and PUGLIA
OF HESTER STREET INC. D/B/A PUGLIA
RESTAURANT,
Defendants.
-------------------------------------------------------------------X
STATE OF NEW YORK
COUNTY OF
PEDRO MONTES-ROJAS, being duly sworn deposes and says as follows, under the
penalties of perjury:
1. My name is PEDRO MONTES-ROJAS, and I am the Plaintiff in the above captioned
matter.
2. I make this affidavit to verify the truthfulness of the allegations contained within my
Complaint, and to the merit of said allegations, all in support of my instant motion for a
Default Judgement against Defendants, PUGLIA OF HESTER STREET INC., and
PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT,. A copy of my
complaint is annexed hereto as Plaintiff's Exhibit "A".
3. On September 15, 2019 while I was lawfully in, at, or about the premises located at 189
Hester Street, County of New York, State of New York, I was caused to slip, trip and/or
fall and sustain severe, serious and permanent injuries.
4. I retained the law firm of Adam L. Shapiro & Associated, P.C. who commenced a lawsuit
on my behalf and brought suit against Defendants, PUGLIA OF HESTER STREET INC.,
and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT.
5. My attorneys informed me that Defendants have been served but have not interposed an
Answer in this matter despite letters to them requesting same.
6. I have read the annexed Summons and Complaint and swear and affirm the truthfulness
of the allegations contained therein.
Dated: New York
December 1, 2020
FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021
PEDR S-RO 8,
Sworn to before me this
day of August, 2020
N
FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS AFFIDAVIT OF MERIT
_______________________----------------------------------------------X Index No. 705437/2020
PEDRO MONTES-ROJAS,
Plaintiff,
- against -
PUGLIA OF HESTER STREET INC., and PUGLIA
OF HESTER STREET INC. D/B/A PUGLIA
RESTAURANT,
Defendants.
---------------------------------------------------------------------X
STATE OF NEW YORK
COUNTY OF
PEDRO MONTES-ROJAS, being duly sworn deposes and says as follows, under the
penalties of perjury:
1. My name is PEDRO MONTES-ROJAS, and I am the Plaintiff in the above captioned
matter.
2. I make this affidavit to verify the truthfulness of the allegations contained within my
Complaint, and to the merit of said allegations, all in support of my instant motion for a
Default Judgement against Defendants, PUGLIA OF HESTER STREET INC., and
PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT,. A copy of my
complaint is annexed hereto as Plaintiff's Exhibit "A".
3. On September 15, 2019 while I was lawfully in, at, or about the premises located at 189
Hester Street, County of New York, State of New York, I was caused to slip, trip and/or
fall and sustain severe, serious and permanent injuries.
4. I retained the law firm of Adam L. Shapiro & Associated, P.C. who commenced a lawsuit
on my behalf and brought suit against Defendants, PUGLIA OF HESTER STREET INC.,
and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT.
5. My attorneys informed me that Defendants have been served but have not interposed an
Answer in this matter despite letters to them requesting same.
6. I have read the annexed Summons and Complaint and swear and affirm the truthfulness
of the allegations contained therein.
Dated: New York
December 1, 2020
FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021
- O ,
RO
Sworn to before me this
of August, 2020
____ day
Notary Public
Preview
FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020 NYSCEF DOC. NO. 5 LAW OFFICES RECEIVED NYSCEF: 01/04/2021 OF ADAM L. SHAPIRO & ASSOCIATES, P.C. 7 www.Shapirolawoffice.com QUEENS OFFICE NASSAU OFFICE 70 - 20 Austin St., Ste. 111 6 Willow Lane Forest Hills, NY 11375 Hewlett Harbor. NY 11557 (718)261- 8500 Phone (516)749-1626Phone - 2102 Facsimile - 3825 Facsimile (718) 732 (516) 908 e-mail: Adam@Shapirolawoffice.com Reply To: QUEENS Office *New York and Florida Bars December 1, 2020 PEDRO MONTES-ROJAS 102-29 47th Avenue Apt. IB Corona, NY 11368 Re: Your accident of September 15, 2020 Our File No.: 20-039 Dear Mr. PEDRO Enclosed is an Affidavit of Merit needed for your Motion of Default Judgment. "X" Please read it and sign everywhere that is indicated by the on all pages and return the Affidavit to me in the envelope provided for your convenience. Please do so immediately. Thank you for your time and consideration. Very truly yours, Salah Shawa ALS/SS FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS AFFIDAVIT OF MERIT ----------------------------------------------------------------------X Index No. 705437/2020 PEDRO MONTES-ROJAS, Plaintiff, - against - PUGLIA OF HESTER STREET INC., and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT, Defendants. ----------------------------------------------------------------------X STATE OF NEW YORK COUNTY OF PEDRO MONTES-ROJAS, being duly sworn deposes and says as follows, under the penalties of perjury: 1. My name is PEDRO MONTES-ROJAS, and I am the Plaintiff in the above captioned matter. 