Preview
FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021
"A"
EXHIBIT
FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020
|FILED : QUE CNS COUNTT CLERK 10 /22 /2020 04:12 INDEX NO. 719685/2(20
PM|
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021
NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2(20
File#: 9242
SUPREME COURT OF THE STATE OF NEW YORK Index#:
COUNTY OF QUEENS
-------------,..------------------ X Plaintiff designates
MARIA LUZ VICENTE, QUEENS County
as the Place of Trial
Plaintiff,
SUMMONS
- -against- .
Basis for venue:
NEW Y.ORK.CITY TRANSIT AUTHORITY, MTA BUS . Location of incident
COMPANY, METROPOLITAN TRANSIT AUTHORITY,
and BRENDA i RODRIGUEZ PRUTTS,
Defendants.
To theAbove Named Defendants:
YOU AllE HEREBY SUMMONED to answer the Verified Complaint in this action and
to serve a copy of your Answer, or, if the Verified Complaint is not served withthis Sumrnant to
serve notice of appearance on theplaintiffs attorneys within twenty [20] days after the service of this
Summons, exclusive of the day of service (or withinthirty [30] days after the service is complete if
this Summons is not personally delivered to you within the State of New York.); and in case of your
failure to appear or answer, judgment will be taken against you by default for the relief demanded
in Verified Complaint.
Dated: Garden City, New York
October 22, 2020
SILBERST , AWAD & MIKLOS, P.C.
By: __
Kyl C Brur10, Esq.
Att eysforPlaintiff
600 Old Country Road, Suite 505
Garden City, New York 1 1530
Phone#: (516) 832-7777
Otu·
File#: 9242
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NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2(20
DEFENDANTS'
ADDRESSES:
NEW YORK CITY TRANSIT AUTH.ORITY
130 Livingston Street
Brooklyn, NY 11201
MTA BUS COMPANY
2 Broadway
New YorkcNY 10004
and
College Point Depot
28d¹
128-15 Avenue
Flushing NY 11354
METROPOLITAN TRANSIT AUTHORITY
2 Broadway
New York, NY 10004
BRENDA J. RODRIGUEZ PRUTTS
130 Livingston Street
Brooklyn,.NY 11201
And
LGA Depot
8501 24th Ave, Flushing, NY 11370
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NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
____ ______________ X
MARIA LUZ VICENTE Index#:
Plaintiff,
-against- VERIFIED
COMPLAINT
| NEW YORK CITY TRANSIT AUTHORITY, MTA BUS
COMPANY, METROPOLITAN TRANSIT AUTHORITY, and
BRENDA J. RODRIGUEZ PRUTTS,
Defendants.
___________ ___ .......... X
. . .
Plaintiff, MARIA LU7, VICENTE through her attorneys, SILBERSTEIN, AWAD &
MIKLOS, P.C., complaining of the defendants herein, alleges, upon information and belief, as
.follows:
1. That on October 14, 2Q19, and at all times hereinafter mentioned, plaintiff, MARIA LUZ
VICENTE, was and still is a resident of the County of Queens, State of New York.
2. That on October 14, 2019, and at all times herein mentioned, defendant, NEW YORK CITY
TRANSIT AUTHORITY, was and still is a 1domestic public authority duly organized and existing
under and by virtue of the laws of the State of New York.
3. That on October 14, 2019, at all times hereinafter mentioned, defendant, NEW YORK
CITY TRANSIT AUTHORITY, maintained a principal place of business in the County of Kings,
State of New York.
4. That on Octobei 14, 2019, and at all times hereinafter mentioned, defendant,
NEW YORK CITY TRANSIT AUTHORITY, transacted business in the State of New York.
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5. 1 That on October 14, 2019, and at all times herein mentioned defendant, MTA
BUS COMPANY, was and still is a domestic public authority.
6. That the defendant, MTA BUS COMPANY, is a subsidiary corporatipn of
defendant, Metropolitan Transit Authority (MTA).
l 7. That on October 14, 2019, at all times hereinafter mentioned, defendant, MTA
BUS COMPANY, maintained a principal place of business in the County and State ofNew
York.
8 . That on October 14, 2019, and at all times hereinafter mentioned, defmdant,
MTA BUS COMPANY, transacted business in the State ofNew York.
9. 1That on October 14, 2019, and at all times herein mentioned, defendant,
METROPOLITAN TRANSPORTATION AUT.HORITY, was and still is a domestic public
authority.
