On September 12, 2023 a
EXHIBIT(S) - 1 (Motion #001) - Affidavit of Merit
was filed
involving a dispute between
Natasha Valentin Cepeda,
and
Elizabeth T. Churchill,
Stephen K Churchill,
for Torts - Motor Vehicle
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 10/10/2023
Exhibit 1
FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 10/10/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
--------------------------------------------------------------------X Index No.:
NATASHA VALENTIN CEPEDA,
Plaintiff
-against- AFFIDAVIT OF MERIT
ELIZABETH T. CHURCHILL AND
STEPHEN K. CHURCHILL,
Defendants.
____________________________________________________________________Ç
STATE OF NEW YORK )
) ss.:
COUNTY OF NEW YORK )
NATASHA VALENTIN CEPEDA, being duly sworn, deposes and says that:
42nd
1. I am over the age of 18 and I reside at 21006 Avenue Apt 2D Bayside, NY
11301.
attorneys'
2. I make this affidavit in support of my within motion for a default
judgment against the Defendants, ELIZABETH T. CHURCHILL AND STEPHEN K.
CHURCHILL, herein pursuant to CPLR 3215.
3. I am the Plaintiff in the above captioned action.
4. The above-entitled action was brought by me against the Defendants for the severe
and personal injuries which I sustained as a sole result of the carelessness, recklessness and
negligence of the Defendants herein.
5. On or about July 17, 2023, I was caused to be involved in a motor vehicle accident
at or near Long Island Expressway Near Exit 19. More specifically, I was operating my motor
vehicle. The vehicle owned, operated, and controlled by Defendants then struck my vehicle while
traveling at a high rate of speed, thereby creating the dangerous and perilous condition which
FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 10/10/2023
caused my accident.
6. Due to said accident, I was caused to sustain severe and personal injuries of a
debilitating nature with lifelong residuals.
7. I have conferred with my attorneys and firmly believe that I have a good and
meritorious cause of action.
attorneys'
8. Wherefore, I respectfully request that my motion for a default judgment
against the Defendants, ELIZABETH T. CHURCHILL AND STEPHEN K. CHURCHILL, be
granted.
ATASHA VALENTIN CEPEDA
STATE OF NEW YORK )
) ss.:
COUNTY OF )
On the \ day of rÅ before me, the undersigned, a notary
public
to me or proved
in and for said State,
to me on the basis
personally appeare evidence to be the
ersonally
whose
known
of satisfactory individual(s)
name(s) is (are) subscribed to the within instrument and acknowledged to me that he/she/they
executed the same in his/her/their capacity(ies), and that by his/her/their signature(s) on the
instrument, the individual(s), or the person upon behalf of the individual(s) acted, executed the
instrument.
NICHOLASR VINCENT
GONCHAR
NOTARY
PUBLIC,STATE0FNEWYORK
ReghtrationNo.02GO6414501
QualmedIn Richmond
County
Comadsalon
Expires
February22,2025
Document Filed Date
October 10, 2023
Case Filing Date
September 12, 2023
Category
Torts - Motor Vehicle
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Preview
FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 10/10/2023 Exhibit 1 FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 10/10/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS --------------------------------------------------------------------X Index No.: NATASHA VALENTIN CEPEDA, Plaintiff -against- AFFIDAVIT OF MERIT ELIZABETH T. CHURCHILL AND STEPHEN K. CHURCHILL, Defendants. ____________________________________________________________________Ç STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) NATASHA VALENTIN CEPEDA, being duly sworn, deposes and says that: 42nd 1. I am over the age of 18 and I reside at 21006 Avenue Apt 2D Bayside, NY 11301. attorneys' 2. I make this affidavit in support of my within motion for a default judgment against the Defendants, ELIZABETH T. CHURCHILL AND STEPHEN K. CHURCHILL, herein pursuant to CPLR 3215. 3. I am the Plaintiff in the above captioned action. 4. The above-entitled action was brought by me against the Defendants for the severe and personal injuries which I sustained as a sole result of the carelessness, recklessness and negligence of the Defendants herein. 5. On or about July 17, 2023, I was caused to be involved in a motor vehicle accident at or near Long Island Expressway Near Exit 19. More specifically, I was operating my motor vehicle. The vehicle owned, operated, and controlled by Defendants then struck my vehicle while traveling at a high rate of speed, thereby creating the dangerous and perilous condition which FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 10/10/2023 caused my accident. 6. Due to said accident, I was caused to sustain severe and personal injuries of a debilitating nature with lifelong residuals. 7. I have conferred with my attorneys and firmly believe that I have a good and meritorious cause of action. attorneys' 8. Wherefore, I respectfully request that my motion for a default judgment against the Defendants, ELIZABETH T. CHURCHILL AND STEPHEN K. CHURCHILL, be granted. ATASHA VALENTIN CEPEDA STATE OF NEW YORK ) ) ss.: COUNTY OF ) On the \ day of rÅ before me, the undersigned, a notary public to me or proved in and for said State, to me on the basis personally appeare evidence to be the ersonally whose known of satisfactory individual(s) name(s) is (are) subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their capacity(ies), and that by his/her/their signature(s) on the instrument, the individual(s), or the person upon behalf of the individual(s) acted, executed the instrument. NICHOLASR VINCENT GONCHAR NOTARY PUBLIC,STATE0FNEWYORK ReghtrationNo.02GO6414501 QualmedIn Richmond County Comadsalon Expires February22,2025