2. I make this affidavit to verify the truthfulness of the allegations contained within my Complaint, and to the merit of said allegations, all in support of my instant motion for a Default Judgement against Defendants, PUGLIA OF HESTER STREET INC., and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT,. A copy of my complaint is annexed hereto as Plaintiff's Exhibit "A". 3. On September 15, 2019 while I was lawfully in, at, or about the premises located at 189 Hester Street, County of New York, State of New York, I was caused to slip, trip and/or fall and sustain severe, serious and permanent injuries. 4. I retained the law firm of Adam L. Shapiro & Associated, P.C. who commenced a lawsuit on my behalf and brought suit against Defendants, PUGLIA OF HESTER STREET INC., and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT. 5. My attorneys informed me that Defendants have been served but have not interposed an Answer in this matter despite letters to them requesting same. 6. I have read the annexed Summons and Complaint and swear and affirm the truthfulness of the allegations contained therein. Dated: New York December 1, 2020 FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021 EDRO MONTES-ROJ , Sworn to before me this day of August, 2020 N FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS AFFIDAVIT OF MERIT ----------------------------------------------------------------------X Index No. 705437/2020 PEDRO MONTES-ROJAS, Plaintiff, - against - PUGLIA OF HESTER STREET INC., and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT, Defendants. -------------------------------------------------------------------X STATE OF NEW YORK COUNTY OF PEDRO MONTES-ROJAS, being duly sworn deposes and says as follows, under the penalties of perjury: 1. My name is PEDRO MONTES-ROJAS, and I am the Plaintiff in the above captioned matter. 2. I make this affidavit to verify the truthfulness of the allegations contained within my Complaint, and to the merit of said allegations, all in support of my instant motion for a Default Judgement against Defendants, PUGLIA OF HESTER STREET INC., and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT,. A copy of my complaint is annexed hereto as Plaintiff's Exhibit "A". 3. On September 15, 2019 while I was lawfully in, at, or about the premises located at 189 Hester Street, County of New York, State of New York, I was caused to slip, trip and/or fall and sustain severe, serious and permanent injuries. 4. I retained the law firm of Adam L. Shapiro & Associated, P.C. who commenced a lawsuit on my behalf and brought suit against Defendants, PUGLIA OF HESTER STREET INC., and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT. 5. My attorneys informed me that Defendants have been served but have not interposed an Answer in this matter despite letters to them requesting same. 6. I have read the annexed Summons and Complaint and swear and affirm the truthfulness of the allegations contained therein. Dated: New York December 1, 2020 FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021 PEDR S-RO 8, Sworn to before me this day of August, 2020 N FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS AFFIDAVIT OF MERIT _______________________----------------------------------------------X Index No. 705437/2020 PEDRO MONTES-ROJAS, Plaintiff, - against - PUGLIA OF HESTER STREET INC., and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT, Defendants. ---------------------------------------------------------------------X STATE OF NEW YORK COUNTY OF PEDRO MONTES-ROJAS, being duly sworn deposes and says as follows, under the penalties of perjury: 1. My name is PEDRO MONTES-ROJAS, and I am the Plaintiff in the above captioned matter. 2. I make this affidavit to verify the truthfulness of the allegations contained within my Complaint, and to the merit of said allegations, all in support of my instant motion for a Default Judgement against Defendants, PUGLIA OF HESTER STREET INC., and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT,. A copy of my complaint is annexed hereto as Plaintiff's Exhibit "A". 3. On September 15, 2019 while I was lawfully in, at, or about the premises located at 189 Hester Street, County of New York, State of New York, I was caused to slip, trip and/or fall and sustain severe, serious and permanent injuries. 4. I retained the law firm of Adam L. Shapiro & Associated, P.C. who commenced a lawsuit on my behalf and brought suit against Defendants, PUGLIA OF HESTER STREET INC., and PUGLIA OF HESTER STREET INC. D/B/A PUGLIA RESTAURANT. 5. My attorneys informed me that Defendants have been served but have not interposed an Answer in this matter despite letters to them requesting same. 6. I have read the annexed Summons and Complaint and swear and affirm the truthfulness of the allegations contained therein. Dated: New York December 1, 2020 FILED: QUEENS COUNTY CLERK 01/04/2021 11:33 AM INDEX NO. 705437/2020 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/04/2021 - O , RO Sworn to before me this of August, 2020 ____ day Notary Public