10. That on October 14, 2019, at all times hereinafter mentioned, defendant,.
METROPOLITAN TRANSPORTATION AUTHORITY, maintained a principal place of
business in the County and State of New York.
11. That on October 14, 2019, and at all times hereinafter mentioned, defendant,
METROPOLITAN TRANSPORTATION AUTHORITY, transacted business in the State of
New York.
12. That on October 14, 2019, and at all times hereinafter mentioned, defendant,
BRENDA J. RODRIGUEZ PRUTTS was and still is a resident of the County of Queens, State of
New York.
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13. That on October 14, 2019, and at all times hereinafter mentioned, defendant,
BRENDA J. RODRIGUEZ PRUTTS., was and stillis an employee ofdefendant, NEW YORK CITY
TRANSIT AUTH.ORITY with an employee badge number of 33183.
14. That on October 14, 2019, and at all times hereinafter mentioned, defendant,
BRENDA J. RODRIGUEZ PRUTTS, was and still is an employee of defendent, MTA BUS
COMPANY with an employee badge number of 33183,
15. . That on October and at all times hereinafter mentioned,: defendant
14, 2019,
BRENDA J. RODRIGUEZ PRUTTS, was and still is an employee of defendant METROPOLITAN
TRANSPORTATION AUTHORITY with an employee badge number of 33183.
16. That on October 14, 2019, and at all times hereinafter mentioned, defendant,
. BRENDA J. RODRIGUEZ PRUTTS, was an agent, acting within the duty and scope of her
employment as an employee, of defendants, NEW YORK CITY TRANSIT AUTHORITY, MTA
BUS COMPANY, and /or METROPOLITAN TRANSPORTATION AUTHORITY.
17. That on or about November 27, 2019, and within ninety (90) days after the date of
the accident, and more than thirty (30) days prior to conuñcacement of this action, plaintiff duly
presented, served, and filed a Notice of Claim with the NEW YORK CITY TRANSIT
MTA BUS and METROPOLITAN TRANSPORTATION -
AUTHORITY, COMPANY,
AUTHORITY for adjustment of the damagest sustained by the plaintiff herein, upon which this
action is based, and thereafter, more than thirty (30) days have passed, and the defendants, NEW
YORK CITY TRANSIT AUTHORITY, MTA BUS COMPANY and METROPOLITAN
TRANSPORTATION AUTHORITY have failed or refused to make an adjustment of said claim,
and said claim remains unpaid or unadjusted, although plaintiff has duly demanded that same be
adjusted and paid.
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18. 1That pursuant to New York General Municipal Law §50-h, plaintiff, MARIA LUZ
VICENTE, appeared for a 50-h hearing on February 5, 2020 to allow for examination of the claims
underlying this Complaint by attorneys from the defendants.
19. That prior to the commencement of this action, plaintiff duly complied with all
conditions precedent to the bringing of this action against the defendants, NE W YORK CITY
TRANSI F AUTHORITY, MTA BUS COMPANY, and METROPOLITAN TRANSIT
AUTHORITY.
20. That since the filing of plaintiff's claim, the defendants, ..NEW YORK CITY
TRANSIT AUTHORITY, MTA BUS COMPANY, and METROPOLITAN TRANSIT
AUTHORITY, have had a reasonable opportunity and adequate time to investigate plaintiff's claim,
prepare a defense in preparation for the within litigation, and/or to effect settlement before the
. . commencement of this action.
2 l. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW
YORK CITY TRANSIT AUTHORITY, owned a Hybrid bus bearing New York State registration
plate number AT9430 and vehicle #3622.
22. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW
YORK CITY TRANSIT AUTHORITY, was the title owner of a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
23. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW
YORK CITY TRANSIT AUTHORITY, operated a Hybrid bus bearing New York State registration
plate number AT9430 and vehicle #3622.
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24. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW
YORK CITY TRANSIT AUTHORITY, maintained a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
25. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW
YORK CITY TRANSIT AUTHORITY, controlled a Hybrid bus bearingNew York State registration
plate number AT9430 and vehicle #3622.
26. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW
YORK CITY TRANSIT AUTHORITY, managed a Hybrid bus bearing New York State registration
plate number AT9430 and vehicle #3622.
27. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW
YORK CITY TRANSIT AUTHORITY, repaired a Hybrid bus bearing New York State registration
plate number AT9430 and vehicle #3622.
