FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF BRONX
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`DELORIS BRADSHAW
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`Plaintiff,
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`-against-
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`ODAI MENWER AL HAJEH, VENTURE LEASING,
`LLC, CB LIVERY LEASING, LLC, UBER
`TECHNOLOGIES, INC., UBER USA, LLC, RASIER-
`NY, LLC, ELF-NY LLC, and LYFT, INC.,
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`Index No.: 811882/2022E
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`VERIFIED ANSWER TO
`AMENDED COMPLAINT
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`Defendants.
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`Defendants, VENTURE LEASING, LLC and CB LIVERY LEASING, LLC, by and
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`through their attorneys, Miller, Leiby & Associates, P.C., as and for their Answer to the Amended
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`Complaint of plaintiff DELORIS BRADSHAW, dated April 26, 2023, set forth upon information
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`and belief as follows:
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`AS AND FOR THE FIRST ALLEGED CAUSE OF ACTION
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`Deny knowledge or information sufficient to form a belief as to the allegations
`1.
`contained in paragraph “1” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`2.
`contained in paragraph “2” of the Amended Complaint.
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`3.
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`4.
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`5.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`6.
`contained in paragraph “6” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`7.
`contained in paragraph “7” of the Amended Complaint.
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`Admit the allegations contained in paragraph “3” of the Amended Complaint.
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`Admit the allegations contained in paragraph “4” of the Amended Complaint.
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`Deny the allegations contained in paragraph “5” of the Amended Complaint.
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`1 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`Deny knowledge or information sufficient to form a belief as to the allegations
`8.
`contained in paragraph “8” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`9.
`contained in paragraph “9” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`10.
`contained in paragraph “10” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`11.
`contained in paragraph “11” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`12.
`contained in paragraph “12” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`13.
`contained in paragraph “13” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`14.
`contained in paragraph “14” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`15.
`contained in paragraph “15” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`16.
`contained in paragraph “16” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`17.
`contained in paragraph “17” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`18.
`contained in paragraph “18” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`19.
`contained in paragraph “19” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`20.
`contained in paragraph “20” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`21.
`contained in paragraph “21” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`22.
`contained in paragraph “22” of the Amended Complaint.
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`2 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`Deny knowledge or information sufficient to form a belief as to the allegations
`23.
`contained in paragraph “23” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`24.
`contained in paragraph “24” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`25.
`contained in paragraph “25” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`26.
`contained in paragraph “26” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`27.
`contained in paragraph “27” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`28.
`contained in paragraph “28” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`29.
`contained in paragraph “29” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`30.
`contained in paragraph “30” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`31.
`contained in paragraph “31” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`32.
`contained in paragraph “32” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`33.
`contained in paragraph “33” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`34.
`contained in paragraph “34” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`35.
`contained in paragraph “35” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`36.
`contained in paragraph “36” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`37.
`contained in paragraph “37” of the Amended Complaint.
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`3 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`Paragraph “44” does not require a response.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`38.
`contained in paragraph “38” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`39.
`contained in paragraph “39” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`40.
`contained in paragraph “40” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`41.
`contained in paragraph “41” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`42.
`contained in paragraph “42” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`43.
`contained in paragraph “43” of the Amended Complaint.
`
`44.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`45.
`contained in paragraph “45” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`46.
`contained in paragraph “46” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`47.
`contained in paragraph “47” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`48.
`contained in paragraph “48” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`49.
`contained in paragraph “49” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`50.
`contained in paragraph “50” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`51.
`contained in paragraph “51” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`52.
`contained in paragraph “52” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`53.
`contained in paragraph “53” of the Amended Complaint.
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`4 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`Deny the allegations contained in paragraph “59” of the Amended Complaint.
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`Deny the allegations contained in paragraph “60” of the Amended Complaint.
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`Deny the allegations contained in paragraph “61” of the Amended Complaint.
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`Deny the allegations contained in paragraph “62” of the Amended Complaint.
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`Deny the allegations contained in paragraph “63” of the Amended Complaint.
`
`Deny the allegations contained in paragraph 64” of the Amended Complaint.
`
`Admit the allegations contained in paragraph “65” of the Amended Complaint.
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`Deny the allegations contained in paragraph “66” of the Amended Complaint.
`
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`54.
`contained in paragraph “54” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`55.
`contained in paragraph “55” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`56.
`contained in paragraph “56” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`57.
`contained in paragraph “57” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`58.
`contained in paragraph “58” of the Amended Complaint.
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`59.
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`60.
`
`61.
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`62.
`
`63.
`
`64.
`
`65.
