On November 16, 2021 a
AFFIRMATION
was filed
involving a dispute between
Jerson Galeano,
and
Ninhursag Properties Llc,
for Torts - Other (Labor Law)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 08/08/2022 06:10 PM INDEX NO. 160393/2021
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 08/08/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
__________..____________________..________ x
JERSON GALEANO, AFFIRMATION OF
GOOD FAITH FOR
Plaintiff, PRELIMINARY
CONFERENCE
-against-
Index No.: 160393/2021
NINHURSAG PROPERTIES LLC,
Defendant.
____________________-__________________Ç
Christopher J. Gorayeb, an attorney duly admitted to practice law in the Courts of
the State of New York, hereby affirms the following to be true under penalty of perjury:
I am a member of the firm of GORAYEB & ASSOCIATES, P.C., attorney for the
plaintiff in the above entitled action, and as such I am fully familiar with the facts and
circumstances herein.
This affirmation is submitted in connection with the attached request for a
preliminary conference.
This action seeks money damages for the severe and permanent personal injuries
sustained by plaintiff as a result of the negligence of the defendants herein.
That your affirmants office has made a good faith effort to resolve the issues
contained in this request for a preliminary conference for a discovery schedule and such
efforts were not successful. Judicial intervention is necessary at this time.
WHEREFORE, it is respectfully requested that a Preliminary Conference date be
set by this Court.
Dated: New York, New York
August 8, 2022
Christoph rÓ. Gorayeb
LawOffices
GORAYEB& ASSOCIATES,
P.C.
100WILUAMSTREET
NEWYORK,NEWYORK10038
1 of 1
Document Filed Date
August 08, 2022
Case Filing Date
November 16, 2021
Category
Torts - Other (Labor Law)
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FILED: NEW YORK COUNTY CLERK 08/08/2022 06:10 PM INDEX NO. 160393/2021 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 08/08/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK __________..____________________..________ x JERSON GALEANO, AFFIRMATION OF GOOD FAITH FOR Plaintiff, PRELIMINARY CONFERENCE -against- Index No.: 160393/2021 NINHURSAG PROPERTIES LLC, Defendant. ____________________-__________________Ç Christopher J. Gorayeb, an attorney duly admitted to practice law in the Courts of the State of New York, hereby affirms the following to be true under penalty of perjury: I am a member of the firm of GORAYEB & ASSOCIATES, P.C., attorney for the plaintiff in the above entitled action, and as such I am fully familiar with the facts and circumstances herein. This affirmation is submitted in connection with the attached request for a preliminary conference. This action seeks money damages for the severe and permanent personal injuries sustained by plaintiff as a result of the negligence of the defendants herein. That your affirmants office has made a good faith effort to resolve the issues contained in this request for a preliminary conference for a discovery schedule and such efforts were not successful. Judicial intervention is necessary at this time. WHEREFORE, it is respectfully requested that a Preliminary Conference date be set by this Court. Dated: New York, New York August 8, 2022 Christoph rÓ. Gorayeb LawOffices GORAYEB& ASSOCIATES, P.C. 100WILUAMSTREET NEWYORK,NEWYORK10038 1 of 1