. 28. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW
YORK CTTY TRANSIT AUTHORITY, inspected a Hybrid bus bearing New York State registration
plate number AT9430 and vehicle #3622.
29. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW
YORK CITY TRANSIT AUTHORITY, had possession of a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
30. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA
BUS COMPANY, owned a Hybrid bus bearing New York State registration plate number AT9430
and vehicle #3622.
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31. That·on October 14, 2019, and at all times here in after mentioned, defendant, MTA
BUS COMPANY, was the title owner of a Hybrid bus bearing New York State registration plate
. .
number AT9430 and vehicle #3622.
32. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA
BUS COMPANY, operated a Hybrid bus bearingNew York State registration plate number AT9430
and vehicle #3622.
33. That on October 14, 2019, and at all times here in after mentioned, defendant,. MTA
BUS COMPANY, maintained a Hybrid bus bearing New York State registration plate number
AT9430 and vehicle #3622.
34. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA
BUS COMPANY, controlled a Hybrid bus bearing New York State registration plate number
AT9430 and vehicle #3622.
35. That on October 14, 2019, and at all times here in after mentioned, defendant, .MTA
BUS COMPANY, managed a Hybrid bus bearing New York State registration plate number AT9430
and vehicle #3622.
36. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA
BUS COMPANY, repaired a Hybrid bus bearing New York State registration plate number AT9430
and vehicle #3622.
37. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA
BUS COMPANY, inspected a Hybrid bus bearing New York. State registration plate number
AT9430 and vehicle #3622.
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COUNTY CLERK 10 / 22 / 2020 04:12 PM|
INDEX NO.
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38. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA
BUS COMPANY, had possession ofa Hybrid bus bearing New York State registration plate number
AT9430 and vehicle #3622.
39. That on October 14, 2019, and at all times here in after Inentioned, defendant,
METROPOLITAN TRANSIT AUTHORITY, owned a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
40. That on October 14, 2019, and at all times here in after mentioned, defendant,
METROPOLITAN TRANSITAUTHORITY, was the title owner of a Hybrid bus bearingNew York
State registration plate number AT9430 and vehicle #3622 .
41. That on October 14, 2019, and at all times here in after mentioned, defendant,
METROPOLITAN TRANSIT AUTHORITY, operated a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
42. That on October 14, 2019, and at all times here in after mentioned, defendant,
METROPOLITAN TRANSIT AUTHORITY, maintained a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
43. That on October 14, 2019, and at all times here in after mentioned, defendant,
METROPOLITAN TRANSIT AUTHORITY, controlled a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
44. That on October 14, 2019, and at all times here in after mentioned, defendant,
METROPOLITAN TRANSIT AUTHORITY, managed a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
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45. That on October 14, 2019, and at all times here in aher mentioned, defendant,
METROPOLITAN TRANSIT AUTHORITY, repaired a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
46. That on October 14, 2019, and at all times here in after mentioned, defendant,
METROP OLITAN TRANSIT AUTHORITY, inspected a Hybrid bus bearing New York State
registration plate number AT9430 and vehicle #3622.
47. That on October 14, 2019, and at all times here in after mentioned, defendant,
METROPOLITAN TRANSIT AUTHORITY, had possession of a Hybrid bus bearing New York
State registration plate number AT9430 and vehicle #3622.
48. That on October 14, 2019, and at all times here in after mentioned, defendant,
i. BRENDA J. RODRIGUEZ PRUTTS, operated a Hybrid bus bearing New York. State registration
92nd
plate number AT9430 and vehicle #3622 at or near the corner of Street and Astoria Blvd, in the
County of Queens, State of New York with permission and consent of its owner, 1 within the scope
of that permission and consent, and 1within the scope of her employment..
49. That on October 14, 2019, and at all times here in after mentioned, defendant,
BRENDA L RODRIGUEZ PRUTTS, controlled a Hybrid bus bearing New York State registration
of92"d
plate number AT9430 and vehicle #3622 at or near the corner Street and Astoria Blvd, in the
County of Queens, State of New York with permission and consent of its owner, 1 within the scope
of that permission and consent, and 1within the scope of her employment.