`
`66.
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`Deny in the form alleged the allegations contained in paragraph “67” of the
`67.
`Amended Complaint.
`
`Deny in the form alleged the allegations contained in paragraph “68” of the
`68.
`Amended Complaint.
`
`69.
`
`70.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`71.
`contained in paragraph “71” of the Amended Complaint.
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`Deny the allegations contained in paragraph “69” of the Amended Complaint.
`
`Deny the allegations contained in paragraph “70” of the Amended Complaint.
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`5 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`Deny knowledge or information sufficient to form a belief as to the allegations
`72.
`contained in paragraph “72” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`73.
`contained in paragraph “73” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`74.
`contained in paragraph “74” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`75.
`contained in paragraph “75” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`76.
`contained in paragraph “76” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`77.
`contained in paragraph “77” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`78.
`contained in paragraph “78” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`79.
`contained in paragraph “79” of the Amended Complaint.
`
`Deny knowledge or information sufficient to form a belief as to the allegations
`80.
`contained in paragraph “80” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`81.
`contained in paragraph “81” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`82.
`contained in paragraph “82” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`83.
`contained in paragraph “83” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`84.
`contained in paragraph “84” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`85.
`contained in paragraph “85” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`86.
`contained in paragraph “86” of the Amended Complaint.
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`6 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`Deny knowledge or information sufficient to form a belief as to the allegations
`87.
`contained in paragraph “87” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`88.
`contained in paragraph “88” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`89.
`contained in paragraph “89” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`90.
`contained in paragraph “90” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`91.
`contained in paragraph “91” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`92.
`contained in paragraph “92” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`93.
`contained in paragraph “93” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`94.
`contained in paragraph “94” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`95.
`contained in paragraph “95” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`96.
`contained in paragraph “96” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`97.
`contained in paragraph “97” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`98.
`contained in paragraph “98” of the Amended Complaint.
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`Deny knowledge or information sufficient to form a belief as to the allegations
`99.
`contained in paragraph “99” of the Amended Complaint.
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`100. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “100” of the Amended Complaint.
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`101. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “101” of the Amended Complaint.
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`7 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`102. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “102” of the Amended Complaint.
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`103. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “103” of the Amended Complaint.
`
`104. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “104” of the Amended Complaint.
`
`105. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “105” of the Amended Complaint.
`
`106. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “106” of the Amended Complaint.
`
`107. Deny the allegations contained in paragraph “107” of the Amended Complaint.
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`108. Deny the allegations contained in paragraph “108” of the Amended Complaint.
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`109. Deny the allegations contained in paragraph “109” of the Amended Complaint.
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`110. Deny the allegations contained in paragraph “110” of the Amended Complaint.
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`111. Deny the allegations contained in paragraph “111” of the Amended Complaint.
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`112. Admit that defendant ODAI MENWER AL HAJEH was a lessee of, and authorized
`to operate, the 2018 Toyota bearing NY license plate T766503C and otherwise deny in the form
`alleged the allegations contained in paragraph “112” of the Amended Complaint.
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`113. Deny the allegations contained in paragraph “113” of the Amended Complaint.
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`114. Deny the allegations contained in paragraph “114” of the Amended Complaint.
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`115. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “115” of the Amended Complaint.
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`116. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “116” of the Amended Complaint.
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`117. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “117” of the Amended Complaint.
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`118. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “118” of the Amended Complaint.
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`8 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`119. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “119” of the Amended Complaint.
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`120. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “120” of the Amended Complaint.
`
`121. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “121” of the Amended Complaint.
`
`122. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “122” of the Amended Complaint.
`
`123. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “123” of the Amended Complaint.
`
`124. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “124” of the Amended Complaint.
`
`125. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “125” of the Amended Complaint.
`
`126. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “126” of the Amended Complaint.
`
`127. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “127” of the Amended Complaint.
`
`128. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “128” of the Amended Complaint.
`
`129. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “129” of the Amended Complaint.
`
`130. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “130” of the Amended Complaint.
`
`131. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “131” of the Amended Complaint.
`
`132. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “132” of the Amended Complaint.
`
`133. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “133” of the Amended Complaint.
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`9 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`134. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “134” of the Amended Complaint.
`
`135. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “135” of the Amended Complaint.
`
`136. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “136” of the Amended Complaint.
`
`137. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “137” of the Amended Complaint.
`
`138. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “138” of the Amended Complaint.
`
`
`AS AND FOR THE UBER DEFENDANTS
`
`
`139. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “139” of the Amended Complaint.
`
`140. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “140” of the Amended Complaint.
