On March 25, 2021 a
AFFIRMATION OF GOOD FAITH
was filed
involving a dispute between
Ccrnc,
Crnc Llc Dba Cortland Park Rehabilitation And Nursing Center,
Crown Park Rehabilitation And Nursing Center,
and
Carol Alexander,
Paul Alexander,
for Commercial - Contract
in the District Court of Cortland County.
Preview
FILED: CORTLAND COUNTY CLERK 09/06/2022 10:40 AM INDEX NO. EF21-165
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 09/06/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF CORTLAND
______________________________________________________________________________ x
CCRNC, CROWN PARK REHABILITATION AND Index No.: EF21-165
NURSING CENTER, CRNC LLC d/b/a CORTLAND PARK
REHABILITATION AND NURSING CENTER,
GOOD FAITH
Plaintiffs, AFFIRMATION
- against -
CAROL ALEXANDER and PAUL ALEXANDER,
Defendants.
______________________________________________________________________________ x
DANIEL L. SULLIVAN, an attorney duly admitted to practice law before the Courts of
the State of New York, affirms that the following statements are true under the penalties of
perjury:
1. I am an associate with the law firm of WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP, attorneys for plaintiff, CROWN PARK REHABILITATION
AND NURSING CENTER and, as such, am fully familiar with the facts and circumstances
herein, the source of my knowledge being the files maintained by this office for the defense of
this matter.
2. Prior to seeking judicial intervention a good faith effort was made in an attempt to
defendants'
obtain compliance and to resolve the discovery issues raised in this motion.
Specifically, good faith correspondence was sent via e-mail on March 8, 2022 to defendants
seeking their compliance with outstanding discovery. The correspondence did not result in
responses, necessitating this Motion. A copy of the good faith correspondence is annexed hereto
"F."
as Exhibit
WHEREFORE, it is respectfully requested that the within motion be granted in its
entirety.
2022325329
EF21-165
09/06/2022 10:40:55 AM
Pages 2
AFFIRMATION OF GOOD FAITH
Elizabeth Larkin, County Clerk
1 of 2
FILED: CORTLAND COUNTY CLERK 09/06/2022 10:40 AM INDEX NO. EF21-165
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 09/06/2022
Dated: New York, New York
September 6, 2022
Yours, etc.
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
By: Da e L.. StxR¿yoov, E
Daniel L. Sullivan, Esq.
Attorney for Plaintiff
CROWN PARK REHABILITATION AND
NURSING CENTER
42nd
150 East Street
New York, New York 10017
(212) 490-3000
File No.: 23625.00002
TO: Allan C. VanDeMark, Esq.
WILLIAMSON, CLUNE & STEVENS
Attorneys for Defendants
Office and Post Office Address
317 North Tioga Street, P.O. Box 126
Ithaca, NY 14851
(607) 273-3339
av@weslaw.net
Harvey D. Mervis, Esq.
HINMAN, HOWARD & KATTELL, LLP
Attorneys for Plaintiff
CCRNC
80 Exchange Street
Binghamton, NY 13902
(607) 723-5341
hmervis@hhk.com
2
2 of 2
Document Filed Date
September 06, 2022
Case Filing Date
March 25, 2021
Category
Commercial - Contract
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FILED: CORTLAND COUNTY CLERK 09/06/2022 10:40 AM INDEX NO. EF21-165 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 09/06/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF CORTLAND ______________________________________________________________________________ x CCRNC, CROWN PARK REHABILITATION AND Index No.: EF21-165 NURSING CENTER, CRNC LLC d/b/a CORTLAND PARK REHABILITATION AND NURSING CENTER, GOOD FAITH Plaintiffs, AFFIRMATION - against - CAROL ALEXANDER and PAUL ALEXANDER, Defendants. ______________________________________________________________________________ x DANIEL L. SULLIVAN, an attorney duly admitted to practice law before the Courts of the State of New York, affirms that the following statements are true under the penalties of perjury: 1. I am an associate with the law firm of WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP, attorneys for plaintiff, CROWN PARK REHABILITATION AND NURSING CENTER and, as such, am fully familiar with the facts and circumstances herein, the source of my knowledge being the files maintained by this office for the defense of this matter. 2. Prior to seeking judicial intervention a good faith effort was made in an attempt to defendants' obtain compliance and to resolve the discovery issues raised in this motion. Specifically, good faith correspondence was sent via e-mail on March 8, 2022 to defendants seeking their compliance with outstanding discovery. The correspondence did not result in responses, necessitating this Motion. A copy of the good faith correspondence is annexed hereto "F." as Exhibit WHEREFORE, it is respectfully requested that the within motion be granted in its entirety. 2022325329 EF21-165 09/06/2022 10:40:55 AM Pages 2 AFFIRMATION OF GOOD FAITH Elizabeth Larkin, County Clerk 1 of 2 FILED: CORTLAND COUNTY CLERK 09/06/2022 10:40 AM INDEX NO. EF21-165 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 09/06/2022 Dated: New York, New York September 6, 2022 Yours, etc. WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP By: Da e L.. StxR¿yoov, E Daniel L. Sullivan, Esq. Attorney for Plaintiff CROWN PARK REHABILITATION AND NURSING CENTER 42nd 150 East Street New York, New York 10017 (212) 490-3000 File No.: 23625.00002 TO: Allan C. VanDeMark, Esq. WILLIAMSON, CLUNE & STEVENS Attorneys for Defendants Office and Post Office Address 317 North Tioga Street, P.O. Box 126 Ithaca, NY 14851 (607) 273-3339 av@weslaw.net Harvey D. Mervis, Esq. HINMAN, HOWARD & KATTELL, LLP Attorneys for Plaintiff CCRNC 80 Exchange Street Binghamton, NY 13902 (607) 723-5341 hmervis@hhk.com 2 2 of 2