50. That on October 14, 2019, and at all times here in after mentioned, defendant,
BRENDA J. RODRIGUEZ PRUTTS, managed a Hybrid bus bearing New York State registration
92nd
plate number AT9430 and vehicle.#3622 at or near the corner of Street and Astoria Blyd,.in the
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/22/2020
County of Queens,
Preview
FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021 "A" EXHIBIT FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 |FILED : QUE CNS COUNTT CLERK 10 /22 /2020 04:12 INDEX NO. 719685/2(20 PM| NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2(20 File#: 9242 SUPREME COURT OF THE STATE OF NEW YORK Index#: COUNTY OF QUEENS -------------,..------------------ X Plaintiff designates MARIA LUZ VICENTE, QUEENS County as the Place of Trial Plaintiff, SUMMONS - -against- . Basis for venue: NEW Y.ORK.CITY TRANSIT AUTHORITY, MTA BUS . Location of incident COMPANY, METROPOLITAN TRANSIT AUTHORITY, and BRENDA i RODRIGUEZ PRUTTS, Defendants. To theAbove Named Defendants: YOU AllE HEREBY SUMMONED to answer the Verified Complaint in this action and to serve a copy of your Answer, or, if the Verified Complaint is not served withthis Sumrnant to serve notice of appearance on theplaintiffs attorneys within twenty [20] days after the service of this Summons, exclusive of the day of service (or withinthirty [30] days after the service is complete if this Summons is not personally delivered to you within the State of New York.); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in Verified Complaint. Dated: Garden City, New York October 22, 2020 SILBERST , AWAD & MIKLOS, P.C. By: __ Kyl C Brur10, Esq. Att eysforPlaintiff 600 Old Country Road, Suite 505 Garden City, New York 1 1530 Phone#: (516) 832-7777 Otu· File#: 9242 1 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 CLERK INDEX NO. 719685/2 20 FILED NYSCEF : DOC. QUEENS NO. 19 COUNTY 10/2272020 04: 12 PMl RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2(20 DEFENDANTS' ADDRESSES: NEW YORK CITY TRANSIT AUTH.ORITY 130 Livingston Street Brooklyn, NY 11201 MTA BUS COMPANY 2 Broadway New YorkcNY 10004 and College Point Depot 28d¹ 128-15 Avenue Flushing NY 11354 METROPOLITAN TRANSIT AUTHORITY 2 Broadway New York, NY 10004 BRENDA J. RODRIGUEZ PRUTTS 130 Livingston Street Brooklyn,.NY 11201 And LGA Depot 8501 24th Ave, Flushing, NY 11370 2 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 CLERK INDEX NO. 719685/2020 [FILED : QUEENS COUNTY 10 / 2 2 / 2 0 2 0 0 4 : 12 PM| NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2d20 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ____ ______________ X MARIA LUZ VICENTE Index#: Plaintiff, -against- VERIFIED COMPLAINT | NEW YORK CITY TRANSIT AUTHORITY, MTA BUS COMPANY, METROPOLITAN TRANSIT AUTHORITY, and BRENDA J. RODRIGUEZ PRUTTS, Defendants. ___________ ___ .......... X . . . Plaintiff, MARIA LU7, VICENTE through her attorneys, SILBERSTEIN, AWAD & MIKLOS, P.C., complaining of the defendants herein, alleges, upon information and belief, as .follows: 1. That on October 14, 2Q19, and at all times hereinafter mentioned, plaintiff, MARIA LUZ VICENTE, was and still is a resident of the County of Queens, State of New York. 2. That on October 14, 2019, and at all times herein mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, was and still is a 1domestic public authority duly organized and existing under and by virtue of the laws of the State of New York. 3. That on October 14, 2019, at all times hereinafter mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, maintained a principal place of business in the County of Kings, State of New York. 4. That on Octobei 14, 2019, and at all times hereinafter mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, transacted business in the State of New York. 3 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 INDEX NO. 719685/2020 FILED: QUEENS COUNTY CLERK 10/_22/2020 04 :12 PM) NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO 1 RÉCEIVED NYSCEF: 10/22/2d20 5. 1 That on October 14, 2019, and at all times herein mentioned defendant, MTA BUS COMPANY, was and still is a domestic public authority. 6. That the defendant, MTA BUS COMPANY, is a subsidiary corporatipn of defendant, Metropolitan Transit Authority (MTA). l 7. That on October 14, 2019, at all times hereinafter mentioned, defendant, MTA BUS COMPANY, maintained a principal place of business in the County and State ofNew York. 8 . That on October 14, 2019, and at all times hereinafter mentioned, defmdant, MTA BUS COMPANY, transacted business in the State ofNew York. 9. 1That on October 14, 2019, and at all times herein mentioned, defendant, METROPOLITAN TRANSPORTATION AUT.HORITY, was and still is a domestic public authority. 