Motion-Secondary: Alyssa Jones v. Catrena Magwood, Michael Washington

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                                UD)                               OUN              IK                                    04   DV                 INDEX    NO.   509682/2015
NYSCEF         BOC.      NO.          14                                                                            RECEIVED   NYSCEF     10/19/2016




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF KINGS
                       ana        a              re eee nent     tie eee     ee!                  x
                  ALYSSA JONES and NJ an Infant under the age of
                  16 years by her Mother and Natural Guardian
                  ALYSSA JONES and ALYSSA JONES Individually,                                                AFFIRMATION IN
                                                                                                               OPPOSITION
                                                                                   Plaintiff(s)
                                                                                                            Index No.: 509682/15
                                                     - against -

                  CATRENA MAGWOOD                         and MICHAEL
                  WASHINGTON,

                                                                             Defendant(s)
                  ae         ee                   te ne          nee       nee    ee    eee


                                  Andrew Fuchs, Esq., an attorney duly admitted to practice law before the Courts

                  of New York State, affirms the following under penalties of perjury based upon a review

                  of the file and upon information and belief:
                         4
                                  | am associated with the law firm of JAMES G. BILELLO & ASSOCIATES,

                  attorneys for the defendant(s), Catrena Magwood                           and Michael Washington, and as

                  such, | am fully familiar with the facts and circumstances of this matter. The source of

                  my knowledge is the files and records maintained by said law firm.

                        2         | submit this affirmation in opposition to Plaintiff's motion for summary judgment.

                        3.        On October 11, 2016, after receiving resuits from an investigator, your affirmant

                 was finally able to get in touch with his client-driver, Michael Washington’s, sister,

                 Vanessa Washington. Ms. Washington informed your affirmant that Michael Washington

                 is currently serving in the United States Navy. She did not.have any contact information

                 for her brother and did not know where he is stationed, but she told me that she would

                 give Mr. Washington my phone number when he called her next.




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4      In light of this new development, your affirmant asks that this motion be

adjourned for at least several months so that he can obtain an affidavit from his client to

oppose Plaintiff's motion on the merits.

   WHEREFORE,          it is respectfully requested that Plaintiff's motion be adjourned for at

least several months, and for such other and further relief as this court deems just and

proper.

                                                              fot   Fr
Dated: Hicksville, New York                                 a

                                                      LA
          October 12, 2016

                                             Andrew Fuchs, Esq.
                                             JAMES G. BILELLO & ASSOCIATES
                                             15K2105
                                             Attorneys for Defendant(s)
                                             Catrena Magwood
                                             Michael Washington
                                             100 Duffy Avenue, Suite 500
                                             Hicksville, NY 118014
                                             516-861-1758
                                             Our File No.: 15K2105




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Index # 509682/15

 SUPREME COURT OF THE STATE OF NEW YORK
 COUNTY OF KINGS
(ee

 ALYSSA     JONES    and NJ an Infant under the age of 16 years by her Mother
 and Natural Guardian ALYSSA JONES             and ALYSSA JONES         Individually,
                                                                     Plaintiff(s)

                                          -against-

 CATRENA MAGWOOD              and MICHAEL WASHINGTON,
                                                                      Defendant(s)




                     naiineninnrs                                    ED             =   eat

                             JAMES G. BILELLO & ASSOCIATES
                                 Attorneys for the Defendant(s)
                          Catrena Magwood and Michael Washington
                                    Office and Post Office Address
                                     100 Duffy Avenue, Suite 500
                                         Hicksville, NY 11801
                                             516-861-1758
      EE                                  oe                LETTE

 Levine and Wiss, PLLC
 Attorneys for Piaintiff(s)
 ALYSSA JONES and NJ
 510 Hempstead Tpke., Suite 206
 West Hempstead, NY 11552
 516-747-3222




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