`
`141. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “141” of the Amended Complaint.
`
`142. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “142” of the Amended Complaint.
`
`143. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “143” of the Amended Complaint.
`
`144. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “144” of the Amended Complaint.
`
`145. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “145” of the Amended Complaint.
`
`146. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “146” of the Amended Complaint.
`
`147. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “147” of the Amended Complaint.
`
`148. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “148” of the Amended Complaint.
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`10 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`149. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “149” of the Amended Complaint.
`
`150. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “150” of the Amended Complaint.
`
`151. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “151” of the Amended Complaint.
`
`152. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “152” of the Amended Complaint.
`
`153. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “153” of the Amended Complaint.
`
`154. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “154” of the Amended Complaint.
`
`155. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “155” of the Amended Complaint.
`
`156. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “156” of the Amended Complaint.
`
`157. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “157” of the Amended Complaint.
`
`158. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “158” of the Amended Complaint.
`
`159. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “159” of the Amended Complaint.
`
`160. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “160” of the Amended Complaint.
`
`161. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “161” of the Amended Complaint.
`
`162. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “162” of the Amended Complaint.
`
`163. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “163” of the Amended Complaint.
`
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`11 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`164. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “164” of the Amended Complaint.
`
`165. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “165” of the Amended Complaint.
`
`166. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “166” of the Amended Complaint.
`
`167. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “167” of the Amended Complaint.
`
`168. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “168” of the Amended Complaint.
`
`169. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “169” of the Amended Complaint.
`
`170. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “170” of the Amended Complaint.
`
`171. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “171” of the Amended Complaint.
`
`172. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “172” of the Amended Complaint.
`
`173. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “173” of the Amended Complaint.
`
`174. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “174” of the Amended Complaint.
`
`175. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “175” of the Amended Complaint.
`
`
`AS AND FOR LYFT, INC.
`
`
`176. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “176” of the Amended Complaint.
`
`177. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “177” of the Amended Complaint.
`
`178. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “178” of the Amended Complaint.
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`12 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
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`INDEX NO. 811882/2022E
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`RECEIVED NYSCEF: 05/24/2023
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`179. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “179” of the Amended Complaint.
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`180. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “180” of the Amended Complaint.
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`181. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “181” of the Amended Complaint.
`
`182. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “182” of the Amended Complaint.
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`183. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “183” of the Amended Complaint.
`
`184. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “184” of the Amended Complaint.
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`185. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “185” of the Amended Complaint.
`
`186. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “186” of the Amended Complaint.
`
`187. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “187” of the Amended Complaint.
`
`188. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “188” of the Amended Complaint.
`
`189. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “189” of the Amended Complaint.
`
`190. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “190” of the Amended Complaint.
`
`191. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “191” of the Amended Complaint.
`
`192. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “192” of the Amended Complaint.
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`193. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “193” of the Amended Complaint.
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`13 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
`
`INDEX NO. 811882/2022E
`
`RECEIVED NYSCEF: 05/24/2023
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`194. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “194” of the Amended Complaint.
`
`195. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “195” of the Amended Complaint.
`
`196. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “196” of the Amended Complaint.
`
`197. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “197” of the Amended Complaint.
`
`198. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “198” of the Amended Complaint.
`
`199. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “199” of the Amended Complaint.
`
`200. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “200” of the Amended Complaint.
`
`201. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “201” of the Amended Complaint.
`
`202. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “202” of the Amended Complaint.
`
`203. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “203” of the Amended Complaint.
`
`204. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “204” of the Amended Complaint.
`
`205. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “205” of the Amended Complaint.
`
`206. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “206” of the Amended Complaint.
`
`207. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “207” of the Amended Complaint.
`
`208. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “208” of the Amended Complaint.
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`14 of 58
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`FILED: BRONX COUNTY CLERK 05/24/2023 01:25 PM
`NYSCEF DOC. NO. 51
`
`INDEX NO. 811882/2022E
`
`RECEIVED NYSCEF: 05/24/2023
`
`
`
`209. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “209” of the Amended Complaint.
`
`210. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “210” of the Amended Complaint.
`
`211. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “211” of the Amended Complaint.
`
`212. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “212” of the Amended Complaint.
`
`213. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “213” of the Amended Complaint.
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`AS AND FOR THE ALLEGED ACCIDENT
`
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`214. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “214” of the Amended Complaint.
`
`215. Deny knowledge or information sufficient to form a belief as to the allegations
`contained in paragraph “215” of the Amended Complaint.
`
`216. Deny knowledge or information sufficient to form a belief as to the allegations
`co