10. That on October 14, 2019, at all times hereinafter mentioned, defendant,. METROPOLITAN TRANSPORTATION AUTHORITY, maintained a principal place of business in the County and State of New York. 11. That on October 14, 2019, and at all times hereinafter mentioned, defendant, METROPOLITAN TRANSPORTATION AUTHORITY, transacted business in the State of New York. 12. That on October 14, 2019, and at all times hereinafter mentioned, defendant, BRENDA J. RODRIGUEZ PRUTTS was and still is a resident of the County of Queens, State of New York. 4 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 QUEENS COUNTY CLERK 10 INDEX NO. 719685/2020 (FILED_1 DOC. NO. 19 NYSCEF / 2 2 / 2 0 2 0 04 : 12 PM1 RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2020 13. That on October 14, 2019, and at all times hereinafter mentioned, defendant, BRENDA J. RODRIGUEZ PRUTTS., was and stillis an employee ofdefendant, NEW YORK CITY TRANSIT AUTH.ORITY with an employee badge number of 33183. 14. That on October 14, 2019, and at all times hereinafter mentioned, defendant, BRENDA J. RODRIGUEZ PRUTTS, was and still is an employee of defendent, MTA BUS COMPANY with an employee badge number of 33183, 15. . That on October and at all times hereinafter mentioned,: defendant 14, 2019, BRENDA J. RODRIGUEZ PRUTTS, was and still is an employee of defendant METROPOLITAN TRANSPORTATION AUTHORITY with an employee badge number of 33183. 16. That on October 14, 2019, and at all times hereinafter mentioned, defendant, . BRENDA J. RODRIGUEZ PRUTTS, was an agent, acting within the duty and scope of her employment as an employee, of defendants, NEW YORK CITY TRANSIT AUTHORITY, MTA BUS COMPANY, and /or METROPOLITAN TRANSPORTATION AUTHORITY. 17. That on or about November 27, 2019, and within ninety (90) days after the date of the accident, and more than thirty (30) days prior to conuñcacement of this action, plaintiff duly presented, served, and filed a Notice of Claim with the NEW YORK CITY TRANSIT MTA BUS and METROPOLITAN TRANSPORTATION - AUTHORITY, COMPANY, AUTHORITY for adjustment of the damagest sustained by the plaintiff herein, upon which this action is based, and thereafter, more than thirty (30) days have passed, and the defendants, NEW YORK CITY TRANSIT AUTHORITY, MTA BUS COMPANY and METROPOLITAN TRANSPORTATION AUTHORITY have failed or refused to make an adjustment of said claim, and said claim remains unpaid or unadjusted, although plaintiff has duly demanded that same be adjusted and paid. 5 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 CT.RRK INDEX NO. 719685/2 20 [FT-LED : QUEENS COUNTY 10 / 2 2 / 2 0 2 0 0 4 : 12 PMI NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2 20 18. 1That pursuant to New York General Municipal Law §50-h, plaintiff, MARIA LUZ VICENTE, appeared for a 50-h hearing on February 5, 2020 to allow for examination of the claims underlying this Complaint by attorneys from the defendants. 19. That prior to the commencement of this action, plaintiff duly complied with all conditions precedent to the bringing of this action against the defendants, NE W YORK CITY TRANSI F AUTHORITY, MTA BUS COMPANY, and METROPOLITAN TRANSIT AUTHORITY. 20. That since the filing of plaintiff's claim, the defendants, ..NEW YORK CITY TRANSIT AUTHORITY, MTA BUS COMPANY, and METROPOLITAN TRANSIT AUTHORITY, have had a reasonable opportunity and adequate time to investigate plaintiff's claim, prepare a defense in preparation for the within litigation, and/or to effect settlement before the . . commencement of this action. 2 l. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, owned a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 22. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, was the title owner of a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 23. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, operated a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 6 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 INDEX NO. 719685/2020 F I LED : QUE Ei:NS COUNTY CLERK 10 / 2 2 / 2 0 2 O 0 4 : 12 PMI NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2n20 24. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, maintained a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 25. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, controlled a Hybrid bus bearingNew York State registration plate number AT9430 and vehicle #3622. 26. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, managed a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 27. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, repaired a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. . 28. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW YORK CTTY TRANSIT AUTHORITY, inspected a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 29. That on October 14, 2019, and at all times here in after mentioned, defendant, NEW YORK CITY TRANSIT AUTHORITY, had possession of a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 30. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA BUS COMPANY, owned a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 7 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 INDEX NO. 719685/2020 [FI LED : QUEENS COUNTY CLERK 10 / 2 2 /_2 0 2 0 0 4 : 12 PM| NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2020 31. That·on October 14, 2019, and at all times here in after mentioned, defendant, MTA BUS COMPANY, was the title owner of a Hybrid bus bearing New York State registration plate . . number AT9430 and vehicle #3622. 32. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA BUS COMPANY, operated a Hybrid bus bearingNew York State registration plate number AT9430 and vehicle #3622. 33. That on October 14, 2019, and at all times here in after mentioned, defendant,. MTA BUS COMPANY, maintained a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 34. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA BUS COMPANY, controlled a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 35. That on October 14, 2019, and at all times here in after mentioned, defendant, .MTA BUS COMPANY, managed a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 36. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA BUS COMPANY, repaired a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 37. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA BUS COMPANY, inspected a Hybrid bus bearing New York. State registration plate number AT9430 and vehicle #3622. 8 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 MLED : QUE ENS NYSCEF DOC. NO. 19 COUNTY CLERK 10 / 22 / 2020 04:12 PM| INDEX NO. RECEIVED NYSCEF: 04/08/2021 719685/2020 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2020 38. That on October 14, 2019, and at all times here in after mentioned, defendant, MTA BUS COMPANY, had possession ofa Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 39. That on October 14, 2019, and at all times here in after Inentioned, defendant, METROPOLITAN TRANSIT AUTHORITY, owned a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 40. That on October 14, 2019, and at all times here in after mentioned, defendant, METROPOLITAN TRANSITAUTHORITY, was the title owner of a Hybrid bus bearingNew York State registration plate number AT9430 and vehicle #3622 . 41. That on October 14, 2019, and at all times here in after mentioned, defendant, METROPOLITAN TRANSIT AUTHORITY, operated a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 42. That on October 14, 2019, and at all times here in after mentioned, defendant, METROPOLITAN TRANSIT AUTHORITY, maintained a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 43. That on October 14, 2019, and at all times here in after mentioned, defendant, METROPOLITAN TRANSIT AUTHORITY, controlled a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 44. That on October 14, 2019, and at all times here in after mentioned, defendant, METROPOLITAN TRANSIT AUTHORITY, managed a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 9 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 LED : QUE INS COUNTY CLERK 2 0 2 0 EDEX NO. 719685/2n20 10/X27 0 4 : 12 PM| NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO 1 RECEIVED NYSCEF: 10/22/2020 45. That on October 14, 2019, and at all times here in aher mentioned, defendant, METROPOLITAN TRANSIT AUTHORITY, repaired a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 46. That on October 14, 2019, and at all times here in after mentioned, defendant, METROP OLITAN TRANSIT AUTHORITY, inspected a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 47. That on October 14, 2019, and at all times here in after mentioned, defendant, METROPOLITAN TRANSIT AUTHORITY, had possession of a Hybrid bus bearing New York State registration plate number AT9430 and vehicle #3622. 48. That on October 14, 2019, and at all times here in after mentioned, defendant, i. BRENDA J. RODRIGUEZ PRUTTS, operated a Hybrid bus bearing New York. State registration 92nd plate number AT9430 and vehicle #3622 at or near the corner of Street and Astoria Blvd, in the County of Queens, State of New York with permission and consent of its owner, 1 within the scope of that permission and consent, and 1within the scope of her employment.. 49. That on October 14, 2019, and at all times here in after mentioned, defendant, BRENDA L RODRIGUEZ PRUTTS, controlled a Hybrid bus bearing New York State registration of92"d plate number AT9430 and vehicle #3622 at or near the corner Street and Astoria Blvd, in the County of Queens, State of New York with permission and consent of its owner, 1 within the scope of that permission and consent, and 1within the scope of her employment. 50. That on October 14, 2019, and at all times here in after mentioned, defendant, BRENDA J. RODRIGUEZ PRUTTS, managed a Hybrid bus bearing New York State registration 92nd plate number AT9430 and vehicle.#3622 at or near the corner of Street and Astoria Blyd,.in the 10 of 15 FILED: QUEENS COUNTY CLERK 04/08/2021 09:50 AM INDEX NO. 719685/2020 INDEX NO. 719685/2020 [FILED : QUEENS COUNTY CLERK 10 /22 /202 0 04_: 12 . P NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 04/08/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/22/2020 County of Queens,