On September 15, 2023 a
EXHIBIT(S) - F (Motion #003) - Affidavit of Jada Seeram
was filed
involving a dispute between
In The Matter Of The Claim Of Hilda Altagracia Guzman,
and
The City Of New York,
for Special Proceedings - Other (Trip and Fall)
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 10/27/2023 03:19 PM INDEX NO. 719177/2023
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/27/2023
Exhibit F
FILED: QUEENS COUNTY CLERK 10/27/2023 03:19 PM INDEX NO. 719177/2023
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/27/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
------------------------------------------------------------------X Index No. 719177/2023
In the Matter of the Claim of
HILDA ALTAGRACIA GUZMAN,
AFFIDAVIT OF
Petitioner JADA SEERAM
-against-
THE CITY OF NEW YORK,
Respondents.
---------------- ------------.-----------------------------X
STATE OF NEW YORK )
) ss.:
COUNTY OF NEW YORK )
JADA SEERAM, being duly sworn, deposes and says:
1. I am an employee of Subin Associates, LLP ("Subin"). I am a member of Subin's
Investigations Team and in that role, I am responsible for reviewing, investigating, and collecting
all pertinent information relating to newly opened case files.
2. On October 10, 2022, I was assigned to work on the file of Hilda A. Guzman. I
conducted various property and tax searches and identified the owner of the property where the
incident involving Ms. Guzman occurred. I also reviewed the location photographs taken by Danny
Batista. However, I failed to identify the property as a one-, two- or three family residence and
therefore I inadvertently did not add the City of New York as a defendant in the file or designate
the case as Municipal in the case file.
Sworn to before me before this
• '"2>� day of �bee , 2023
&lmij6ER URIBE
���-
Notary Public, State of New
York
"'-•- 'ffiNo.�1UA6402647
"fUal ed In New York County
Commission Expires January s,
2024 1
Document Filed Date
October 27, 2023
Case Filing Date
September 15, 2023
Category
Special Proceedings - Other (Trip and Fall)
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Preview
FILED: QUEENS COUNTY CLERK 10/27/2023 03:19 PM INDEX NO. 719177/2023 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/27/2023 Exhibit F FILED: QUEENS COUNTY CLERK 10/27/2023 03:19 PM INDEX NO. 719177/2023 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 10/27/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ------------------------------------------------------------------X Index No. 719177/2023 In the Matter of the Claim of HILDA ALTAGRACIA GUZMAN, AFFIDAVIT OF Petitioner JADA SEERAM -against- THE CITY OF NEW YORK, Respondents. ---------------- ------------.-----------------------------X STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) JADA SEERAM, being duly sworn, deposes and says: 1. I am an employee of Subin Associates, LLP ("Subin"). I am a member of Subin's Investigations Team and in that role, I am responsible for reviewing, investigating, and collecting all pertinent information relating to newly opened case files. 2. On October 10, 2022, I was assigned to work on the file of Hilda A. Guzman. I conducted various property and tax searches and identified the owner of the property where the incident involving Ms. Guzman occurred. I also reviewed the location photographs taken by Danny Batista. However, I failed to identify the property as a one-, two- or three family residence and therefore I inadvertently did not add the City of New York as a defendant in the file or designate the case as Municipal in the case file. Sworn to before me before this • '"2>� day of �bee , 2023 &lmij6ER URIBE ���- Notary Public, State of New York "'-•- 'ffiNo.�1UA6402647 "fUal ed In New York County Commission Expires January s, 2024 1